VIQ Bulletin From 1 To 17

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Issue 1

Inspector Bulletin Latest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

Introduction - Inspector Bulletin

Welcome to the first edition of this inspector news Examples of Good Observations
specifically here to share observations, OCIMF
guidance, material from clients/operators and any
I would like to share a number of good observations noted in the last few months;
other related feedback. I want to encourage you all to
share any feedback that you have so that we can all
Q) 4.3 Vessel was on voyaged of 1 to 2 days but steering gear tests as per SOLAS V/26.5
learn from any specific situations onboard without
(power unit failure alarms) were not carried out once a week or prior every departure.
naming names or vessels here. Please let me know your
PMS records indicated alarms were tested annually and last done on 18 Sep 2018.
thoughts and remember that no question is too stupid
to ask if you are ever in doubt over any issues do let me
Q) 5.4 During testing of the steering system for the freefall lifeboat, the officers were
know. As we also have engineers on our network team I
not able to demonstrate how to engage the emergency steering function.
would also welcome their professional input to any
The steering system was hydraulic and the activation of the system required the main
technical points that come about.
steering system to be operated by opening a bypass valve. (I have come across this on
=========================================
a number of occasions as the crew often think they can just engage the manual tiller
and push either side)
VIQ 7 – Initial Feedback
Q) 5.26 There was no record for annual inspection of the oxygen and acetylene cylinder
It’s been over 3 months since the introduction of the gas regulators. This is a common finding with the new VIQ
VIQ and there have been a number of points raised from
the practicality of completing an inspection now within Q) 5.43 The air compressor for charging the breathing
the 8 - 10 hours guidance period to errors identified in apparatus, EEBD and lifeboat air cylinders was fitted with
the actual guidance notes themselves. As a a 330 bar safety relief valve. Whilst this was correct for
self-improvement tool we encourage all inspectors to the BA sets which had 300 bar operating cylinders the
review the operators comments to their reports as EEBD and lifeboat air cylinders operating pressure was
discrepancies have been raised by operators identifying 200 bar and as such it would be possible to over
incorrect guidance or misunderstandings in raised pressurise the air cylinders when recharging them. (Also a
observations. We do however all know many operators common observation. There is a kit that can be fitted
will seek to challenge every item and discredit the here as an example to show what to look for)
inspector, hence it is important that all observations
raised are both factual and clear especially when 225 barge relief valve fitted to the side here.
referencing to regulation. Where there is doubt on the
inspectors side then I would encourage you to give
benefit of the doubt, but also do feel free to seek Q) 6.21 Two approved Ballast Water Management Systems (BWTS) available on board.
further guidance from myself and/or client on the Both systems were reportedly operating good and was recorded as in use during
issues. normal cargo operations as per the on board Ballast Water
Management Plan and the operator's procedures.
The initial observation list left or discussed with the
The BWTS on board required the ballast water to be treated both during ballasting and
master is just that, but at the same time observations
during de-ballasting. However, according to the maker's manual the BWTS' seawater
may well need tweaking for clarity in the final report,
temperature lower limit was 3,0 deg. C. The seawater temperature at the port of
though should not be changed within the meaning of
inspection was 1,9 deg. C only and the BWTS could thus not be operated during
the observation itself.
ballasting.
The operator's procedures for actions to be taken in case of BWTS failure, defect and/
or if the 'quality of the uptake water challenged the BWTS' (The uptake water outside
the BWTS design limits) required the vessel to inform the operator on a dedicated
'critical equipment defect report' and the
SIRE Inspection Report
operator to inform class and/or the flag state regarding the intake of non-treated
ballast water.
The operator were then to agree with class/flag upon an action plan and inform the
vessel of same. Further the operator were to inform the PSC authority at the ballast
water discharge port.
The vessel had informed the operator by phone only.
There was no documentation on board that flag and/or class had been informed by the
operator. The vessel planned to do an ordinary ballast water exchange on route to the
next load port.

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Issue 1

Inspector Bulletin Latest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

Examples of Good Observations


Q) 8.50 There was no record of monitoring the slew

VIQ -7 Discrepancies
bearing of the hose handling crane. (Also a common
finding with the new VIQ)

Q) 10.32 The alarm panel in the engine control room This comment is unclear in that it may also include drug testing that
when checked was found to have 22 suppressed alarms. generally would not be done so frequently.
These included the following:
MDO Tank high level alarm • VIQ 5.30 Is the rescue boat, including its equipment and launching arrangement, in
Main engine air temperature cooler inlet alarm good order and officers’ familiar with the launch procedures?
Main engine fuel oil leak high level alarm
HFO Service tank No.2 high level alarm Propeller guard. Each propeller on a lifeboat must be fitted with a propeller guard with a
Also the following alarms were suppressed due to sensor maximum opening of 76 mm (3 in) on all sides on which a person is likely to be exposed.
failures: (46 CFR 160.135.7(10)
HFO Storage Tank Port side level alarm
HFO Settling tank Port side high level alarm Various OCIMF members are treating this in different ways from the replies that we have
seen. The USCG have confirmed the following “The requirements outlined in 46 CFR 160
=============================================== are applicable to lifeboat manufactures that wish to receive a U.S. Coast Guard type
approval number for their product. For foreign ships operating in the U.S., SOLAS
approved lifeboats are acceptable.” Hence if the lifeboat and rescue boat meet SOLAS
VIQ -7 Discrepancies requirements and NOT US flagged then this does not appear to constitute an
observation.
Through feedback and discussions we have identified the
following discrepancies within the VIQ to date. I would
encourage you all to share any other points that you have
also identified. OCIMF are aware of these;

• VIQ 3.2 Are the STCW and flag Administration’s


regulations that control hours of work to minimise
fatigue being followed and are all personnel maintaining
hours of rest records in compliance with MLC or STCW
requirements?

The Inspector should record an observation:


a failure by the manager to acknowledge Similarities with questions under Chapter 5;
significant levels of non-conformance (3 or
more days containing “non-conformance” by
5.4) Are the ship's officers able to demonstrate their familiarisation with the
any individual on board)
operation of fixed and portable firefighting, lifesaving and other emergency
The guidance lacks clarity in that it does not equipment?
state within what time period i.e. 3 or more 5.12) Are the crew familiar with the location and operation of fire and safety
days in any calendar month. equipment and have familiarisations been effectively completed for all staff?
5.15) Is there evidence of regular training in the use of life-saving equipment
• VIQ 3.8 Does the operator have measures in place undertaken and are crew familiar with those requirements and the location /
to prevent Drug and Alcohol abuse in accordance with contents of the training manuals?
OCIMF guidance? 5.27) Are the officers aware of the requirements of LSA, are there ship-specific
life-saving equipment maintenance instructions available and are weekly and
As a general rule the frequency of onboard monthly inspections being carried out?
unannounced testing shall be less than the 5.35) Are the crew aware of the fixed firefighting equipment fitted, are ship
shortest contract period on board to act as an
specific firefighting equipment maintenance instructions available and is
effective deterrent.
maintenance being carried out?
5.40) Are the crew familiar with the fixed fire extinguishing systems, where
fitted, are they in good order and are clear operating instructions Posted?

AWP Marine Consultancy Ltd


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Issue 1

Inspector Bulletin Latest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

Can any of our LNG experts identify


what this device is for??
VIQ -7 Discrepancies
• VIQ 8.27 and 8.37 (oil and chems) Is the liquid level in the deck seal at the correct level, clearly
visible and are officers aware of requirements to periodically check the level? Some guidance in that
the use of double block and bleed systems is safely approved as alternative should be included here.
• VIQ 8.30 Are officers and ratings aware of safe entry requirements for the inert gas room(s), are
these procedures being followed and where applicable, is fixed oxygen detection provided? Vessels
delivered on, or after 01 Jan 2016, two oxygen sensors shall be positioned at appropriate locations in the
space or spaces containing the inert gas system.
These amendments entered into force on 1
January 2016, so only apply to ships the keels
of which are laid or which are at a similar
stage of construction, on or after the date. The
guidance should state: Vessels, the keels of
which are laid or which are at a similar stage
of construction, on or after 01 Jan 2016.
• VIQ 9.7 Is there a policy in place for the
testing of winch brakes and are the results
recorded?
Clarity in guidance to align with the MEG4 on
60% MBL of the line to 60% ship design MBL.
This is a barrier punch device used in
The Line Design Break Force (LDBF) shall be
emergency situations to penetrate 100-105% of the ship design Minimum
the membrane in the bottom of the Breaking Load (MBL)
tank. The punch device is inserted
into the float gauge standpipe on
VIQ 9.11 On split drum winches are all the lines made fast with no more than one layer on each
the trunk deck and the bottom of tension side of the drum?
the standpipe fitted with a split If guidance is not available, a minimum of eight turns should be used.
perforated base to allow the
messenger to penetrate through to MEG4 refers to the above under 5.7.6.2. However, 6.3.3.1 also states
the membrane. The invar “As a general guideline allow for the following:
membrane is fitted with a thin • A minimum of ten turns for steel wire rope and HMSF mooring lines .
diaphragm and the plywood • A minimum of five to six turns for conventional fibre mooring lines.”
insulation box thinner than normal
Obviously this is a little confusing but I believe we
to allow penetration. This need treat this in the sense that in all cases there
operation is necessary only in the should be eight turns minimum, but if the makers
event of damage to the membrane have provided guidance on the vessel and then in the
such that LNG accumulates as a line management plan this can be accepted if less. I
also believe there needs to be some leeway here as if
liquid within the primary barrier
just one winch has one turn too little it would be fair
space rising up the lower chamber to verbally point out to the vessel is the staff are well
and sidewalls as if liquid remained in aware of the requirements. We are after all
the sidewalls when the tank was conducting a risk assessment and not trying to gain
pumped out then severe damage points alone and our professional judgement should
be considered.
would occur.
There is also of course the issue that if there is to be 10 turns are the split drums actually designed with
this capability as you can see from the photo here you possibly will be struggling to get 10 turns on the
drum first layer. New builds will have this considered moving on but existing vessels will be struggling
here.

AWP Marine Consultancy Ltd


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Issue 1

Inspector Bulletin Latest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

OCIMF Information Papers

OCIMF have recently published a number of information Testing of Machinery Alarms


papers and I would encourage you to read these and use
in relation to the SIRE inspections you perform. The VIQ 10.21 If the vessel class notation allows UMS operation, are main engine bearing
information papers can be downloaded from the OCIMF temperature monitors, or the crankcase oil mist detector, in good order?
website on the following link; https://www.ocimf.org/ Testing of the detector alarm can be carried out either electronically or by removing a
publications/information-papers.aspx cover and blocking the sensor path , in accordance with manufacturer’s instructions.

The photo shows a Visatron typical oil mist


detector alarm. Many engineers demonstrate
the alarm function by removing the two clips on
the face of the unit and that has the immediate
effect of causing an alarm on the vacuum failure
rather than testing the actual oil mist sensor.
Hence its good practise to look in the makers
instruction how to test the unit but I would
expect them to remove the centre plug in this
case and feed smoke into the unit or remove the
cover, place a plastic seal on the unit to prevent
the vacuum alarm and insert an opaque screen
that will set off the oil mist sensor alarm itself.

The picture is of a float type oil


leakage alarm fitted to an
auxiliary engine. Sometimes the
engineers offer to test this from
the electrical junction box circled
Forecastle Overboard Valves in yellow removing the cover and
bridging the alarm. I would
VIQ 6.10 Are the arrangements for the disposal of oily suggest physically checking the
water in the forecastle and other internal spaces float is operative as this can get
adequate and are officers aware of these requirements? stuck with sludge.
Where hand pumps or ejectors are fitted, pollution
prevention notices should be posted and the overboard
valves should be secured against accidental opening. The pictures here show the testing of the splash oil monitoring for the main engine.
This system acts as a pre failure warning of the engine bearings much sooner than the
I often come across the overboard valves from forecastle oil mist detection.
spaces padlocked closed and no key available for
emergency use. This is unacceptable and the valves
should be sealed with a breakable seal to prevent
accidental opening whilst at the same time able to open
in an emergency.

———————————————————————————————————

Hope you find the first edition here useful and I also hope that
it encourages you all to share your feedback here.

Disclaimer: this material discusses OCIMF activities based on personal experience and opinion and
not necessarily in agreement with OCIMF or OCIMF members views.

AWP Marine Consultancy Ltd


EMAIL: admin@awpmarine.com TELEPHONE: +44 (0) 151 792 4882
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Issue 2

Inspector Bulletin Latest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

Competence Assessment
This is proving to be a very controversial issue with the
inspections and I believe there are a number of areas
What all drivers from the UK may need to do to drive in the EU
that should be addressed here to ensure that the
competence based questions are correctly addressed.
and EEA when the UK leaves the EU.
My thoughts which I hope will open up discussions;
With the Brexit so clear as mud the following guidance may not be so clear
 Inspectors have no formal training with OCIMF either, but this is just to make UK inspectors aware of the additional
on competence assessment (such as IMO Model requirements in the event of hiring a car and driving in Europe after the UK
Course 1.30 or NI Assessing Behavioural
leaves. Correction IF the UK leaves the EU.
Competence Onboard Course )

 There is little guidance in the VIQ under the


https://www.gov.uk/guidance/prepare-to-drive-in-the-eu-after-brexit
competence questions to help inspectors and ========================================================================
operators judge the expectations here
My thanks to colleagues for raising the following awareness discussion;
 The inspectors are approaching this with such
varying levels of questioning from virtually Q3.2 Are the STCW and flag Administration’s regulations that control hours of work to
nothing asked on competence (treating the VIQ minimise fatigue being followed and are all personnel maintaining hours of rest records
questions as physical yes / no items eg Do you in compliance with MLC or STCW requirements?
have a VRP rather than can you tell me the main
purpose of a VRP etc) to COC questioning as The previous guidance in the VIQ it was clearly stated that for 3 or more violations (day)
with in the orals examination for national in a calendar month an observation should have been recorded.
certificates (rule of the road, stability, This is not the case any longer and the guidance now states:
regulations etc etc)
The Inspector should record an observation:
All parties would benefit here if guidance and training • If “any 24 hours” is not interpreted literally, or
was introduced by OCIMF on the subject questions. I • a lack of evidence of conformance/non-conformance calculations, or
believe the stance and approach should be based • any lack of evidence that managers are informed at least monthly of compliance levels
around ascertaining the crew members understanding on board, or
of his/her roles and actions to safely perform their job • a failure by the manager to acknowledge significant levels of non-conformance (3 or
onboard. COC’s have been issued by approved more days containing “non-conformance” by any individual on board)
government bodies specifically trained here to
determine a level of competence to meet a rank. A SIRE Under existing VIQ guidance, most of the inspectors reportedly are following the same
inspector on the other hand should be there to verify concept used for the previous guidance and at the same time the Operators claim and
that the crew are operating the vessel safely and are under the impression that, as long they acknowledge the “3 days non-conformance”
specifically in accordance with international and issue, an observation should not be recorded.
company standards.
Another view of this is that if OCIMF consider 3 or more days containing “non-
conformance” by any individual on board a significant level of non-conformance, then
up to 2 days containing “non-conformance” by any individual on board could be
considered in any case a level of non-conformance and should be reported. In fact the
guidance does not specify any longer the number and the days needed before the
inspector should record an observation.

Let’s look at an example, a total of seven violations were recorded in a month,


regardless of how many for each crew member, an observation would have been
appropriate since the record was indicating that there was an issue with rest hours.
Another consideration that could be made is that the guidance leaves it up to the
inspector to decide to record an observation in respect of violations (number and days)
and in case of 3 or more days containing “non-conformance” by any individual on
board, evidence of the management acknowledgement (and corrective actions) should
be available. If not in addition to the observation for the violations an observation for
lack of acknowledgement could be considered here basis the risk involved.

AWP Marine Consultancy Ltd


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Issue 2

Inspector Bulletin Latest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

2020 Sulphur Cap – Guidance

On October 27, 2016 the International Maritime


Organisation (IMO) agreed that the sulphur content of Q5.45 Are fire flaps clearly marked to indicate the spaces they serve and is there
fuel oils used on board ships shall not exceed 0.50%m/ evidence of regular testing and maintenance?
m from 1 January, 2020.
Battery locker vent flaps should always be kept open to prevent a build up of gas within
The Singapore MPA have provided some very useful
the space. Reference should be made to IACS Unified Interpretation SC 240.
guidance here for compliance that I encourage all our
inspectors to read to be prepared for the forthcoming
There are critical safety factors to take into account when considering closing devices
date of implementation and actions required.
for battery rooms. A closing device may be necessary for the vessel to comply with
intact and/or damage stability requirements, or to provide a weather-tight closing
device to satisfy the Load Line Convention, or where a fixed gas fire extinguishing
system is provided. However, Regulation II-2/5.2.1.1 does not take into account the
specific hazards associated with battery rooms; the possible build up of explosive gases
(most notably hydrogen) is a primary safety concern.
In light of this, the Unified
Interpretation specifies that in
all cases where a closing device
is provided, the ventilation
opening should have a clear
warning notice stating, for
example, “This closing device is
to be kept open and only
closed in the event of fire or
https://www.mpa.gov.sg/web/wcm/connect/ other emergency – Explosion
www/203f204f-7f13-4d5d-8b7f-3c7c78cba828/ risk”.
rb183260_mpa_imo2020_brochure_ship_calling_to_sg
_v9.pdf? Q 5.40 Are the crew familiar with the fixed fire extinguishing systems, where fitted, are
MOD=AJPERES&attachment=true&id=1542864257689 they in good order and are clear operating instructions posted?

I have come across a number of vessels where the water mist system is set to local
https://www.mpa.gov.sg/web/wcm/connect/www/ control only. It appears that there could have been faults / sensitivity issues with the
cc5f5846-1ad2-4d75-950c-c13545f4aa6a/ sensors that have caused the systems to operate and as a result they have been set to
rb183260_mpa_imo2020_brochure_srs_v9.pdf? local control only, hence making
MOD=AJPERES&attachment=true&id=1542864162360
auto operation impossible. This is
especially a problem if the space
containing the local control is
also smoke filled or part of the
fire. We urge inspectors to check
to ensure the system is set to
“ Our company goals are simply stated auto mode operation and also
with the target towards No accidents, No verifying the water supply valve is
open from the tank.
incidents and No negative feedback from
our customers and Employees ”
I hope you find this edition useful here and I that it encourages you all to share
your feedback.
Disclaimer: this material discusses OCIMF activities based on personal experience and opinion and not necessarily
in agreement with OCIMF or OCIMF members views.

AWP Marine Consultancy Ltd


EMAIL: admin@awpmarine.com TELEPHONE: +44 (0) 151 792 4882
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Issue 3

Inspector Bulletin Latest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

Sea Service Verification


3.5 Does the officers’ matrix posted for the vessel
on the SIRE website accurately reflect the
ADMIRALTY Guide to ECDIS Implementation,
information relating to the officers on board at
Policy and Procedures (NP232)
the time of the inspection?
Inspectors should spot check discharge book / sea
service records to verify the accuracy of information Inspectors should note there is a new edition of the
within the matrix. above publication released that now includes
guidance on periodic maintenance of the ECDIS,
annual inspection tests, failure drills and a full
section addressing cyber security issues.

Designated Two-Way Portable Radio Equipment

4.26 Is the vessel equipped with sufficient intrinsically safe portable


radios for use on deck?
Sufficient portable radios should be available to allow communications between the cargo
We are coming across operators that are providing
control, the deck officer, the deck watch and the master, as well as the pump man if
little evidence of experience onboard as the required.
discharge books are often issued on a 5 year basis
in many countries/flags hence the officers tend to 5.43 Are crew members familiar with donning breathing apparatus and are
have only the most recent discharge book records Fireman’s Outfits in good order and ready for immediate use?
onboard and this is then causing issues for seeking For ships constructed on or after 1 July 2014, a minimum of two two-way portable
verification evidence. Officers need to maintain radiotelephone apparatus for each fire party for fire-fighter's communication shall be
evidence of their sea service experience in ranks carried on board. Those two-way portable radiotelephone apparatuses shall be of an
and on tankers as this will lead to observations if explosion-proof type or intrinsically safe. Ships constructed before 1 July 2014 shall
evidence is unavailable. comply with the requirements of this paragraph not later than the first survey after 1 July
2018. (SOLAS II-2/10.4)
Some flags such as the Danish Maritime
Administration have since 2017 maintained
records of sea service electronically such that each
seafarer will log in to their own portal to record
the sea service time. These are subject to random
verifications by the DMA. This is likely to be
further advanced in future such that all seafarers
will be able to verify on the masters computer
system such verifications.

“ Our company goals are simply stated


There is no requirement for the radio equipment to be located by the Fireman’s
with the target toward No accidents, No outfits. However, as this is mandatory fire fighting equipment the radios shall be
incidents and No negative feedback from in a known position clearly identified with IMO symbols and easily located in an
emergency. If the radios are in a separate location then the muster list shall
our customers and Employees ” designate person(s) responsible for bringing the radios to the muster station /
BA control station.

AWP Marine Consultancy Ltd


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Issue 3

Inspector BulletinLatest updates & News feeds for Inspectors.

Experience Transfer Advice and Guidance Regulation Updates

Basic Instructions to Visitors

5.12 Are the crew familiar with the location Incident - Inspector Travel
and operation of fire and safety
equipment and have familiarisations been Standard Scam in Spain
effectively completed for all staff?
The company should establish procedures to Recently this last weekend one of our inspectors was subject to a scam resulting in his computer,
ensure that new personnel and personnel passport and documentation stolen from his car. Below is an extract in the inspectors words as to
what happened;
transferred to new assignments related to
safety and protection of the environment are I was driving on the highway from Barcelona towards Castellon after hiring the car at Barcelona
given proper familiarization with their duties. airport. Since my phone charging cables etc were in my computer bag.. I placed it on the passenger
For visitors to the vessel who visit the vessel for seat for easy access.
short periods of time, i.e. 2 to 3 days, basic Just before the exit for Tarragona a car on left began to overtake but then maintained the same
speed going slightly ahead and falling back. After some time a man on the passenger side began
familiarisation must be completed upon
gesticulating towards my left rear tyre...being a rental car I thought something could be the
boarding, and no later than 24 hours after problem...he quickly pulled ahead of me and started slowing down showing his indicator. I had no
joining. choice but to pull up behind him on the right shoulder. He braked hard so that I was close behind him.
The man came out and with gestures asked me to come out and check the rear tyre. He kept bending
down and pointing to the brake disc. I also bent down and he took of the air filling cap and asked if I
7.12 Is an adequate deck watch being
spoke Italian.. I said no and he said get get your tools and check. He suddenly left and went to his car
maintained to prevent unauthorised and they sped off. I also got in and started to drive. After a few minutes I noticed the “door open“
access in port? warning on the dashboard.. I banged my door shut but then it turned to be the passenger side door
and when I started to close it realized my computer bag had disappeared! I then first tried to call the
rental company. No response. Then 112 and went down to Tarragona to lodge my complaint..
I often find that on boarding a vessel a
significant range of guidance provided from We have received feedback here from another local based inspector which is very much
absolutely nothing except a cursory check of appreciated and shared here.

ID and a plastic card provided with just a


number on the card to a very clear instruction Sadly this is a standard scam in Spain, unlike USA for example, hire cars are easy to identify, and
from the gangway watch and a familiarisation these gangs are all over.
checklist to go through and sign as read and Similar job was done to me near Valencia couple of years back.
understood. From a practical perspective and If I may add my own advice: motorway stops are not monitored and I had a similar loss when
risk basis the gangway watch should be robbed taking a driving break, they also grabbed my stuff from the passenger seat. Now I block
access with a crate and carry a baseball bat and knife and leave in plain sight (legal in Spain, as long
providing visitors (aside of the security as you don't use them!...true, sold in garages, but you'd need cojones to use one, these guys are
checks) attending for the day alongside in usually in pairs). Not really suitable for a hire car. Make sure doors are locked at all times, including
port the following basic information; when driving. Put all baggage in the boot.
Never stop for anyone, especially if pointing out some 'problem'. This is the number one scam in
• Emergency alarm system Spain. They also impersonate police (portable blue light trick), so if being stopped by cops, unless it's
clearly a police car, try to pull over in a garage etc.
• Basic action and muster point in the
Try to get a full tank while still light, so you don't need to stop, only use the big motorway stops,
event of emergency don't go wandering round the countryside looking for some local place. Lock the doors when you go
• Advice on the hazards (if any) with the to the desk to pay. Grab a sandwich and avoid the various 'grills' unless daylight and the car remains
cargo onboard in sight. Beware guys cleaning windscreens, wave them away.
• Advice on any other operations that Be especially careful from Cartagena towards France, it's worse around Barcelona / Tarragona.

may affect the persons visit. If the foregoing sounds a bit paranoid, trust me it's not...and no airport is safe in Spain, gangs
operate in all of them and are watching you to let go of your computer bag for 5 seconds. The police
know who they are but cannot chuck them out as landside is public.
A lot of the foregoing applies everywhere I know, but in Spain it really is epidemic! To me, the
I hope you find this edition useful here and I that marking of hire cars is ridiculous, you might as well paint a big target on the car!
it encourages you all to share your feedback. The foregoing is based on 20 plus years driving in Spain, and all has happened to me...and more!
Disclaimer: this material discusses OCIMF activities based on
personal experience and opinion and not necessarily in agreement
with OCIMF or OCIMF members views.

AWP Marine Consultancy Ltd


EMAIL: admin@awpmarine.com TELEPHONE: +44 (0) 151 792 4882
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Issue 4

Inspector Bulletin Latest updates & News feeds for Inspectors. May 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.31 Are lifebuoys, associated equipment and


pyrotechnics in good order, clearly marked and are
Means of Access:
there clear procedures in place to ensure that only
intrinsically safe lights are located in the gas hazardous VIQ 5.47 Is the vessel provided with a safe means of access and are all available
areas? means of access (gangway / accommodation ladder / pilot ladder / transfer basket)
Whilst there are SOLAS requirements for the minimum in good order and well maintained?
weight of the man overboard lifebuoys to be 4 kg there is
no specific minimum requirements for the length of the Safe Access ?
lanyard connecting the lifebuoy to the smoke float. An inspector recently encountered the below situation and I felt this was worth sharing
However, if inspectors are in doubt if they feel the lanyard for inspectors feedback here.
is too short and unlikely to be effective to pull the smoke
float from the bracket then the makers instruction
manuals should be consulted.

Examples;

IKAROS MOB MK IV

The MOB is designed to be used with a life buoy weighing


2.5 kg (5.5 lb) minimum, attached by 8 mm (0.32 in)
diameter line 4 m (13.12 ft) long.
Survitec Man overboard Lifebuoy Marker MK9
Use with Lifebuoy Weighing 4kg lanyard 4m long, 9.5mm
diameter.
Aside of the issues regarding signage, lifebuoy with light and line that are not visible in
Comet Light and Smoke Signal the photo, the main issue here is the vicinity of mooring lines (aft springs) in relation to
the lower part of the accommodation ladder. There needs to be a level of sensible risk
• Use with lifebuoy weighing: 4.0kg (8.82 lb.) management here hence there is no reason why an inspector cannot board in this
condition if the moorings are not being attended to at the time and that the inspector
• Attach to lifebuoy with line: 4m (13ft) long, 9.5mm has assessed that the moorings are not under obvious excessive strain here. The
(0.37 in) diameter company should conduct a risk assessment to ensure that there is no access permitted
whilst the moorings are being adjusted or if the conditions change to put added stress
on the springs.
========================================================================

VIQ 4.7 Is navigation equipment appropriate for the size of the vessel and in good
order?
4.7.1 A receiver for a global navigation satellite system or terrestrial navigation radio
navigation system.
Reliance of GPS is a significant hazard in the marine industry and mariners should be
aware of the GPS equipment they have installed on their vessels to ensure that they are
able to identify when the GPS signal is less reliable or suspect. One such means of
identifying faults and errors on the GPS signal is the Receiver autonomous integrity
monitoring (RAIM) that uses redundant signals to produce several GPS position fixes and
compare them, and a statistical function then determines whether or not a fault can be
associated with any of the signals. We have seen cases where the RAIM alarm on the
GPS has been switched off.

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Issue 4

Inspector Bulletin Latest updates & News feeds for Inspectors. May 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 2.15 Is the vessel free of any documentary or


visual evidence to indicate any structural concerns?

The VIQ guidance states that the ESP file “may be VIQ 2.13 Is the vessel provided with an approved Ballast Water and Sediments
provided at the time of delivery but should, in all cases, Management Plan, are records maintained of all ballast water exchanges or
be available on board at least one year prior to the treatment operations and are the officers aware of BWM requirements?
vessel’s fifth anniversary.”
All ships (i.e. vessels of any type operating in the aquatic environment, including submersibles,
However, the guidance does not state the requirements floating craft, floating platforms, floating storage units (FSUs) and floating production, storage and
for there to be a planning document onboard the vessel offloading (FPSO) units) are required to:
and there are cases when this is not available with
feedback to say that this is in the operators office • have an approved ballast water management plan on board,
ashore. Rules and Regulations for the Classification of • maintain a ballast water record book;
Ships require a Survey Planning Questionnaire and a
There has been some confusion as to the format of the record requirements.
Survey Programme to be prepared by the Owner at
least six months in advance of the intermediate or As per International Convention for the Control and Management of Ships' Ballast Water and
special survey and submitted for agreement. Hence at Sediments (BWM) Adoption: 13 February 2004; Entry into force: 8th September 2017
least 6 months prior to docking the planning document Regulation B-2 Ballast Water Record Book
shall be provided on the vessel.
1) Each ship shall have on board a Ballast Water record book that may be an electronic record
system, or that may be integrated into another record book or system and, which shall at least
contain the information specified in Appendix II.
2) Ballast Water record book entries shall be maintained on board the ship for a minimum period of
two years after the last entry has been made and thereafter in the Company is control for a
minimum period of three years.
3) In the event of the discharge of Ballast Water pursuant to regulations A-3, A-4 or B-3.6 or in the
event of other accidental or exceptional discharge of Ballast Water not otherwise exempted by this
Convention, an entry shall be made in the Ballast Water record book describing the circumstances
of, and the reason for, the discharge.
4) The Ballast Water record book shall be kept readily available for inspection at all reasonable
times and, in the case of an unmanned ship under tow, may be kept on the towing ship.
5) Each operation concerning Ballast Water shall be fully recorded without delay in the Ballast
Water record book. Each entry shall be signed by the officer in charge of the operation concerned
and each completed page shall be signed by the master. The entries in the Ballast Water record
book shall be in a working language of the ship. If that language is not English, French or Spanish
========================================================================================
the entries shall contain a translation into one of those languages. When entries in an official
national language of the State whose flag the ship is entitled to fly are also used, these shall prevail
in case of a dispute or discrepancy.

6) Officers duly authorized by a


“ Our company goals are simply stated Party may inspect the Ballast
Water record book on board any
with the target toward No accidents, No ship to which this regulation
applies while the ship is in its port
incidents and No negative feedback from or offshore terminal, and may
make a copy of any entry, and
our customers and Employees ” require the master to certify that
the copy is a true copy. Any copy
so certified shall be admissible in
Disclaimer: this material discusses OCIMF activities based on any judicial proceeding as
personal experience and opinion and not necessarily in agreement evidence of the facts stated in the
with OCIMF or OCIMF members views.
entry. The inspection of a Ballast
Water record book and the taking
of a certified copy shall be
Inspectors are encouraged to feedback performed as expeditiously as
and share their experiences for us all to possible without causing the ship
to be unduly delayed
learn from.

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Issue 5

Inspector Bulletin
Latest updates & News feeds for Inspectors. 11th June 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 10.44 Are the officers and crew aware of the safe
operating requirements of any watertight doors fitted?

In order to address this question its important VIQ 5.9 Are the officers and ratings aware of the requirements of the ISGOTT Ship/Shore Safety
inspectors are aware of the differences with what Check List (SSSCL) and are the provisions of the check list being complied with?
constitutes a watertight and what constitutes a Safety matches or fixed (car-type) electrical cigarette lighters should be provided in
weathertight door. approved smoking locations. All matches used on board tankers should be of the safety
Watertight Doors type.

Watertight doors are designed to prevent water ingress The definition of Safety Match from the
from both sides, thereby ensuring that watertight Oxford dictionary : “a match that will only
integrity of the neighbouring compartment of the ship is start burning if you rub it along a special
not lost. Watertight doors located below deck level are surface on its box”
designed to open and close upwards or sideward The matches in the picture above were
(usually by automatic means). A remote signal on the presented to me as “Safety Matches” which
status (open / close) of watertight doors is required by could be challenged of course as meeting the
regulations. definition above. However, my concern was
the fact that it was a very large box of
Figure 1 shows a hinge operated watertight door
matches in a soft containment box itself
(located above the waterline) whilst figure 2 shows a
presenting a safety issue.
power operated sliding door below waterline.

VIQ 5.48 Is there a suitable means for storing of cargo and bunker samples
cargo and bunker sample locker situated within the main cargo area and is it
in good order?
All cargo samples should be stowed securely in lockers that have access external
to the accommodation. Consideration should be given to storing samples in a
location protected by a fixed fire-fighting system, such as a paint locker.

Inspectors need to be aware of a few points when raising observations in this


area;
Weathertight Doors • Fixed fire extinguishing systems need only be fitted where the volume of
the space is 4m2 or more. (SOLAS Reg. II-2/10.6.3.3)
On the other hand Weathertight Doors are located • “The requirements given in SOLAS Reg. II-2/10.6.3.2. and 10.6.3.3 are not
above the waterline of the vessel. Designed to prevent
considered applicable for cargo service spaces intended for the stowage
the entrance of water from outside to inside. This
generally includes a insignificant head of water. Their
of cargo samples, when such spaces are positioned within the cargo area
onboard tankers.” (Class UI SC 199 (June 2005))
main use is to prevent ingress
of green seas (A solid wave of
water coming aboard the deck Further, regarding paint lockers;
of a ship ) into the space of the Regulations II-2/4.5.1.2 and II-2/4.5.1.3 – Location of paint lockers within the
ship they are designed to cargo block
protect. Paint lockers, regardless of their use, should not be located above the tanks and
spaces defined in SOLAS regulation II-2/4.5.1.2 for oil tankers. (MSC.1/Circ.1239)
Most of the doors on deck are
weathertight doors. These
doors are designed to open So regarding the above, paint lockers cannot be located above the cargo decks,
outwards thereby ensuring a but cargo sample lockers can. Paint lockers must have a fixed fire fighting
positive pressure should there system where the volume of the space is over 4m2, but cargo sample lockers
be a draught of water acting on need not, though it is encouraged.
them.

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Issue 5

Inspector BulletinLatest updates & News feeds for Inspectors. 11th June 2019

Experience Transfer Advice and Guidance Regulation Updates

Interesting observations and class responses here;


VIQ 5.39 Are officers aware of the requirements for VIQ 5.44 Are crew members familiar with the donning of Emergency Escape Breathing Devices
testing fixed fire detection and alarm systems and are (EEBD's) located in the accommodation, engine room and pump room (as applicable) and are they
the systems in good order and tested regularly? in good order and ready for immediate use?

All ships shall carry at least two emergency escape breathing devices within accommodation spaces.
Inspector Observations: There was no fire detection sensor in (SOLAS II-2/13.3.4.2)
Navigation Bridge which was a control station, therefore Spare emergency escape breathing devices shall be kept on board. (SOLAS II-2/13.3.4.1)
bridge was not protected by fire detection during cargo The EEBD shall have a service duration of at least 10 min.
operations when bridge was unmanned. The nearest sensor
was located outside the bridge behind the internal bridge VIQ 8.59 (Chemical) Are the officers and ratings familiar with donning of the emergency escape
entrance fire door. sets where provided and are these sets in good order?

Initial Operator Comments: Ship was constructed on VIQ 8.66 (LPG) Are crew members familiar with the requirements for personal protection for toxic
2011 (vessel’s keel laid on 09 Sept 2011) and delivered products and donning of the emergency escape sets where provided?
to her owners on 17th Feb 2012 being fully compliant
Ships carrying cargoes for which 'Yes' is indicated in column 'n' of Chapter 17 (Chemical) and column
with applicable rules & regulations at the time of "I" in the table of chapter 19 (Gas) shall be provided with suitable respiratory and eye protection
construction. sufficient for every person on board for emergency escape purposes subject to the following:
The following response was received from Class Society self-contained breathing apparatus shall have at least a duration of service of 15 minutes;
on 01/Apr/2019:
Hence the primary difference here is of the
QUOTE: minimum air duration the units provide and
---------- the number required to be carried onboard.
It is feasible for the emergency escape sets
1) First of all, “xxxxxx”, is delivered on 17th February
to replace the EEBD such that a single type
2012 (keel laying 09/09/2011) and therefore unit be provided onboard.
SOLAS 74 consolidated edition 2009 is applicable.
2) In this respect, SOLAS Reg. II-2/9.2.4.1 states that As can be seen from the above pictures the
“for tankers, only method IC as defined in units can look the same but the one on the
paragraph 2.3.1.1 shall be used.” left is 15 minutes duration (hence meeting
3) Further to above, SOLAS Reg. II-2/7.5.5.1 &7.5.1 the IGC and IBC code requirements) and the
also states that in Method IC – “A fixed fire one on the right 10 minutes duration that
just meets the SOLAS requirements.
detection and fire alarm system shall be so
installed and arranged as to provide smoke
detection in all corridors, stairways and escape
routes within accommodation spaces.”
4) Therefore it is concluded that the Navigation

Any Issues here ?


Bridge of the above mentioned vessel is not
required to be covered by a fixed fire detection
system.
---------- VIQ 5.31 Are lifebuoys, associated equipment and
UNQUOTE pyrotechnics in good order, clearly marked and
are there clear procedures in place to ensure that
“ Our company goals are simply stated with the target only intrinsically safe lights are located in the gas
hazardous areas?
toward No accidents, No incidents and No negative
Containers, brackets, racks and other similar stowage
feedback from our customers and Employees ” locations for life-saving equipment shall be marked with
symbols in accordance with IMO Res. A.760(18) indicating
Disclaimer: this material discusses OCIMF activities based on the devices stowed in that location for that purpose. If
personal experience and opinion and not necessarily in agreement more than one device is stowed in that location, the
with OCIMF or OCIMF members views. number of devices shall also be indicated. (SOLAS
III/20.10)
Inspectors are encouraged to share their
experiences for us all to learn from here.

AWP Marine Consultancy Ltd


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Issue 6

Inspector Bulletin Latest updates & News feeds for Inspectors. 15th July 2019

Experience Transfer Advice and Guidance Regulation Updates

Toxic Gas Detector Tube Issues


VIQ 5.23 Does the vessel have appropriate duplicate
portable gas detection equipment suitable for the
cargoes carried, are the officers’ familiar with the Examples of Interesting Observations
operation, calibration and is the equipment being
VIQ 6.3 Are means readily available for dealing with small oil or chemical spills?
maintained in accordance with manufacturers and
Inspector Observations:
industry recommendations?
There was no evidence to show that the suction and discharge hose fitted on both portable
spill pumps (wilden pumps) located on the main deck aft for dealing with small cargo spills
Mixing Pumps and Tubes
were chemical resistant hoses.
Q. Can RAE tubes be used in Gastec or Draeger hand
pumps and vice versa? Initial Operator Comments:
A. Gastec - Yes Draeger – No Wilden pumps on aft main deck suction and discharge
hoses are flexible rubber material, electrically continuous ,
Low-Vacuum Bellows
however chemical resistant certificate for Neoprene
* ~7 mm tube o.d.
material hose couldn’t be located onboard, resulting in
* Larger particles above observation. We agree with the Inspector’s
* Examples: observation new chemical resistance hose will be supplied
* Draeger Accuro
to the vessel at her next convenient port end of May ‘19
along with chemical resistance chart.
* MSA Kwik-Draw

High-Vacuum Piston VIQ 5.40 Are the crew familiar with the fixed fire extinguishing systems, where fitted, are
* ~5 mm tube o.d. they in good order and are clear operating instructions posted?
* Smaller particles
Inspector Observations: The quantity of the foam compound in the foam tank for the fixed
* Examples: RAE LP-1200, Gastec GV/100, Matheson- Kitagawa 8014- 400A
foam firefighting system was not as required by the Class. As per the List of Approved
It is essential to ensure that the compatibility of the tubes Safety Equipment ( issued by the Class ) 3000 litres of the foam compound was required. At
is checked prior to mixing the equipment here, hence the the time of inspection about 122 cm of the foam compound was in the foam tank ( about
instruction manuals and makers reference data should be 2700 litres ). Diameter of the foam tank was about 160 cm. Calibration tables for the foam
consulted in all cases. It is not just the volume capacity of tank were not found on board at the time of inspection.
the hand pumps that make the difference, but the actual
tube diameter that can influence the readings. Initial Operator Comments: Record of approved Safety equipment document states that
the maximum capacity of the foam tank is 3000 litres. Fixed foam firefighting plant’s
Gas Detector Hose Length Restrictions
maker, in his operational booklet, specifies that the quantity of foam concentrate in
Below is a table of restrictions for examples of gas
detection equipment with maximum hose lengths that accordance with SOLAS and FSS Code requirements shall be minimum 2700 litres to handle
can be used for sampling, hence it is essential to have the an emergency as per attached calculation. Firefighting operational booklet and maker’s
correct equipment for the tank size; instructions were shown to inspector.
Hyper Mist System
Additionally, during inspection inspector was
provided with document stating the quantity
purchased and delivered to the vessel during the
renewal process of the foam done on 8 June 2017,
supervised by class.

VIQ 5.40 Are the crew familiar with the fixed fire
extinguishing systems, where fitted, are they in
good order and are clear operating instructions
posted?

“ Our company goals are simply stated with the target Can anyone identify the issue with this situation I
towards No accidents, No incidents and No negative was presented with the other day? Fixed fire
fighting systems shall be readily available for use at
feedback from our customers and Employees ” all times!

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Issue 6

Inspector Bulletin Latest updates & News feeds for Inspectors. 15th July 2019

Experience Transfer Advice and Guidance Regulation Updates

Interpretation of completion of Enclosed Space Entry


Permit Section 3 - BREATHING APPARATUS AND OTHER
EQUIPMENT
Example observation raised here and operators subsequent comments;
I have had recent discussions with OCIMF and members 5.16. Are the officers aware of the industry requirements for enclosed space entry
regarding the completion of section 3 of the recommended and have these been correctly followed? (Yes/No/Not Seen/Not Applicable)
No
format provided in IMO Resolution A.1050(27) to which I
Observations: At the time of the inspection there was no evidence that the
would like to share with you; breathing apparatus, to be used in case of emergency, had been checked/tested
prior "use". Furthermore several enclosed space permits had been checked and
noted that questions regarding familiarity of the crew with BA, means of
communication, emergency signal, rescue harnesses/lifeline, personnel entering
the space provided with multi-gas detector, had been marked as a "NA". As per
instruction reported into the form above questions had to be checked if "entry a
space where the atmosphere is suspected or known to be unsafe" only.

Initial Operator Comments: Immediate Cause: Observation was referenced to SFSAF 9


section: "Additional precaution for entry into a space where the atmosphere is suspected
or known to be unsafe" where vessel marked N/A

Root Cause: The management company does not consider this to be a valid observation.
The enclosed space entry permits on board were in place and being used as per company
and legislative requirements. The permits were completed correctly as per company
policy. The attending inspector has stated the permit contained a section that was to be
filled in if the atmosphere of the space was suspected or known to be hazardous. In his
‘personal’ opinion this section should be filled in at all times irrespective, however as the
space in question the atmosphere was not suspected to be at all hazardous ships staff had
correctly left this section blank.

Correction: There is no correction required

Corrective Action: There is no corrective action required

Due to the very varied approach to this as seen by many different operators, the right interpretation
and approach was sought from the member and OCIMF. OCIMF’s response is that section 3 of the
check list needs to be addressed ONLY when the atmosphere is known to be unsafe and requires BA
The guidance stated under 9 ADDITIONAL PRECAUTIONS to be used for entry. This will further be addressed in the new version of ISGOTT under present
FOR ENTRY INTO A SPACE WHERE THE ATMOSPHERE IS development.
KNOWN OR SUSPECTED TO BE UNSAFE appears to refer to Hence inspectors should not raise an observation if this specific section of the enclosed space entry
section 3 of the permit though does not directly make it permit is not completed.
clear this is the case (i.e. reference section 3 etc). There
are clearly in the industry 2 thoughts here;
VIQ 5.43 Are crew members familiar with donning breathing apparatus and are Fireman’s Outfits in
1.) The equipment shall be immediately checked on good order and ready for immediate use?
location (whistle, air pressure etc) and hence parts of the Compressed air breathing apparatus shall be fitted with an audible alarm and a visual or other device
section 3 completed as appropriate which will alert the user before the volume of the air in the cylinder has been reduced to no less than
200 L. New ships constructed (keel-laid) on or after 1 July 2014 and existing ships (ships constructed
2.) The equipment brought to the site untested and before 1 July 2014) shall comply with the requirements by 1 July 2019. (FSS Code 3/2.1.2.2)
only when an emergency occurs shall section 3 then be
completed here. We have had some queries as to what constitutes a “visual or other
device which will alert the user before the volume of the air in the
cylinder has been reduced to no less than 200 L”
Disclaimer: this material discusses OCIMF activities based on personal INSB Class states “A pressure indicator, with which the user can read
experience and opinion and not necessarily in agreement with OCIMF or that the volume of remaining air in the cylinder has been reduced to no
OCIMF members views. less than 200l, regardless of the need for supplemental lighting, may be
regarded as a "visual device".
Inspectors are encouraged to share their experiences
for us all to learn from here. Hence this can be a pressure gauge as illustrated here.

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Issue 7

Inspector Bulletin Latest updates & News feeds for Inspectors. 2nd Aug 2019

Experience Transfer Advice and Guidance Regulation Updates

Safety vs Security
VIQ 5.10 Are the crew aware of the requirements to keep external doors, ports and windows closed
in port and is the accommodation space atmosphere maintained at a slightly higher pressure than
that of the ambient air?
The subject of Safety vs Security was raised at the recent auditors meeting in Windsor and a valuable
VIQ5.26 Is gas welding and burning equipment in good
presentation by Tony Jones highlighted the issues and concerns. Below courtesy of Tony are examples order and spare oxygen and acetylene cylinders stored
of compromised safety situations on vessels external door preventing access from the outside in an apart in a well-ventilated location outside of the
emergency;
accommodation and engine room?

Guidance notes make reference to the British


Compressed Gases Association Code of Practice CP7 for
safe use of oxy-acetylene equipment. CP7 section 6.2
further states “Correct hose connections, properly fitted
and tested to BS EN 1256 (43) and retained by suitable
clips or ferrules, are essential. Re-usable worm-drive
clamps shall not be used.”

CP7 Section 5.3 Maintenance Table 1:


REGULATORS and their integral protective devices:
Functional tests to ensure correct operation shall be
conducted annually by a *suitably trained person*.
Typically this will include a creep test to ensure regulator
VIQ guidance states Doors should not normally be locked in port. However, where there are security integrity.
concerns, measures may need to be employed to prevent unauthorised access while at the same time
ensuring that there is a means of escape for the personnel inside. ( ISGOTT 24.1) *Annual maintenance shall be carried out by a person
who has been formally trained to demonstrate that he
Example observation;
Inspector Observations: Accommodation door on main deck Stbd side was locked using a padlock which
has:
could be opened from inside by opening a butterfly nut. However the (i) Sufficient practical experience of oxy-fuel and related
shore based or emergency response team would require key for access to
gas equipment,
the accommodation.
and
Initial Operator Comments: We respectfully disagree with this
observation. (ii) Theoretical knowledge of the functioning of the equip-
The requirement for accommodation doors in ports to be closed as ment, the properties of gases used, the potential defects
per ISGOTT 24.2 strictly comply and the use of locking device is
only in place while there are any security concerns in and hazards which may occur and their importance to
order to prevent unauthorized access in the interests of the safety the integrity and safety of the equipment.
and security of the vessel and its crew.
As witnessed during the inspection the mentioned locking device
does not jeopardize with the safety on board; means of escape for
the personnel inside are established (see attached
photograph) and all responsible crewmembers on duty are
equipped with a key to secure entrance to the accommodation
from outside if required. “ Our company goals are simply stated
I believe there is good need to challenge the operators comments here that are highlighted in green as with the target towards No accidents, No
the inspector clearly states the vessel was operating in security level 1 so why should the door be pad-
locked rather than sealed? incidents and No negative feedback
OCIMF response to the issue of safety and security was discussed at the auditors meeting June 2019 and
from our customers and Employees ”
they stated that “security should be ensured, but not at the cost of safety and where situations are
encountered onboard that suggest the compromise of safety then this should be recorded in the most
appropriate question”. This encourages observations to be raised accordingly where compartments are
padlocked rather than sealed where there are low security concerns.

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Issue 7

Inspector Bulletin Latest updates & News feeds for Inspectors. 2nd Aug 2019

Experience Transfer Advice and Guidance Regulation Updates

MEG4 issues
VIQ 9.7 Is there a policy in place for the testing of winch brakes and are the results recorded?
Meg 4 further states;
MEG 4 has introduced new terminology with regards to the rendering of winch brakes and it is good to
reiterate this point here for inspectors as we often come across the terms “rendering” and “holding”
interpreted in different contexts. 1.9.1 While all new ships should be able to achieve all parts
of the proposed MSMP structure, existing ships may
Brake Holding Load experience limitations particularly in accessing original
OCIMF recommends a brake holding load setting of 60% of ship design MBL, on the first layer instead of the design information.
80% value in ISO 3730. The brake should have the capability to be set up to the 80% value, to always allow
a setting at 60% to be achieved irrespective of wear and tear on the brake. It is recommended that existing ships undertake the
necessary due diligence to collate required information or
Rendering Load align their operating practices with these fundamental safe
Sometimes also known as stall pull or stall heaving capacity. mooring principles, so far as it is possible and practicable.
This is defined as the line pull the winch will exert when the control lever is in heave and the mooring line is
held stationary. A high rendering load is desirable to winch a ship onto the pier against high environmental 5.2.3 Existing ships may have deck equipment that results in
loads. However, the rendering load should not be so high that there is any danger of mooring line breakage a lower D/d ratio than is optimal (D/d ratio is the diameter
and should never exceed 50% of ship design MBL. of the bend divided by the diameter of the mooring line).
Any bending of the line will immediately reduce its breaking
The main purpose of brake testing is to verify that the brake will render at a load less than the ship design strength. Repeated bending will reduce the service life of
MBL. (MEG 6.4.6) the mooring line. The Did ratio should be as large as
Each winch should be tested individually, and test should be carried out prior to the ship’s delivery and possible to maximise mooring line strength and working
then every year thereafter following recommendation in the MEG. In addition, individual winches should life.
be tested after completion of any modification or repair involving the winch brakes, or upon any evidence Operators may be able to address this by either replacing
of premature brake slippage or related malfunctions. Brakes should be tested to prove they render at a the fittings or adjusting maintenance activities in their LMP
load that is equivalent to 60% of the ship design MBL (MEG 6.4.6.1) to account for the reduction in the service life of lines.

Line Design Break Force (LDBF) - the minimum force that a new, dry, spliced mooring line will break at Ship Size and Hull Form
when tested according to Appendix B of MEG4. When selecting lines, the LDBF of a line shall be 100%– (Input data from Shipyard/Ship Designer)
105% of the ship design MBL.
Mooring Force Calculation
Working load limit (WLL) - The WLL is expressed as a percentage of ship design MBL and should be used as
Ref Section 2.3
a limiting value in both ship design and operational mooring analyses. During operation, the WLL should
not be exceeded. The WLL value is used as a limit with the standard environmental criteria and mooring
layout when designing mooring systems. Mooring Re-straint Requirements
Ref Section 2.4
The diagram extract from MEG 4 provides a good reference to the various settings;

Mooring Re-straint Requirement/number of


Mooring Lines in same Group =
Ships built post MEG4 MBL of Mooring Line
Vessels built after MEG4 release should already
have a ship design MBL to satisfy OCIMF Standard
MBL gives ‘Design Rope’
Environmental Criteria restraint requirements and
Table 7.1 and ISO 3730
each mooring line will have a LDBF. Mooring
fittings and mooring winch brake rendering values
are based on the ship design MBL..
‘Design Rope’ leads to following Winch parameters:
Ships built prior to MEG4 Brake Design Load = 80% of line MBL
Pre MEG 4 vessels should still follow the same Brake Holding Load = 60% of line MBL
guidance of setting their mooring winch brake Winch Pull: not to exceed 30% of line MBL
rendering values based on the “line MBL” which, Drum Diameter = 16 x line diameter
should be assumed to be synonymous with the Width of Tension Part = 10 x line diameter
ship design MBL, termed “Design Rope” MBL (See
Figure 7,3 in MEG3).
FIGURE 7.3: CALCULATION OF MOORING LINE MBL AND
RELATIONSHIP TO WINCH PARAMETERS

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Issue 7

Inspector Bulletin
Latest updates & News feeds for Inspectors. 2nd Aug 2019

Experience Transfer Advice and Guidance Regulation Updates

Placing Observations under the Most


Appropriate Question within the VIQ
VIQ 5.47 Is the vessel provided with a safe means of access and are all available means of
Inspectors are often getting challenged by
access (gangway / accommodation ladder / pilot ladder / transfer basket) in good order
operators where an observation is raised that it and well maintained?
does not specifically fit under a VIQ question.
During the last OCIMF auditors meeting OCIMF
issued interim advice stated as follows “Guidance
notes do not form rigid boundaries for the
recording of observations and that where
inspectors note issues that may not be covered by
the guidance then that should not prevent them
In all of the above cases the weight will fall onto the spreader itself rather than the actual
from recording observations”. Hence we suggest ladder ropes.
to inspectors to take the nearest question suitable
Rail not designed for Pilot ladder Pilot ladder secured using ship
and raise the observation under this question. The made brackets. The weight of the
loading pilot will be supported by one step
point here is that the observation should be only. The hard edge of the top hull
captured within the SIRE report to ensure that it is plate may damage the ropes.

acted on and not omitted simply because it does


Pilot ladder should not be secured
not fit within the VIQ question specifically. by shackles or trying to ship side
rails. These rails are easily
damaged and their strength
cannot be guaranteed.
Interesting Observations
More override devices on turning gear
The above methods of securing pilot ladders are incorrect; the correct way to secure a pilot
ladder is by the use of rope lashings to the side ropes attached to approved strong lashing
points on deck.
The pilot ladder should be directly lashed tightly to a ring plate provided near the ship’s
side for exclusive service, with no other items connected. If the full length of the ladder is
not used, each of the two stopper ropes of an adequate length
should be connected to a rigid structure such as the ring plate

Further on the subject of safe access attached link to Rightship


safety circular on the use of accommodation ladders is well worth
the read; https://www.rightship.com/wp-content/
uploads/2019/07/Safe-Gangway-Access-Tony-Honeyborne.pdf

Good Practises

Here we have an excellent tag out and lock out system to


complement the permit to work onboard;

Disclaimer: this material discusses OCIMF activities


based on personal experience and opinion and not
necessarily in agreement with OCIMF or OCIMF
members views.

Inspectors are encouraged to share their experiences for us


all to learn from here.

AWP Marine Consultancy Ltd


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Issue 8

Inspector Bulletin Latest updates & News feeds for Inspectors. 23rd Aug 2019

Experience Transfer Advice and Guidance Regulation Updates

MEG 4 Issues and Existing Vessels

In the last edition of the Inspectors Newsletter we The below diagram provides an example of the Equipment Number calculation for a vessel;
discussed the general concept of how vessels with no
defined Ship Design MBL (pre MEG 4) should set winch
brakes and consider suitable fittings for mooring
equipment.

There remains confusion for existing vessels in how


they determine the selection criteria of mooring ropes
and wires to meet OCIMF MEG4 and in applying due
diligence in this selection process.

Pre MEG 4 Selection Criteria and Equipment Number

Where the Ship Design MBL is not available or the data


not calculated then MSC/Circ.1175 GUIDANCE ON
SHIPBOARD TOWING AND MOORING EQUIPMENT
provides standards for the design and construction of
shipboard fittings and supporting hull structures Further to the above, the below practical guidance has been provided by OCIMF;
associated with towing and mooring, which
OCIMF are not mandating that you put a
Administrations are recommended to implement. The
Minimum strength line on board.
provisions of this guidance do not require tow lines nor
However we do not recommend
mandate standards for mooring lines onboard the ship overstrength mooring lines which reduce
however. the ratio of the safety factors between
the various components. These safety
Reference to table 1 of the above mentioned circular factors are there for the safety of the
provides the minimum breaking strength (kN) seafarer and the asset. OCIMF are also
recommendations for mooring lines as calculated from not advocating reducing standards as we
the formula; have always advocated more
conservative safety factors than the IACS
requirements. This is still the case
following the updates of IACS URA2 and
MEG 4.

Should you wish to increase the strength of the Mooring line then a Management of
Change process should be followed including a full risk assessment and the outcomes of
any changes made are recorded in the Mooring System Management Plan MSMP.

If your lines are currently greater than the SDMBL - OCIMF are not mandating that they
are renewed. However you should record that they are above the ship design MBL in the
MSMP and also document what procedures you have instigated to mitigate the reduction
of the differential in safety factors in the other mooring system components. One of your
potential mitigations would be to set the winch brake to render at 60% of the Ship design
MBL and not the actual MBL of the mooring line. If the mooring line MBL was lower
(weaker than) than the Ship design MBL then the brake would need to be set lower to
maintain the safety factor differential.

Regarding the LDBF this is more for the rope manufacturer. When they design mooring
Disclaimer: this material discusses OCIMF activities based on
lines they cannot guarantee that the requested MBL is exactly the strength requested.
The rope manufacturers agreed a +5% tolerance.
personal experience and opinion and not necessarily in agreement
Therefore if an operator requests to purchase ropes with 100T MBL then certificate will
with OCIMF or OCIMF members views.
say ship design MBL of 100T but the same certificate will have a LDBF of between 100T
Inspectors are encouraged to share their experiences for us all to and 105T.
learn from here.

AWP Marine Consultancy Ltd


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Issue 8

Inspector Bulletin
Latest updates & News feeds for Inspectors. 23rd Aug 2019

Experience Transfer Advice and Guidance Regulation Updates

MGC SIMPLE+ Gas Detector feedback

You may remember in a previous edition of our company newsletter that we Interesting Observations
provided some information on a personal gas detector MGC SIMPLE+. Capt Aidan
Drew has very kindly shared the below experience with us regarding the unit and Some interesting observations that have come
some good learnings for those of you travelling on planes having similar devices. to light recently worth a deeper investigation
and clarification;
I’ve had one of these since March 2019.
Cost £676.20 including VAT VIQ 11.14 Are laundries free of accumulations
The unit is bigger than the BW GasAlertMicroClip XL I had been using previously. of clothing that could constitute a fire hazard?
Bigger to contain the non rechargeable battery. I haven’t found this to be
inconvenient and not noticeable when clipped to boiler suit breast pocket. There are no specific international
requirements restricting the use of laundry
It is very convenient to not have to charge the unit, one less thing to think about equipment (washing machines and driers) in
when between inspections, and not having to think about calibration is a big port though there maybe some local
bonus. The unit display gives a countdown on time remaining which is a handy restrictions concerning these matters such as
feature. The unit seems durable and has withstood various knocks and falls. washer waste outlets and terminal restrictions
on the use of driers from a fire safety concern.
It has one very big disadvantage and that is that you cannot turn it off. Recently I Hence this should be discussed as part of the
was travelling with a short connection time between two flights with a risk of initial safety discussions with the terminal.
baggage going astray, so I carried the detector in my hand baggage. On first flight
we took off and I had headphones on listening to some music when suddenly the Where there are no specific restrictions
flight assistant starting rummaging around in the overhead locker above me. I soon washing machine outlets should discharge to
realised that she was looking for my gas detector which was in alarm mode. When I internal tanks and driers should be maintained
told her it was a gas detector she started worrying that gas had been detected. I in good working order with emphasis on filter
realised almost straight away that the change in cabin pressure must have activated and outlets clear of debris. There have been a
the alarm. I had to cover the alarm with my thumb to try and deaden the sound number of incidents in recent years with the
and cupped the unit in my hands to conceal the flashing red lights. The only way to following extracts taken from such incidents to
interrupt the alarm was to press the calibration button (marked as a power button) highlight the risks ;
which sends it into calibration mode after maybe 10 seconds of alarming. So for the
rest of this flight I sat with detector cupped in hands, one thumb on alarm and the USCG Marine Safety Alert 11-15 ; Dried Not
other on the calibrate button, and palms concealing the flashing red lights. It Fried
alarmed about four times on each flight as aircraft ascended and descended. https://www.dco.uscg.mil/Portals/9/DCO%
20Documents/5p/CG-5PC/INV/Alerts/1115.pdf
Aidan contacted Martek and the following solution
found; IMCA Safety Flash 07/16 ; Near Miss: Laundry
I am very sorry for the obviously embarrassing situation Fire Hazards
you have had. The good news is this can be easily https://www.imca-int.com/alert/1007/near-
resolved as the instrument can be turned off, in a sense. miss-laundry-fire-hazards/
If you hold down the button, the unit will scroll through
the below, keep the button pressed down while it does
this

Zero 3,2,1, OK
Retest 3,2,1, OK
Off 3,2,1, OK

When you reach Off, okay then release the button and the instrument will switch off. It
doesn’t stop the countdown which is shown on the screen but it will turn off the sensors
so that they don’t alarm in these situations.

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Issue 9

Inspector Bulletin Latest updates & News feeds for Inspectors. 8th Oct 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 6.21 If the vessel is provided with an approved Ballast


Water Treatment System, is the system in good order, used
where required and are officer’s familiar with the safe
operation of the same? Interesting Observation - Rest Hours
Where hazardous chemicals or treatment additives are provided,
inspectors should verify safe handling and access controls in place.
VIQ 3.2 Are the STCW and flag Administration’s
Reference to BWM.2/Circ.20 21 July 2009 should be considered regulations that control hours of work to
here for safe handling and storage of chemicals. minimise fatigue being followed and are all
personnel maintaining hours of rest records in
There are generally two types of ballast treatment technology; compliance with MLC or STCW requirements?
separation and/or disinfection. Separation removes organisms
from ballast water while disinfection kills or renders organisms A really interesting observation was
incapable of reproducing. Each system has its own hazards and recently highlighted by one of our
some of these are described below; inspectors that has identified some
shortfalls in the guidance notes of the VIQ
regarding this question.
Observation: There were three or more breaches to the crew rest hours for the following crew
members within a 30 day period;
1) Pump man : 3 breaches in 8 days from March to April 2019 and 3 breaches in 21 days from May to
June 2019.
2) Ordinary seaman : 3 breaches in 8 days from March to April 2019 and 3 breaches in 28 days from
April to 27 May 2019.
3) Motor man 1 : 3 breaches in 6 days from March to April 2019.
4) Motor man 2 : 3 breaches in 27 days from April to May 2019.
5) Master : 4 breaches in 26 days from May to June 2019.
6) ETO : 3 breaches in 22 days from March to April 2019.
7) Chief officer : 4 breaches in 23 days from April to May 2019 and 4 breaches in 29 days from May to
Ultraviolet - Disinfection Irradiation (UV) Systems June 2019.
Protection from excessive UV exposure should be considered 8) Bosun : 3 breaches in 27 days from April to May 2019 and 3 breaches in 23 days from May to June
(interlocks on use of UV without water flow within the treatment 2019.
chamber) and high temperature alarms functional. 9) AB3 : 4 breaches in 6 days in March 2019, 3 breaches in 24 days from May to June 2019 and 3
breaches in 28 days from June to July 2019.
Prepared Chemical Treatment Systems 10) AB2 : 3 breaches in 26 days from April to May 2019.
Documentation in the form of MSDS must be provided at the 11) AB1 : 3 breaches in 30 days from March to April 2019 and 3 breaches in 23 days from May to June
handling area for the chemicals together with any PPE 2019.
requirements. Chemicals shall be stored correctly in line with The breaches were raised when the crew members had not taken continuous 6 hours in any 24 hours
MSDS requirements (temperature, sunlight, humidity, and/or 10 hour in any 24 hours and/or 77 hours
ventilation etc) and crew members must be aware of the in any 7 days and/or 10 hours rest comprised with more than 2 rest periods. Also, there was no
requirements. operator's acknowledgement available.
Maximum dosing levels and discharge concentrations shall be
followed and containment in the form of drip trays may need to Operator Feedback: The inspector is stating that we, as a company failed to acknowledge 3 or more
be considered together with maximum filling levels. breaches for certain crew members in a period of 30 days.
Gas detection systems should be operational and also ventilation Note that we have our monthly reports which were checked by the inspector, where the Masters are
adequate. Tank coating considerations should be verified to sending us the rest hours records including N/C reports for that month from the 1st till the last day of
ensure compatibility. the month. I have attached last month correspondence for reference (I can send all the records for the
last year if you need me to). The software we are using is ISF Watchkeeper.
Ozone Injection Systems What the Inspector is writing, is that we need to calculate the N/Cs every day for the last 30 days for all
Ozone maybe hazardous at low concentrations hence ozone the crew and not only calendar months.
leakage detectors shall be operational and the plant room well To be noted, we do calculate for “any 24 hrs” and “any 7 days” as per ILO requirements, but there are
ventilated. no requirements as far as we know for our Captains to check in any 30 days. Please see attached
Shut down systems shall be provided and verified operational Circular Letter sent to the Masters last year in April, explaining how to deal with rest hours.
with alarms for high O2 (25%) and high ozone (0.2ppm) Can you please direct us to a regulation which is requiring us to do so?
concentrations.
From the above note the operator is correct in that there is no stated guidance on the logging of
Electro-chlorination Systems non-conformities over a 30 day period, but only over a calendar month. The challenge here however is
Electro-chlorination systems produce hydrogen (flammable) and that there could be numerous N/C’s raised at the end of a month that fall into the following month
chlorine (toxic), hence the spaces containing the installation shall that would not in itself constitute an issue on a calendar month by calendar month basis (less than 3 N/
be fitted with Ex or intrinsically safe equipment and ventilation C’s), but from a safety and practical point of view the risk remains regardless and should be identified.
of at least 30 air changes an hour. Interlocks for the system shall This point has been taken up with OCIMF to provide further clarity.
ensure the fans operational when the system is running and
hydrocarbon gas detection alarms will initiate an ESD.

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Issue 9

Inspector Bulletin
Latest updates & News feeds for Inspectors. 8th Oct 2019

Experience Transfer Advice and Guidance Regulation Updates

Below is a reminder to us all of the risks with


entering enclosed spaces and the attached USCG safety circular further highlights the issues.

Ethylene Leaks and Personal gas meter CO alarms VIQ 4.17 Are the master and deck officers aware of the
requirements of Electronic Chart Display and Information
VIQ 8.36 Is the compressor room free of gas leaks? System (ECDIS) and does the system fitted meet SOLAS and
Inspector Observations: Upon entering the compressor room the personal gas monitors of the inspector, flag state requirements?
Chief Officer, and Chief Engineer went into alarm for high concentrations of Carbon monoxide (CO) in
excess of 50ppm. The space was evacuated. The space was still found to hold significant concentrations 3 Observations: The vessel was fitted with two ECDIS systems
hours after the initial entry. As a result the compressor room was not inspected. as per Safety Equipment Certificate.
The source of the CO could not be verified. However the master ECDIS was found with only an ordinary
computer mouse connected and an ordinary keyboard
Initial Operator Comments: Situation: connected.
During the inspection while entering the compressor room the per- The back-up ECDIS was found with the approved roller ball
sonal gas detection gave alarm on the presence of Carbon Monoxide. mouse connected but with an ordinary keyboard only.

Cause:
ECDIS must be “type approved” in accordance with IMO Res A.817 (19)
The personal detector gave alarm on CO concentration being present as amended and use only official Electronic Navigation Charts (ENCs).
in the cargo compressor room. This was not known by the crew
before, and the fixed gas detection was not giving any alarm on the
presence of any gasses in the compressor room.
- The FGDS was monthly checked one day before the inspection on
the 13/07/2019.
- After the inspection the FGDS was checked, and tested and it was found fully operational.
- The crew is carrying out daily gas measurements every morning with a portable detector, same was done
on the day of the inspection by the Chief officer and presence of gas was not measured.
The crew investigated where the leakage is coming from and this was found to be coming from the top
covers of the cargo compressors being a minor leakage of Ethylene.

Corrective action:
The Crew tightened the top
cover of the leaking cargo
compressor which resulted in
the leakage being rectified.

Preventive action:
As a preventive matter an
order was made for new
gaskets/o-ring set and the crew replaced those on both cargo compressors to make sure that the top
covers are remaining gas tight.

Operators Feedback following the investigation also stated;


Both starboard cargo compressor and starboard cargo condenser were not in use during the cargo
operation. The starboard condenser had just been overhauled ashore including pressure test after the
overhaul. Starboard cargo condenser had been re-installed onboard but was not in use as the Class had not
yet verified the installation nor pressure tested the system after the onboard installation. Starboard
Condenser was clearly marked “Do not use STB Cargo condenser until the Class has pressure test the ECDIS shall meet IMO performance standards IEC 61174
system". Edition 4.0. For ECDIS approved within the European Union
When the vessel had left the port, the starboard cargo condenser was pressure tested and a small pinhole under the Marine Equipment Directive (MED) the following
was found in the condensate pipe of the condenser. Wheel Mark is affixed to the equipment;
When the pinhole was discovered all valves and pipes were isolated with blinds on all connection pipes to The first number denotes the Notified Body that awarded the
the condenser to make sure no further leaks should occur. (see attached file: “Drawing of isolation valves type approval; the second number denotes the year the
and Photos of isolation valves”) equipment passed approval.
Any ECDIS keyboard and mouse should be approved to
What appears not to have been considered here is that the fixed gas detection system had not activated at IEC60945 requirements.
all. The attached link to the USCG Marine Safety Alert Ethylene vapors activate Carbon Monoxide alarm
https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/CG-5PC/INV/Alerts/0718.pdf?ver=2018-05-30
-135040-603 provides a feasible answer here as to why the CO alarm activated and should be considered
here carefully.

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Issue 10

Inspector Bulletin
Latest updates & News feeds for Inspectors. 13th Nov 2019

Experience Transfer Advice and Guidance Regulation Updates

Monitoring IGS
VIQ 8.26 Was the fixed oxygen analyser
calibrated immediately prior to use of the inert
MEG 4 – Further Clarifications
gas system and do local and remote oxygen and
pressure recorders, where fitted, agree? Following on from Inspector Bulletins 7 and 8 we have received some further
feedback from OCIMF for inspectors to note below.

Inspectors Observation AWP Question


The inert gas pressure and oxygen delivery I appreciate if you can provide OCIMF stance as I have received mixed
recorder was not marked with the time and date feedback from clients provided guidance on the use of overstrength ropes on
switching on and off. existing (pre MEG4) vessels. We understand this is NOT recommended, but
in the case of many pre MEG4 vessels they still have a program to change out
the ropes, hence still have ropes that exceed 105% of the ship design MBL.
Instrumentation shall be fitted for continuously
indicating and permanently recording when inert gas is From and inspectors point do we;
being supplied:
- The pressure of the inert gas supply forward of the • Issue an observation in this case and make a comment as to what action if any the operator has
non-return devices; and made (risk assessment / reduced BHC setting etc) even if the action is safe and reasonable
- The oxygen content of the inert gas. (FSS Code • Raise an observation only if no suitable action has been taken to mitigate the risk of the
15.2.2.4.2.1) mooring lines being in excess of 105% ship design MBL.

I quote from clients some messages from OCIMF that they received ;

“ Should you wish to increase the strength of the Mooring line then a Management of Change process
should be followed including a full risk assessment and the outcomes of any changes made are recorded
in the Mooring System Management Plan MSMP.
If your lines are currently greater than the SDMBL - OCIMF are not mandating that they are renewed.
However you should record that they are above the ship design MBL in the MSMP and also document
what procedures you have instigated to mitigate the reduction of the differential in safety factors in the
other mooring system components. One of your potential mitigations would be to set the winch brake to
render at 60% of the Ship design MBL and not the actual MBL of the mooring line. If the mooring line
MBL was lower (weaker than) than the Ship design MBL then the brake would need to be set lower to
maintain the safety factor differential.” This point implies that no observation be raised if actions
followed.

There must be evidence that the means of And also “MEG 4 does not recommend the use of over strength mooring lines and therefore we cannot
continuously monitoring the pressure and oxygen provide guidance on winch brake testing in this situation. Using overstrength mooring lines reduces the
ratio of other safety factors in the mooring system.
delivery content is provided hence there must be a The use of overstrength ropes is not recommended as there is an imbalance in the mooring system. The
means to show that the system was in use from Sire Training and Accreditation Manager (Ajay Gour) has advised inspectors on this issue. This includes
commencing operation to completion. guidance to inspectors where an overlap of ships built to MEG2 and MEG3, until MEG4 guidance is
widely used in construction. "

This point indicates that an observation be raised even if mitigation measures are in place ? Also I do
not remember getting the advice from Ajay on this matter as I cannot find a mail on the subject
anywhere.

On OCIMF website the following guidance is stated “Ships built prior to MEG4 should still follow the
same guidance of setting their mooring winch brake rendering values based on the “line MBL” which,
should be assumed to be synonymous with the ship design MBL, which is termed “Design Rope” MBL
(See Figure 7,3 in MEG3).” However this does not help in the event that mooring rope line MBL is not
the same as ship design MBL.

OCIMF Response

If the vessel does not comply to MEG 4 guidance an


observation must be recorded. No exceptions. Where a
vessel has carried out a risk assessment, the details of that
Nice to see the crew enjoying their work… should be recorded as a comment. It is then up to the
report reader to evaluate the information in order to
interpret any risk.

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Issue 10

Inspector Bulletin
Latest updates & News feeds for Inspectors. 13th Nov 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 11.2 Are hull markings clearly indicated and


correctly placed?

Note: The following should also be clearly indicated, where applicable: VIQ 11.13 Are accommodation, public spaces, sanitary areas, food store
• The vessel’s name; handling spaces, refrigerated spaces, galleys and pantries well illuminated,
• Load lines; clean, tidy, in a hygienic condition and obstruction free?
• Draft marks;
Unburned fuel or fatty deposits in galley ranges, within flue pipes
• Thruster warnings;
and in the filter cowls of galley vents can cause fire and must be
• Tug push points. maintained in a clean condition.

I think if I was the operator I would prefer to Types of Filters


have the observation for illegible draft Broadly, galley hood filters are available in three different types;
marks rather than take these unnecessary
risks here that only increase the severity and Mesh Filters
Also known as Cassette Filters, mesh
number of observations!. filters are made from aluminium mesh
strips placed one over the other in
After all inspections are there to identify the succession. They are highly effective in
risks here and we need to remember that; the capture and removal of oil and
grease from smoke of both ducted and
ductless chimneys. With the volume of
filtration being high, these types of filters
need to be cleaned once every week.
Baffle Filters
These type of filters are made out of
steel/aluminium frames with curved
panels. The curves in these panels are
capable of catching up on grease, oil
and other such particulates. Highly
durable and easy to clean, they need
to be cleaned once every month and
are used in both ducted and ductless
chimneys.

Charcoal Filters
VIQ 5.24 Are officers aware of the requirements for hot work and are hot work
Charcoal filters are made out of fine
procedures in accordance with the recommendations of ISGOTT and OCIMF guidelines? powdered activated carbon charcoal
that is in a honeycomb structure. Used
Inspectors Observation primarily in a ductless chimney for the
There was no evidence to show that a full risk assessment had been performed for the designated filtration of odours, a charcoal filter has
hot work area in the machinery space. There were two, sea water lines passing immediately above no cleaning method and is usually
the hot work area with no splash protection provided in the event of flange leakage. replaced once every 6 months or so.

ISGOTT 9.4.2 Hot Work Inside a Designated Space


Whenever possible, a space such as the engine room workshop, where conditions are deemed safe, With all of the above systems it is important that regular
should be designated for Hot Work and first consideration should be given to performing any Hot maintenance is followed to prevent both grease build up in the
Work in that space. If the company designates such a place, it should be assessed for possible risks, filters and extraction hoods, thus minimising the risk of fire. In the
and the conditions under which Hot Work can be undertaken in that place defined. case of mesh filters there needs to be sufficient layers of
aluminium mesh strips to be effective at removing the grease from
The above picture is a typical example where the vessel has the air extracted. Some examples of poor filtration can be seen in
not performed a thorough risk assessment with flange the following arrangements which have very little effect at
preventing grease build up within the extraction hoods and fan
connections noted on water lines immediately above the gas
units hence considered a high risk for fire;
burning area in the workshop.
Inspectors should review the risk assessments as required by Although this looks clean at a glance, the
VIQ 5.1 to ensure that these risks have been thoroughly single mesh filter has very little effect in
removing the grease from the extracted
considered.
air here. On close examination of the
trunking a thin layer of grease was
evident that constituted a high fire risk.

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Issue 11

Inspector Bulletin Latest updates & News feeds for Inspectors. 06th Dec 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.39 Are officers aware of the requirements for


testing fixed fire detection and alarm systems and are
the systems in good order and tested regularly?
Inspector Observation: The vessel was not provided with the correct equipment
Spaces not covered by a fire detection system should be
covered by regular fire patrols. for testing of the flame and heat detectors onboard. A non-approved heat gun
was reported to have been used for such testing rather than the correct flame
and heat testers as recommended by the makers instruction booklet.

Approved Test Equipment

Approved Test Equipment

Inspector Observation: There was no fire detection sensor in Exhaust Gas Cleaning System Failures
the Navigation Bridge which was a control station,
therefore bridge was not protected by fire detection during
cargo operations when bridge was unmanned. The nearest
sensor was located outside the bridge behind the internal
bridge entrance fire door.

Initial Operator Comments: Ship was constructed on 2011


(vessel’s keel laid on 09 Sept 2011) and delivered to her
owners on 17th Feb 2012 being fully compliant with
applicable rules & regulations at the time of construction.
However, following the observation we are in contact with
Classification Society in order to ascertain if further actions
are required. Effect of Failure of EGCS

SOLAS Reg II/2 Reg 7 5.5 Cargo ships (Unless expressly With the 2020 sulphur cap deadline approaching
provided otherwise, the requirements of this chapter shall and the numerous installations of exhaust gas
apply to ships constructed on or after 1 July 2012) cleaning systems on vessels the IMO have
introduced guidance on actions in the event of
Accommodation and service spaces and control stations of failure of such systems.
cargo ships shall be protected by a fixed fire detection and
fire alarm system and/or an automatic sprinkler, fire This Guidance letter https://www.mardep.gov.hk/en/msnote/pdf/msin1917anx3.pdf
detection and fire alarm system as follows, depending on a specifies that a short-term temporary emission exceedance due to the system failure
protection method adopted in accordance with regulation should not be considered as a breach, and the system malfunction that cannot be rectified
9.2.3.1. within one hour is regarded as a breakdown and should be reported to flag States and
port State's Administration. The Guidance also specifies the procedures to show the
In this case here there is no requirement for the fitting of ongoing compliance, in case of the failure of a single monitoring instrument, with other
sensors, however the VIQ guidance does require regular fire parameters continuing at the normal levels.
rounds during periods of the bridge being unmanned. In (Refer to MEPC.1/Circ.883 as attachment 14).
this case, inspectors should verify that a regular fire round
covers the bridge during these unmanned periods. This also This is just to inform inspectors in advance what actions operators will be expected to
applies to other areas that are not protected with fixed fire follow.
detection equipment.

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Issue 11

Inspector Bulletin
Latest updates & News feeds for Inspectors. 06th Dec 2019

Experience Transfer Advice and Guidance Regulation Updates

Interesting Observation Shared

VIQ 8.46 Is the pump room gas monitoring system ECDIS Annual Inspection Test
in good order, regularly checked and are officers Following on from the Concentrated Inspection Campaign (CIC) on Safety of
aware of the alarm settings? Navigation including ECDIS jointly with the Tokyo MOU between 1 September
2017 and 30 November 2017 it was noted in 3.8% of the inspections, Q2 of the
Sampling points or detector heads shall be located in
suitable positions in order that potentially dangerous questionnaire “Does the ECDIS have the appropriate up-to-date electronic charts
leakages are readily detected. for the intended voyage and is there a suitable back-up arrangement?” raised a
deficiency.
Inspectors Observation;
The Consilium fixed Gas As a result of the CIC and in response to concerns raised by stakeholders across
Sensor Cabinet fitted in the
the maritime industry about the condition of in-service ECDIS, frequently found to
CCR had lost its gas
containment function for have operational issues. Problems typically encountered included inadequate
an eventual system gas power supply arrangements, outdated software versions, disabled audio signal
leak, as 2 approx. 8 cm for alerts, and the incorrect functioning of interfaces to connected equipment.
Diam. Holes had been The purpose of the Guideline is to ensure that an in-service ECDIS is functioning
perforated on the side, properly, in the interests of safety of navigation and of course to meet ISM and
reportedly for better pump SOLAS requirements.
ventilation/cooling.

MSC.1/Circ.1370 GUIDELINES FOR THE DESIGN,


CONSTRUCTION AND TESTING OF FIXED
HYDROCARBON GAS DETECTION SYSTEMS
2.1.7 " The system should be designed, constructed
and installed to prevent the leakage of hydrocarbon
gases into any accommodation and service spaces,
control stations or machinery spaces."

Though the test is NOT mandatory it is recommended and inspectors should


3.2.3 " The gas concentration inside the control verify that there is a process in place for verifying the performance of the
panel enclosure should be monitored. Upon equipment annually. Makers maintenance instructions for ECDIS should also be
detection of gas concentrations above the alarm included within the vessels planned maintenance program.
setpoint within the enclosure, in addition to the
alarm, the gas analysis unit should be automatically Ballast Tanks and Flame Screens - Clarification
isolated from all sampling pipes and shut down.
Appropriate measures should be taken to vent VIQ 11.7 Are fuel, ballast and other space vents and air pipes in good
flammable gas inside the enclosure to an open order and does visual evidence indicate regular maintenance?
NOTE There is no requirement for ballast tank vents to be fitted with flame
space away from ignition sources." screens.

Class have no requirement for installing flame screens on ballast tanks


Basis the above guidance the inspector has rightly though if there are screens fitted then they should of course be in
identified a compromise of the cabinet integrity good order.
which may have an impact on the gas detection 46 CFR 56.50-85 states “Vent outlets from all tanks which may emit
capability of the sensor detecting a leak within the flammable or combustible vapors must be fitted with either :
1) A single screen of corrosion resistant wire of at least 30 by 30 mesh;
space. Refers to enclosure and as you say this is now
or
broached with a larger hole hence integrity is 2) Two screens of corrosion resistant wire of at least 20 by 20 mesh
compromised and system no longer approved or an spaced not less than 1/2 inch nor more than 1 1/2 inches apart. The
"enclosure" clear area through the mesh must not be less than the internal
unobstructed area of the required pipe.”
Hence again no requirement for fitting flame screens in ballast tanks.

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Issue 12

Inspector Bulletin Latest updates & News feeds for Inspectors. 19th Feb 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 4.1 Are the deck officers’ familiar with the Company navigation
procedures and instructions and are the Company navigation procedures
comprehensive?
Use of Bridge Navigational Watch Alarm System (BNWAS) modes
(automatic, on and off) and procedures for ensuring correct operation
VIQ 3.6 Are those officers who have immediate responsibility for cargo transfer, in possession of the
Certificates of Specialized Training as applicable to the type of cargo being carried?
VIQ 4.7.34 Bridge navigational watch alarm system (BNWAS) Masters, chief engineer officers, chief mates, second engineer officers and any person with immediate responsibility for
The bridge navigational watch alarm system shall be in operation whenever loading, discharging, care in transit, handling of cargo tank cleaning or other cargo related operations on oil, chemical or
the ship is underway at sea. liquefied gas tankers shall hold a certificate in advanced training for oil, chemical or liquefied tanker cargo operations.
(STCW Reg V/1-1.3, 1.5 or 2.3).
The term "Person with immediate responsibility" as used in paragraphs 3 and 5 of regulation V/1-1 and paragraph 3 of
regulation V/1-2 means a person being in a decision making capacity with respect to loading, discharging, care in transit,
handling of cargo, tank cleaning or other cargo related matters". (STCW Code B V-1).
It is interpreted that a 'Person with immediate responsibility' includes all watch keeping officers in charge of cargo
related operations whether the vessel is at sea or in port. This includes 2nd Officer, 3rd Officer, 4th officer, Gas/Cargo
engineer.
It should be noted that persons with immediate responsibility may include pump man and other ratings engaged in direct
supervision of the cargo operation.

Inspectors Observation - Vessel did not carry a pump man and while all junior officers and engineers had
done advanced oil and chemical training neither the bosun nor any ratings had done so.
Operators comments: We kindly refer to the guidance note in VIQ7 in which it can be seen that advance
oil and chemical course is only a requirement for officers. Ratings are only required to have basic training.
There has been a lot of discussions from various parties regarding as to We also note that requirement is mandatory for all officer in charge of cargo related operations, however
when the BNWAS should be activated. From a legislation view; only optional for pump man and other ratings.
SOLAS states “The bridge navigation watch alarm system shall be in
operation whenever the ship is underway at sea“. This can be interpreted as Now in this case the inspector should have provided more clarity as the operators have pointed out that
literally underway as per colregs “means a vessel is not at anchor, or made “only optional for pump man and other ratings” which is correct as stated in the guidance notes.
fast to the shore, or aground.”
However, the critical issue here is whether the bosun and/or ratings had immediate responsibility for the
RESOLUTION MSC.128(75) states “The BNWAS should be operational cargo operation. This maybe identified during the inspection through interviews and by observation if the
whenever the ships heading or track control system is engaged, unless bosun and/or ratings were controlling pumps, valves and other operations related to the cargo directly or
inhibited by the Master.” if they were being supervised and directed to do so. In the former case this would be considered
immediate responsibility, but in the later case then not. This could further be verified with a review of
MSC.1/Circ.1474 states “SOLAS regulation V/19.2.2.3 requires the provision the SMS job descriptions for the bosun and/or ratings and also checks of the cargo plan and deck log
of a Bridge Navigational Watch Alarm System (BNWAS), which shall be in books.
operation whenever the ship is under way at sea”

From a flag state point of view example ;


VIQ 2.7 Is the vessel free of conditions of class or significant recommendations, memoranda or notations?
DEPARTMENT OF MARINE SERVICES AND MERCHANT SHIPPING (Antigua
and Barbuda) states; Inspector Observations: The vessels latest class status report dated 21 December 2019 had the following
“Use of the system in practice.
memos - MO 7 - dated 11 August 2011 stating exhaust gas boiler decommissioned.
The SOLAS amendments require that the BNWAS should be in operation MO 16 - dated 18 March 2018 shaft generator taken out of use & MO 22 - dated 12 August 2019 Port
whenever the ship is underway at sea. The Administration defines this to Boiler found inoperative.
mean at sea when normal watch-keeping is undertaken and does not define Other Inspector Comments: The vessel was issued with the following class memoranda for owners MO 8,
this to include: MO 12 and MO 13, for noting indents in the ships side which had no due dates and was for reference
only.
a. When the ship is under pilotage,
b. Times when the bridge is manned by more than one officer such as when Initial Operator Comments: The vessel is free from significant recommendations, memoranda or notations. The class has
in confined waters or similar when the BNWAS could distract from effective given the following statement regarding these memoranda: Quote “These memos as per the status report are
bridge team management. “non-critical” and not to be considered as conditions to class. They are just “notes” for the next surveyor during his
annual survey, to verify there is no development that may lead to rectification to be asked for.” Unquote. The
OCIMF Guide to best practise for navigation audits question states “Is the memoranda in question are included in class survey for annual/intermediate/special surveys as applicable. The vessel
bridge navigation watch alarm system fully operational at all times when the will follow any future requirements issued by class related to these memoranda.
vessel is not alongside”? The way this question is addressed suggests that
the BNWAS should be in use as soon as the vessel departs a berth.
From an inspectors position it remains important to raise any such memo’s or recommendations that relate to
equipment removed from service as;
Now I believe that we need look at what the primary function of the BNWAS
is here to take a sensible approach especially when manoeuvring with • OCIMF take the stance that if a piece of equipment is fitted to the vessel regardless of whether it is
alarms and other distractions that may occur. The BNWAS is a monitoring mandatory then it should be operational or should be removed from the vessel
and alarm system designed to notify other navigational officers and/or the • There maybe circumstances where the charterer requires a vessel to have a shaft generator or other
master of the vessel if the officer on watch (OOW) does not respond or he/ equipment that may remain on the VPQ or Q88 documentation that has been decommissioned on the vessel
she is incapable of performing the watch duties efficiently, which can lead that maybe critical to the charterers requirements
to maritime accidents. I believe that the Antigua and Barbuda flag has taken
the practical approach here that we all should follow on the premise that
the company SMS should clearly define these circumstances when the Hence inspectors should continue to raise observations as recorded above.
BNWAS may be switched off especially with regards to bridge manning.

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Issue 12

Inspector Bulletin Latest updates & News feeds for Inspectors. 19th Feb 2019

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.23 Does the vessel have appropriate duplicate portable gas detection
equipment suitable for the cargoes carried, are the officers’ familiar with
the operation, calibration and is the equipment being maintained in
accordance with manufacturers and industry recommendations?
Inspectors Observation: One packet of “in use” benzene tubes was noted OCIMF Release - CORONAVIRUS (COVID-19) OUTBREAK
with 5 of the humidity filter tubes unused indicating 4 of the benzene tubes
used individually rather than in accordance with makers instructions. The outbreak of novel coronavirus (COVID-19) in Peoples Republic of China (PRC) sadly continues to
cause loss of life. The outbreak is impacting travel both, within PRC and internationally. Many countries
are providing their citizens with health and travel advice reflecting that available from the WHO.
That advice continues to develop alongside the situation, with governments issuing advice ranging from
suspending all travel to enforcing a quarantine period on those travellers who may have visited affected
areas.
This has added a further layer of complexity to the management of Inspector courses and audits. OCIMF
has therefore decided to suspend all SIRE (Cat-1 & Cat-3) audits, refresher courses and new-inspector
courses for the year 2020.
OCIMF will review the situation at the end of June 2020 to assess whether inspector courses and audits can
be reinstated. OCIMF will keep auditors informed of any decisions.
As this will have an impact on several stakeholders within the SIRE programme, OCIMF recommends that
the clarifications provided below are read and understood.
SIRE Inspector (Cat-1 & 3) Audits - Accreditation and Renewal (including retakes).
OCIMF will provide extensions of a period of 12months to all inspectors whose accreditations are expiring in
2020. This includes all auditor inspectors as well. Please note that these extensions are temporary, and all
accreditation cycles will be brought in line with original accreditation dates in the following year.
All Inspector Audits (Accreditation and renewal audits, including any retakes) are being suspended with
immediate effect.
OCIMF will review this situation at the end of June 2020
Please do not make any arrangements for audits or audited inspections with immediate effect. If there are
any audits that have already been planned with arrangements for travel made, then you must contact
OCIMF immediately to seek clarification.
OCIMF will, of course, keep the situation under review and provide updates.
OCIMF SIRE Auditors Conference.
Please noted that considering this situation and the consequent changes, the SIRE Auditors Conference for
2020 is cancelled.
Please do not hesitate to contact OCIMF if you have any questions.

Inspectors should never feel pressured to attend vessels where they feel they are putting themselves at risk
and if in doubt please ask.

It is essential that the gas testing equipment is used as per makers VIQ 4.17 Are the master and deck officers aware of the requirements of Electronic Chart Display and Information
instructions to ensure no distortion in the accuracy of any possible gas System (ECDIS) and does the system fitted meet SOLAS and flag state requirements?
measured. This is considered high risk. With reference to newsletter #9 and the use of “plug and play” keyboard and mouse I was presented with the
following document from a vessel to suggest that the add on mouse in use (in addition to the main trackball) was
“approved”.
VIQ 8.15 Where fitted, is the condition of the cargo tank heating system
satisfactory, is it regularly tested and is any observation tank free of oil? Transas have further advised that;
Inspector Observations: There had been a welded repair to the sea water “Connecting a non-approved device will cancel the
inlet line to the tank cleaning heater in the ballast pump room. The same ECDIS certification.
spool line was noted with signs of further pinhole leaks appearing. But, if there is an issue with a specific Input device,
such as the Keyboard or Trackball and we were
informed, then you can connect a normal 3rd party
keyboard or mouse.
But this, only temporarily and until the replacement
units have been received.”
This is totally inadequate and having spoken to
Transas on the subject they have provided an
example certificate below that should be provided
by the vessel in any similar circumstances;

Initial Operator Comments: Root Cause:


Spool line pinhole leaks appearing.

Corrective Action:
The sea water inlet pipe on the tank cleaning system has been dismantled
repaired/welded in the workshop. Pipe in place and tested in good working
condition, November 05th 2019. See attached photo.
Preventive Action:
Verify that the sea water inlet lines are implemented in the planned
maintenance system onboard.
Issued Lesson Learnt report and sent to all vessels in the fleet.
Regrettably here the operators believe that the repair they have performed
seen in the picture by build-up welding on the pipe is permanent. The Thank you for reading our inspector Bulletin!!
pipeline should have either been renewed or the area identified with the
pinhole then cropped out and an insert repair added.

AWP Marine Consultancy Ltd


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Issue 13

Inspector Bulletin
Latest updates & News feeds for Inspectors. 27th Apr 2020

Experience Transfer Advice and Guidance Regulation Updates

Coronavirus (COVID-19) Guidance and Updates


on Port and Terminal Access Worldwide
Seafarer Mental Health Awareness

In view of the rapidly changing situation with COVID and Mental illness is estimated to cost UK businesses £30billion every year, through lost production,
as we are still able to perform inspections in many recruitment and absence. The Office of National Statistics has reported that one in six adults (almost
20%) will be experiencing a mental health problem at any one time. The chances of members of ships’
locations following both OCIMF and client risk based
crews being affected are therefore statistically high – and may be exacerbated by particular aspects of
approach the following attached links will be of assistance seafaring, such as separation from family and isolation. This is particularly prevalent at this very
to both inspectors, clients and operators to determine stressful time during the CORONAVIRUS outbreak where seafarers are often forced to become even
where ports and terminals still permit inspections to be more isolated with little or no shore leave, no possibility of relief due to travel restrictions and further
performed. The decision to commission SIRE/BIRE and difficulties in obtaining fresh provisions onboard due to terminal and other restrictions.
OVID inspections rests with the Member/Submitting
Organisation and AWP will work with the members to The terms “mental health” and “mental illness” refer to the social, psychological and emotional
determine if it is feasible for an inspection to be well-being of individuals.
Mental illnesses, which include conditions such as depression, bipolar disorder, anxiety disorder,
performed safely under the various industry guidance
anorexia nervosa, obsessive-compulsive disorder, psychosis and schizophrenia, may be less visible
provided. than many physical disabilities but their effects on affected individuals can be very serious.

The Guidance and Updates on Port and Terminal Access is The UK Chamber of Shipping have produced GUIDELINES TO SHIPPING COMPANIES ON MENTAL
being updated on a regular basis hence should be reliable HEALTH AWARENESS to aid shipping companies on drawing up policies on mental health and mental
for general planning. illness. Companies are recommended to adopt such policies; if they already have policies in place,
they are recommended to review them in the light of these guidelines. This is particularly important
at this time with COVID-19 restrictions. https://awpmarine.com/DesktopModules/EasyDNNNews/
• North of England P and I: https://www.nepia.com/
DocumentDownload.ashx?portalid=0&moduleid=425&articleid=302&documentid=175
industry-news/coronavirus-outbreak-impact-on-
shipping/ Inspectors are encouraged to make themselves familiar with existing health guidelines on COVID-19
• Inchcape Shipping Service: https://www.iss- prior to visiting any vessel and ensure that they do not take up any assignment if they exhibit any such
shipping.com/pages/coronavirus-port-country- COVID symptoms. The guidance can found on this link (https://www.ics-shipping.org/docs/default-
implications source/resources/coronavirus-(covid-19)-guidance-for-ship-operators-for-the-protection-of-the-
health-of-seafarers.pdf?sfvrsn=6 )

The inspector has a responsibility to:

• Decline or cancel an inspection appointment if they have suffered or have been in contact with
someone else who has suffered COVID-19 symptoms in the 14 days before an inspection.
• Decline or cancel an inspection appointment if they are aware that the vessel to be inspected has
been subject to health restrictions imposed by a government body in the 14 days before an
inspection.
• Decline or cancel an inspection appointment where travel to the vessel would breach travel
restrictions imposed by National, Regional or Local Governments or require them to self-isolate upon
returning home.
• Refuse a request to be accompanied by a trainee
inspector.
• Verify that travel to and from the port of inspection
can be completed in compliance with National,
Regional and Local Government regulations in force
at the time of travel.
• Comply with any additional safety precautions or
PPE requirements imposed by a terminal or vessel as
“ Our company goals are simply stated a result of the COVID-19 pandemic, provided it is safe
with the target towards No accidents, to do so.
• Comply with social distancing requirements put in
No incidents and No negative feedback place by the vessel, terminal and, where applicable,
the local government as far as is possible while
from our customers and Employees ” onboard a vessel.
• Avoid personal contact and maximise social
distancing wherever possible.

AWP Marine Consultancy Ltd


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Issue 13

Inspector Bulletin Latest updates & News feeds for Inspectors. 27th Apr 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 2.7 Is the vessel free of conditions of class or


significant recommendations, memoranda or
notations?
VIQ 10.32 Are the following, where
Following on from this question raised in Newsletter 12 we have applicable, all in good order and do they
had some very positive challenging comments on the subject appear to be well maintained?
asking why we should be raising observations when class have
noted clearly in the survey status that a piece of equipment has Inspector Observations: The remote wire pulley for
been removed from service requiring no further action by the the port boiler safety valve was obstructed by a
operators unless they chose to reinstate the equipment in the bracket when tensioned such that the valve may
future in which case class were to reattend the recommissioning. not lift when fully activated.
It therefore follows that this has little impact on the risk of the
vessel or its operation and hence raising the issue as an Initial Operator Comments: We thank the inspector
observation would be of no value to the member or the for bringing this to our attention. The valve lever
operators of the vessel. This should therefore be the approach bonnet is screwed onto the valve body and this had
recording such equipment removed from service under the come loose due to vibration. This occurred shortly
comments section rather than to raise as an observation. prior to the inspection and resulted in the wire being
obstructed by the bracket. We have since
It was stated in the last newsletter OCIMF take the stance that if re-attached the point where it is screwed to the
a piece of equipment is fitted to the vessel regardless of valve body and the wire is now clear of the bracket
whether it is mandatory then it should be operational or should Crew are reminded to frequently check the
be removed from the vessel. This should refer specifically to VIQ readiness of safety mechanisms. The finding will be
4.7 where the OCIMF guidance states Note: Regardless of shared with other vessels in our fleet to raise
whether a vessel is required by legislation to carry specific awareness and prevent recurrence.
navigational equipment, if equipment is fitted then it should be
operational.

VIQ 5.9 Are the officers and


ratings aware of the
requirements of the ISGOTT
Ship/Shore Safety Check List
(SSSCL) and are the provisions
of the check list being complied
with?

Ashtrays should be of the self-


IACS Definitions extinguishing type (honeycomb,
enclosed)

Recommendations/Conditions of Class Possibly not the best impression


‘Recommendation’ and ‘Condition of Class’ are different terms made on the bridge !!!!
used by IACS Societies for the same thing, i.e. requirements to
the effect that specific measures, repairs, surveys etc. are to be
carried out within a specific time limit in order to retain class.
VIQ 4.7 Is navigation equipment appropriate for the
Memoranda size of the vessel and in good order?
Other information of assistance to the surveyor and owners may One way to identify if the bridge team are fully familiar with
be recorded as ‘memoranda’ or a similar term. They may, for the navigational equipment and its optimum use is by
example, include notes concerning materials and other identifying alarm settings which must be set practically and in
constructional information. A memorandum may also define a line with industry and/or operators policies.
condition which, though deviating from the technical standard,
does not affect the class (e.g. slight indents in the shell which do To the right you can see a compass display having 2 gyros and
not have an effect upon the overall strength of the hull or minor one magnetic compass. Note the alarm threshold for the gyro
deficiencies, which do not affect the operational safety of the compasses set at 10 degrees between the two which I believe
machinery). is excessive here. Practically this should not be set more than
3 to 5 degrees maximum to optimise the alarms in the event
In addition, memoranda could define recurring survey of failures or problems occurring. Just one of the many points
requirements, such as annual survey of specified spaces, or to determine the overall awareness of the OOW onboard.
retrofit requirements, which have the de-facto effect of
conditions of class.

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Issue 13

Inspector Bulletin
Latest updates & News feeds for Inspectors. 27th Apr 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.31 Are lifebuoys, associated equipment and


pyrotechnics in good order, clearly marked and are
there clear procedures in place to ensure that only VIQ 4.7 Is navigation equipment appropriate for the size of the vessel and in
intrinsically safe lights are located in the gas good order?
hazardous areas?
Self-contained RLTA are often disassembled for trans- 4.7.10 A daylight signalling lamp.
porting the units to the vessel. Inspectors should check to
ensure that the equipment is reassembled and rockets All ships of over 150 GT, when engaged on international voyages, shall have on board an
correctly positioned ready for immediate use. efficient daylight signalling lamp which shall not be solely dependent on the ship’s main
source of electrical power. (SOLAS 1974 V/11)

The WRONG way – firing pin disconnected and


not ready to be used. Reference MSC.95(72) Performance Standards for Daylight Signalling Lamps
“Each daylight signalling lamp should be provided with at least three spare illuminants
complying with the type tested illuminant.”

Quick Note:
Thank you for taking your time to read our Inspector Bulletin. If you have anything of
interest that you would like to share with us or you wish to add anything to the next
edition, please Email Jordan@awpmarine.com

Click the link Below to see all the latest news from AWP Marine

https://awpmarine.com/Latest-News

The RIGHT way (please ignore the date as this is


an older photograph for illustration purposes)

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Issue 14

Inspector Bulletin Latest updates & News feeds for Inspectors. 2nd June 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.17 Are the crew aware of safe entry procedures


into the pump room, compressor rooms and trunk
spaces as applicable and are safe entry procedures being
followed? VIQ 5.32 Are lifejackets in good order and correctly located?
Inspector Observations: The cargo pump room was not provided
with a fixed communication system. The only means of Inspector Observations: The lifejackets on board were not in accordance with MSC.207(81) as they
communication was by portable radio. required tying of knots.

Initial Operator Comments: Not applicable for the vessel as the date on which keel was laid is 04
February 2008 and the delivery date as recorded in Form A or Form B Q1.8.3 of the IOPPC is 06
September 2008.

The MSC.207(81) requirements applies to lifejackets provided on board ships constructed (having
their keel laid) on or after July 1, 2010 and when providing new lifejackets to vessels with a keel
laying date before July 1, 2010. However, if it becomes necessary
to supply new lifejackets, this will be done strictly in accordance
with existing requirements. Also, as a preventive action – a
campaign of checking lifejackets compliance across the Fleet was
initiated in the Company.

It’s important for inspectors to ensure that when they raise


observations on existing vessels that the legislation is also
applicable here or not. Where there is doubt the inspector should
check at the end of the inspection with reference material such as
ISGOTT 10.10.2 Pumproom Entry Procedures Seamanship / Regs4Ships or onboard publications before raising
A communications system should provide links between the the observation and you always have our support in the office to
pumproom, navigation bridge, engine room and cargo control try to help clarify with anything.
room.
Arrangements should be established to enable effective
communication to be maintained at all times between personnel VIQ 5.29 Are lifeboats, including their equipment and launching mechanisms, in good
within the pumproom and those outside. Regular communication order and have they been launched and manoeuvred in the water in accordance with
checks should be made at pre-agreed intervals and failure to SOLAS requirements?
respond should be cause to raise the alarm.
VHF/UHF communication should not be used as a primary Inspector Observation: The call sign identification marking on top of the enclosed lifeboat appeared
communication method where it is known that reception may too small to be viewed from the air. Each letter size on the call sign was 65mm width x 100mm
not be reliable or practicable due to noise. Where communication height.
by VHF/UHF is difficult, it is recommended that a standby person
is positioned on the pumproom top and that a visual and remote The observation references to the extreme height and width of the letters here.
communication procedure is put in place.
Reference LSA code 4.4.9.3 states Means of identifying the ship to which the
OCIMF An Information Paper on Pumproom Safety lifeboat belongs and the number of the lifeboat shall be marked in such a way
Arrangements should be established to enable effective that they are visible from above.
communication to be maintained at all times between personnel
within the pumproom and those outside. Regular communication DNV-GL Rules for Classification and Construction Guidelines for Lifeboats and
checks should be made at pre-agreed intervals and failure to Rescue Boats Section 5 Hull Outfit 1.3 states “The identification of the ship shall
respond should be cause to raise the alarm. consist of the signal letters or the IMO number of the ship. Letters and number shall be painted or
A communications system should provide links between the pasted on the top of the cover, if available, with a height of not less than 500 mm and not less than
pumproom and the navigation bridge, engine room and cargo 50 mm width*, where possible.” *Note the width is the actual thickness of the letter itself rather
control room. In addition, audible and visual repeaters for than how wide the letter itself is.
essential alarm systems, such as the general alarm, should be “Other markings on the lifeboat shall be so arranged to avoid visual mixing with the markings
provided within the pumproom. defined above”.

Hence it should be noted that there is NO requirement for cargo


pumprooms to be fitted with a fixed communication system such
as telephone booth. However there MUST be an effective means
of communication established that MAY be through the use of
“ Our company goals are simply stated with the target
portable UHF radios. The vessels operator should have towards No accidents, No incidents and No negative
established the method of communication that includes the use
of headsets as maybe determined by the noise level. Further, feedback from our customers and Employees ”
there should be no significant areas in the pumproom that may
have signal issues for the communication system in use.

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Issue 14

Inspector BulletinLatest updates & News feeds for Inspectors. 2nd June 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 8.20 If stop valves are fitted which permit isolation


of individual tanks from the common venting system, **Safety Alert**
are they provided with positive locking arrangements
and are the keys under the control of the person in
overall charge of the cargo transfer?
Carbon Monoxide detected inside Ballast Water Treatment plant room
Where stop valves are fitted, they shall be provided with VIQ 6.21 If the vessel is provided with an approved Ballast Water Treatment System, is
locking arrangements which shall be under the control of the system in good order, used where required and are officer’s familiar with the
the responsible ship's officer. There shall be a clear visual safe operation of the same?
indication of the operational status of the valves or other
acceptable means. Inspector Observations: At the time of entering the BWTS room for visual inspection,
high level (maximum 110 ppm) of Carbon Monoxide was detected by portable gas
Here is a good example of well managed inert gas tank detectors in the BWTS room. (Checked again through the ventilator of BWTS and
valve arrangements detected same high level of carbon monoxide.)
(The BWTS of Electrolysis and Neutralization system was running when inspected and in
normal working without warning alarm).

Other Inspector Comments: BWTS system Electrolysis unit and Neutralization tank were
located in a compartment at 'A' deck level of engine casing structure port side.

Initial Operator Comments: The ballast water management method of vessel is


designated as D -2(ballast water treatment system) in accordance with IBWMC
(International Ballast Water Management Certificate).
The vessel loaded ballast water through BWTS as per above mentioned method during
cargo discharging operation at Kawasaki, Japan. But, Carbon Monoxide was detected by
portable gas detectors in the BWTS room at the time of entering the BWTS room for
visual inspection.
As a result, the BWTS room was not inspected although BWTS was operated normally.
A gas detector for the detection of hydrogen is installed, but a gas detector for the
Here we have the padlocks protected so that they can be detection of carbon monoxide is not provided although this equipment is installed to
opened easily and a clear statement in the CCR as to the meet requirement of regulation.
level of authority for the control of these valves. After departure, the vessel confirmed from maker that generally, scales are produced by
sea water electrolysis as a by-product and these scales could be accumulated in the each
electrolyzer modules inside as time goes by. If the scales are not removed properly and
accumulated too much, electrode can be damaged by over voltage.
The vessel inspected electrolyzer module according to maker's recommendation. As an
Quick Note: inspection result, scales were confirmed in electrolyzer module and these removed and
conducted chemical cleaning of electrolyzer module.
Thank you for taking your time to read our Inspector After maintenance work, the vessel confirmed that Carbon Monoxide is not detected in
Bulletin. If you have anything of interest that you would BWTS room during BWTS is operating.
like to share with us or you wish to add anything to the To prevent recurrence,
next edition, please Email Jordan@awpmarine.com 1) The vessel added PMS items to periodically inspect and conduct cleaning the
electrolyzer module.
Click the link Below to see all the latest news from AWP 2) The vessel prepared and posted the notice letter that fan should be operated and
Marine checked the atmosphere of BWTS room.
3) The vessel revised BWTS operation checklist to check the contents of Carbon
Monoxide for BWTS room every hour when the BWTS is operating.
https://awpmarine.com/Latest-News 4) This observation was distributed to all fleet vessels to add PMS items to periodically
inspect and conduct cleaning the electrolyzer module.
5) All crew have been educated hazards of Carbon Monoxide refer to MSDS.
6) The company will discuss with related team to install the gas detector sensor for
Carbon Monoxide because it was identified the carbon monoxide could be occurred in
the BWTS room.

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Issue 14

Inspector Bulletin
Latest updates & News feeds for Inspectors. 2nd June 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 10.13 Is a Ship specific list of Critical


equipment defined and available on board and
highlighted in the PMS? Are there measures in
place to ensure that defined critical spare parts
are available on board?

The Company should establish a minimum level of critical


spare parts for the vessel based on a risk assessment
that should include consideration from manufacturers
recommendations, class requirements and redundancy
factors of machinery. There should be an effective means
to ensure that the level of critical equipment can be
monitored. COVID-19 Ongoing Situation and Guidance
It is not for the inspector to determine what he/she We have now begun to gain some experience in dealing first hand with the practicalities
considers to be critical equipment and with it the level of COVID-19 preventative measures when conducting inspections and the concerns that it
of critical spare parts that should be maintained may have on both the inspector performing the work and the vessels staff that are
onboard a vessel. The key point of this question is to required to engage with the inspector onboard. Many industry bodies have produced
ensure that the operators have established a risk based some excellent guidance to help facilitate inspections with minimal risk to all parties with
approach to identify the critical equipment onboard the key message that if either party feels unsafe with the situation then they should
that will be based on several factors including terminate the inspection.
experience, age, reliability, duplication, single point
failure and the effects of these failures. Once the To refresh our inspectors with the latest OCIMF support guidance
operator determines the critical equipment onboard https://www.ocimf.org/news/news-articles/ocimf-covid-19-update-bulletin-8-inspection-
(that maybe further subdivided into safety, guidance-during-the-global-covid-19-pandemic
environmental and operational equipment), then they
can determine a minimum level of spares so that in the It is recommended that when organising travel and accommodation, the following points
event of failure they can return the vessel to a safe are considered:
operational level and/or avoid premature failure of
such critical equipment. OCIMF Information Paper • Travel restrictions can change rapidly during the current crisis, and an
Safety Critical Equipment and Spare Parts Guidance
Inspector may be prevented from travelling to undertake an inspection or,
should be consulted by the operators to help follow a
prevented from travelling home upon completion of the inspection. Where the
risk based approach to determining the levels of critical
spares needed. latter is a possibility, it is recommended that the Inspector engages with the
Submitting Company to develop a contingency plan before travelling to the
inspection.
• Distant travel should not be booked for overnight trips if suitable safe
accommodation cannot be booked and confirmed in advance to ensure
adequate rest for safe journey management.
• Driving long distances to and from inspections is undesirable as fuel/food/
rest stops will inevitably increase exposure to COVID-19 for inspectors and the
potential for passing this on to ship’s staff and the inspectors’ families.
• An Inspector is responsible for ensuring that they are adequately rested and
fit to drive when they drive in connection with a Programme Inspection.
• Sleeping on board a vessel which is in the process of being inspected or,
when an inspection has been completed, is discouraged unless it is impossible to
leave the vessel.
• An Inspector should leave a vessel as soon as an inspection has been
completed.

AWP Marine Consultancy Ltd


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Issue 15

Inspector Bulletin
Latest updates & News feeds for Inspectors. 28th July 2020

Experience Transfer Advice and Guidance Regulation Updates

Good Observation

VIQ 8.27 (C) Where fitted, is the condition of the cargo


tank heating system satisfactory, is it regularly tested
VIQ 3.2 Are the STCW and flag Administration’s regulations that control hours of work
and is any observation tank free of oil?
to minimise fatigue being followed and are all personnel maintaining hours of rest
records in compliance with MLC or STCW requirements?
When overheating or overcooling could result in a dangerous
condition, an alarm system which monitors the cargo This is the sole question within the VIQ that directly addresses rest and fatigue, hence this question
temperature shall be provided. (See also operational has some significant importance and inspectors are encouraged to focus in this area during the
requirements in 16.6.) (IBC 7.1.5.4) inspection.

Inspectors Observation: The vessel was carrying heat Lack of fatigue management has been identified as a significant contributory factor in accidents on
sensitive flammable inhibited cargo yet the cargo vessels. This is further supported through research where shortfalls have been highlighted in
computer alarm settings for tank temperatures were set current fatigue management with expectations that seafarers are responsible for their own fatigue
management that can lead to a tolerance to fatigue in the long run.
to zero at the time of the inspection. Further, there were
no records of monitoring of the temperatures during
There are a number of points to look at when addressing
transit.
this question from an inspection view. It is not a case of
a simple review but of rest hours recorded;
IBC 16.6 Cargoes not to be exposed to excessive heat 1. Are there records of work / rest hours maintained and
16.6.1 Where the possibility exists of a dangerous are these records accurate (cross check with operations)
reaction of a cargo, such as polymerization, 2. Are individuals completing their own rest hour records
decomposition, thermal instability or evolution of gas, to ensure record accuracy (can be hard copy or soft copy
resulting from local overheating of the cargo in either the access)
tank or associated pipelines, such cargo shall be loaded 3. Are the crew well aware of their watch and duty
periods both at sea and in port for planning their own rest
and carried adequately segregated from other products
(duty roster should be posted in public areas)
whose temperature is sufficiently high to initiate a 4. Are the duty schedules and planning of watches
reaction of such cargo (see 7.1.5.4). effective (ensure 6/6 rotations and extensive duty periods
are not scheduled)
5. Is the work and living environment onboard designed
to facilitate quality rest (noise/ light/ heat/ vibration)

It is essential that senior management are aware of any


issues of fatigue or rest infringements onboard the vessel
and there should be clear evidence of shore management
involvement with the operations onboard;

1. Are non-conformities raised through an effectively


high channel to ensure actions taken and taken timely
here, not just months after the issues
2. Is there a person designated responsible ashore
for monitoring the rest hour compliance (do they take
an active interest here)
3. Is there an effective planning process to mitigate
the risks of rest hour breeches (maybe electronic
planning tools)
4. Does the shore management take effective further
Disclaimer: this material discusses OCIMF activities based on
action where the trend on breeches is rising or
personal experience and opinion and not necessarily in extensive (additional manning / out of service
agreement with OCIMF or OCIMF members views. downtime / amendments to C/P)

Inspectors are encouraged to share their experiences for us The attached link to AMSA guidelines on fatigue is a
all to learn from here. useful publication looking at the problems and
possible solutions: https://www.amsa.gov.au/sites/
default/files/amsa-fatigue-guidelines-web.pdf and
Click the link Below to see all the latest news from AWP the IMO Guidelines on Fatigue http://www.imo.org/
Marine en/OurWork/HumanElement/Documents/MSC.1-
Circ.1598.pdf
https://awpmarine.com/Latest-News

AWP Marine Consultancy Ltd


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Issue 15

Inspector Bulletin Latest updates & News feeds for Inspectors. 28th July 2020

Experience Transfer Advice and Guidance Regulation Updates

Experience Transfer

VIQ 5.5 Are the crew aware of the requirements for wearing
personal protective equipment such as boiler suits, safety
footwear, eye and ear protection, safety harnesses, respiratory VIQ 8.68 (LPG) and VIQ 8.72 (LNG) Are officers aware of the operation of the chemical
and chemical protective equipment? dry powder system, and is the system in good order?
VIQ 5.32 Are lifejackets in good order and correctly located?
Inspectors observation: The fixed dry powder stations contained sodium bicarbonate
Inspectors observation: The vessel had a number of non SOLAS based chemical reagent rather than potassium bicarbonate as recommended by MSC.1/
approved life vest/work vests located at the gangways for Circ.1315
working over side / rigging ladders.

There is no requirement for work vests to be SOLAS approved,


though equipment , especially PPE should be fit for purpose.
Personal floatation devices and work vests have four main
buoyancy levels: 50, 100, 150 and 275.

Standards applicable to this level range from EN 393 or ISO


12402 – 5 to EN 399 or ISO 12402 – 2.
Hence the work vests should be in good condition and meet a
suitable standard that is stated within the companies ISM
procedure.

VIQ 10.2 If the machinery space is certified for unmanned Only chemicals based on the salts of potassium should be used. Dry chemical storage
operation is it being safely operated in that mode without containers should be designed to pressure codes of practice acceptable to the
regular alarms occurring under normal conditions? Administration, for the maximum system pressure developed at 55ºC. MSC.1/Circ.1315 3.4
Inspectors Observation : There were 5 off scan alarms indicated
So why should potassium bicarbonate be used rather than sodium bicarbonate? Simply in
on the engine alarm system relating to bilge well alarms and fuel
tank overflow alarms.
order of performance, fire tests on flammable liquids have shown potassium bicarbonate
based dry chemical to be more effective than sodium bicarbonate based dry chemical.
Similarly, the monoammonium phosphate based dry chemical has been found equal to or
Inspectors should check if there are any alarms that have been
isolated (or offscan) and where possible establish the reason better than the sodium bicarbonate based chemical. Hence this is the standard required.
why this could be. Especially relevant where the machinery
space is operating unmanned and isolation of alarms can
identify serious problems.
VIQ 2.10 Are the Engine Room (Part I) and Cargo (Part II) Oil Record Books (ORBs) correctly
completed, free of any pollution incidents, violations and are slop/waste oil disposal certificates
provided?

Inspectors Observation; The oil record book part 1 recorded the evaporation of water from the oil residue tank
under C 12.4, however this was not recorded as an approved means of reducing water content under 3.2.3 of the
IOPP Form B.

With reference to MEPC.1/Circ.640 and MEPC.1/Circ.736Rev.2, the heating of oil residue (sludge) as a method of
reducing its volume by evaporation should be recorded in the Oil Record Book, Part I, under Code (C) (Collection,
transfer and disposal of oil residues (sludge)), paragraph 12.4 on condition that the sludge tank is listed in section 3.1
of IOPP supplement. There is no requirement that such natural evaporation should be marked within the IOPP
certificate however, and as such this need not be recorded as a means of disposal of oil residue.

AWP Marine Consultancy Ltd


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Issue 16

Inspector Bulletin Latest updates & News feeds for Inspectors. 24th Sep 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.43 Are crew members familiar with donning


breathing apparatus and are Fireman’s Outfits in
good order and ready for immediate use? VIQ 8.64. Do all key personnel on board involved in DP operations comply with the IMCA
For ships constructed on or after 1 July 2014, a minimum of two and UKOOA minimum requirements for experience and training?
two-way portable radiotelephone apparatus for each fire party
Note: Confirm DP certification and experience from log books. Confirm that Engineers and ETOs have
for fire-fighter's communication shall be carried on board. Those
appropriate training/guidance on how to operate/maintain plant when in DP mode. (IMCA M 117 Rev
two-way portable radiotelephone apparatuses shall be of an
1- The training and Experience of key DP personnel UKOAA Tandem Loading Guidelines).
explosion-proof type or intrinsically safe. Ships constructed
before 1 July 2014 shall comply with the requirements of this
paragraph not later than the first survey after 1 July 2018.
(SOLAS II-2/10.4) Inspectors Observations: There was no evidence that two Engineers (3/E and 4/E) had
attended a structured DP familiarisation course, as per IMCA M117, item 6.4. Sighted
Inspectors Observation. The fire fighters radios were not familiarization records of both Engineers but Operator's form did not address DP
provided with any headset or throat mic option permitting familiarization for Engineers, only a short, general section for ETO/Electricians.
handsfree operation for firefighting.

Initial Operator Comments: Root cause: According to IMCA M 117 Rev. 2, Item 6.4 it says,
It is "Recommended" that engineers and electrical and electronics technicians attend a
structured DP familiarization course either arranged onboard or at a recognized training
establishment. It does not state "Require", and the company follows Oil & Gas UK matrix
when it comes to DP familiarization / training for the DP involved personnel. There is NO
requirement for Senior or Junior engineers to attend this course according to IMCA.
Corrective action: The company will continue to follow Oil & Gas UK matrix, and Oil
majors / operators requirements for DP familiarization / training for DP personnel.

Inspectors Feedback: As highlighted below, VIQ question 8.64 says “comply with the IMCA
and UKOOA”, so from my side it means that content of IMCA Guidelines, under this
particular item, are supposed to be followed. We shall have in mind that IMCA publications
have been always described as “guidelines” but since there are not so many good
SOLAS requires firefighters’ radios to be explosion proof
references about DP operational safety, it’s been recognized by industry as the “best
or intrinsically safe. From a user point of view it would
practice”.
also be expected that firefighters’ radios are “fit for
purpose”, i.e. work within the environment of a fire STCW Section B-V/f also says “ Training should not be limited to DPOs and DP masters only;
scenario, have a sufficient operating range, and are other personnel on board, such as electro-technical and engineer officers, may require
designed for use by crew members wearing full firefighter additional training and experience to ensure that they are able to carry out their duties on
suits with large gloves, helmets and breathing apparatus. a DP vessel.”
Radios that can be fitted on helmets and used with
breathing masks are recommended, BUT the present
legislation does not make this mandatory and the Client Comment: The reality lies with the company and charterers to supply personnel with
legislation can be considered subjective here. Hence it certification to operate the equipment required for specific vessel. I.e. a DP2 vessel may
would be down to the inspector to determine that the not be working DP mode on current charter hence officers do not require training. If
radio is not fit for purpose without a headset or voice mic however the vessel is utilizing its DP capabilities then all personnel involved in the
that would be very challenging and not possible to execution of duties should be trained and experienced in its function. Minimum
determine in the time of a SIRE inspection. requirements specified by charterers of such vessels as supply operations require DP hours
Class interpretation UI SC-291 refers to the actual for DPO of 1000 hours but diving operations will need 10,000 hours.
construction and hazardous area use, but not the physical The local requirements of area of operation might be specific and mandatory, hence takes
operation. The attached white paper published by precedence.
Cobham SATCOM further illustrates this problem and
worth a read.
From the above this does appear to leave gaps in the guidance basis the operation the
https://www.radioholland.com/wp-content/uploads/2020/06/71- vessel maybe involved in, but also the interpretation of “Recommended” and “Required”
155452-solas-chapter-ii-2-regulation-10104-2nd-edition-lo-1.pdf? with applying the SIRE guidance here. We hope this guidance can be further clarified in the
utm_source=webpage&utm_campaign=firefighter&utm_medium=bu
next VIQ.
tton&utm_content=whitepaper

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Issue 16

Inspector Bulletin
Latest updates & News feeds for Inspectors. 24th Sep 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.43 Are crew members familiar with donning


breathing apparatus and are Fireman’s Outfits in
good order and ready for immediate use?
VIQ 5.40 Are the crew familiar with the fixed fire extinguishing systems, where fitted, are
Inspectors Observation; The 4th engineer was a they in good order and are clear operating instructions posted?
designated fireman as stated on the crew muster list yet
he was unable to demonstrate donning of the breathing VIQ 8.68 (LPG) and 8.72 (LNG) Are officers aware of the operation of the chemical dry
apparatus. powder system, and is the system in good order?
Annual maintenance of fixed dry chemical
powder systems shall include agitating the
dry chemical powder charge with nitrogen in
accordance with system manufacturer's
instructions.
(Note: Due to the powder's affinity for
moisture, any nitrogen gas introduced for
agitation must be moisture free.)
On a two-yearly basis a sample of dry powder
shall be subject to test for moisture content.
(MSC.1/Circ.1432)
Inspector Observations: The vessel spare dry
chemical powder refills for the portable
extinguishers was over 6 years of age.
Unfortunate observation Although there is no specific regulatory
for the vessels staff, but
time period for renewing the dry powder
good to see that the
inspector is not just
compound in general, reference is drawn
addressing the condition to the recent USCG detention item which
of the equipment here. It states “Although there is no clear requirement concerning the validity date of
is essential to witness the
powder in the FSS Code, it is generally considered necessary to refill the powder
crews familiarity with
every 5 or 6 years, in principle.” Obviously if it is stated in the makers instructions
equipment onboard for
their specific roles and then this must also be followed.
prepared in the event of
an emergency. https://www.classnk.or.jp/hp/pdf/info_service/psc/bulletin/nkpsc20_e.pdf

Inspectors are encouraged to share their experiences for us VIQ 8.1 Are the officers aware of the operator's policy statements, guidance and
all to learn from here. procedures, including information on maximum loading rates and venting
capacities with regard to safe cargo operations?

Disclaimer: this material discusses OCIMF activities Masters should be provided with information on
maximum permissible loading rates for each cargo
based on personal experience and opinion and not
and ballast tank and, where tanks have a combined
necessarily in agreement with OCIMF or OCIMF members venting system, for each group of cargo or ballast
views. tanks.
Inspector Observations: Information on maximum
Click the link Below to see all the latest news from AWP permissible loading rates for each ballast tank was
Marine not readily available.
https://awpmarine.com/Latest-News
Important point here that it is not just the cargo capacities that need to be known.

AWP Marine Consultancy Ltd


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Issue 17

Inspector Bulletin
Latest updates & News feeds for Inspectors. 12th Nov 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.5 Are the crew aware of the requirements


for wearing personal protective equipment such
AWPS Development – Conflict of Interest TAB
as boiler suits, safety footwear, eye and ear
protection, safety harnesses, respiratory and Inspectors will now see a new tab appearing on their log in page where we would encourage you to
add any existing or new conflicts that you have as this will alert us to any potential conflicts at an early
chemical protective equipment?
stage of the scheduling process.

Documented guidance relating to the use of PPE should


be provided and the crew should be familiar with those
requirements or where to refer to the requirements.
SMS often provide a matrix of PPE requirements for
simplicity posted in various public areas on the vessel. If
there is no such matrix then inspectors should ascertain
there is adequate guidance provided.
https://awpsystem.com/Login.aspx?returnurl=Home
Nice example of best practice here with the PPE
placed outside of the chemical locker such that this
can be donned prior to entering the locker itself. VIQ 5.47 Is the vessel provided with a safe means of access and are all
available means of access (gangway / accommodation ladder / pilot ladder /
transfer basket) in good order and well maintained?

Inspectors Observation The company procedure had not defined means to rig the pilot ladder and the deck
hands who engaged in rigging the pilot ladders confirmed that the pilot ladder was secured to the deck rings
with two steel shackles on the ladder side ropes, by such rigging arrangement, the ladder spacers took the
weight of the ladder. (Reference: Code of Safe Working Practices for Merchant Seafarers, Chapter 22.10.)

This above arrangement is NOT acceptable and should be two designated strops
constructed from manila rope with a breaking strength of no less than 2.4 metric tonnes/24
Kilo Newtons (typically 18mm diameter). The strops should be secured to the deck strong
Inspectors are encouraged to share their experiences points and then secured around the side ropes of the ladder between the steps by means of
for us all to learn from here. a rolling hitch as follows;

Disclaimer: this material discusses OCIMF Further reference should be made to Fathom Safety
A Guide to Pilot Ladder Securing
activities based on personal experience and
https://awpmarine.com/Latest-News/a-guide-to-
opinion and not necessarily in agreement with pilot-ladder-securing and courtesy of Arie Palmers
OCIMF or OCIMF members views. https://www.linkedin.com/posts/activity-
6716073191493697536-nqDP
more reference to failed systems;
Click the link Below to see all the latest news from AWP http://ukmpa.org/wp-content/
Marine uploads/2019/04/20190401-Pilot-Ladders-Error-
Enforcing-Conditions-Final.pdf
https://awpmarine.com/Latest-News
Another subject on pilot ladders relates to fake certificates, again courtesy of Arie Palmers;
https://www.linkedin.com/posts/activity-6717698389724712960-GuG1

AWP Marine Consultancy Ltd


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Issue 17

Inspector BulletinLatest updates & News feeds for Inspectors. 12th Nov 2020

Experience Transfer Advice and Guidance Regulation Updates

VIQ 5.28 Are the officers aware of the


maintenance requirements for lifeboat, liferaft,
rescue boat release hooks and free-fall lifeboat
release systems, where fitted and, are lifeboats, VIQ 8.49 If the vessel uses its own cargo hoses, are they in good
rescue boat and liferafts including associated
order, pressure tested annually and is a record of all hose tests and
equipment well maintained ready for use?
inspections maintained on board?
Lifeboat or rescue boat on-load release gear, including free-fall
lifeboat release systems shall be: Cargo hoses in service should have a documented inspection at least annually to confirm
- maintained in accordance with instructions for on-board their suitability for continued use. This should include:
maintenance as required by regulation 36; - A visual check for deterioration/damage.
- subjected to a thorough examination and operational test - A pressure test to 1.5 times the Rated Working Pressure (RWP) to check for leakage or
during the annual surveys required by regulations I/7 and I/8 by movement of end fittings. (Temporary elongation at RWP should be measured as an
properly trained personnel familiar with the system; and interim step.)
- operationally tested under a load of 1.1 times the total mass of
- Electrical continuity test. (ISGOTT 18.2.6.1)
the lifeboat when loaded with its full complement of person and
equipment whenever the release gear is overhauled. Such over-
Portable cargo pump hoses should be tested and maintained as per manufacturers
hauling and test shall be carried out at least once every five guidelines.
years. (SOLAS III/20.11.2)
Inspectors observations: Vessel was provided with 2
Reference is made to the attached TORM MAREN Marine Multi-chem 4" x 24 meters Framo cargo hoses which
were annually tested for continuity by ship's staff.
accident report
However, hydrostatic and elongation tests for both
https://www.iims.org.uk/wp-content/uploads/2020/09/Danish- cargo hoses as required by ISGOTT chapter 18.2.6.1
Maritime-Accident-Investigation-Board-TORM-report.pdf were not performed on board and were not included in
on the loss of rescue boat 1 APRIL 2020 where the rescue boat the Company SMS.
davit’s wire rope parted, because it was corroded to the extent
that its load bearing capacity was exceeded when the rescue Original Maker's Certificates for cargo hoses were
boat was hoisted. However, the parting of the wire rope was an provided on board with hydrostatic and elongation test
accident event which could not in itself explain why the rescue records included.
boat system failed. Even though the company’s PMS instructed
the officers to inspect and maintain the wire rope, they did not Further, Makers Service Bulletin No.29 stated The
act upon the deteriorating condition of the wire rope. Neither cargo hose for the portable pump to be tested and
did any of the other officers who continuously inspected, maintained according general in forced rules and
maintained and operated the rescue boat system even when procedures valid for cargo hoses onboard the vessel.
the wire rope was readily visible.

The reason why the condition of the wire rope was not
recognised as being detrimental to the functioning of the
rescue boat system was a combination of three factors:
VIQ 10.38 Are switchboards free of significant earth faults?
1. The manufacturer’s manual and PMS which did not specify
how to assess the condition of the wire rope. Good practice suggests that a near to infinity as possible, but not less than 5 megohms,
2. An absence of training in assessing the wire rope’s condition. should be aimed for on the Insulation Monitoring Device (IMD). This should be achievable
3. The PMS activities were compartmentalised which in practise on a 440-volt system, but on a 220-volt system 2 megohms is acceptable due to the large
meant that only one person was assessing each component. number of parallel circuits.
Additionally, all the factors were compounded by the thorough
examination performed by service providers which made the Note, in the photo to the left
officers trust not only the load bearing capability of the wire the earth alarm setting is 0.2
rope, but the man-riding capability of the system as a whole.
mOhm here such that this does
not give much of a warning
before a serious earth fault
occurs. As a minimum the
alarm setting should be 1
megaohm and ideally 2 or
more mOhms to alert the user
TORM MAREN 1st APRIL 2020 of early warning of potential
Marine accident report on loss of rescue boat problems.

AWP Marine Consultancy Ltd


EMAIL: admin@awpmarine.com TELEPHONE: +44 (0) 151 792 4882

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