40
Annual Report on Port State Control regarding the ISM Code ２００4 Aug. 2005
Annual Report on Port State Control regarding the ISM Code
２００4
Aug. 2005
CONTENTS Introduction
Chapter 1 ISM Non-compliant Ships 1.1 General 1 1.2 ISM non-compliant ships sorted by Flag State 2 1.3 ISM non-compliant ships sorted by Type of Ship 5 1.4 ISM non-compliant ships sorted by Age of Ship 6 1.5 ISM non-compliant ships sorted by Gross Tonnage 7 1.6
Port State of non-compliant ships 8
Chapter 2 Analysis of deficiencies related to ISM Code 2.1 ISM deficiencies sorted by dominant causes 11 2.2 Number of ISM deficiencies sorted by section of the ISM Code for the past four
years 12
2.3 Number of ISM deficiencies sorted by PSC State 13 2.4 Particulars of ISM deficiencies sorted by PSC State 15
2.4.1 Japan 16 2.4.2 Hong Kong 16 2.4.3 Canada 17 2.4.4 Netherlands 18 2.4.5 Australia 18 2.4.6 U.S.A. 19 2.4.7 Germany 20 2.4.8 Korea 21
Chapter 3 ISM deficiencies and Action Code
3.1 ISM deficiencies and Action Codes 22 3.2 Action Code sorted by section of the ISM Code 23
Chapter 4 Companies managing the ISM non-compliant ships
4.1 Management companies and number of ships 26 4.2 Management companies and years of ISM system operation 27 4.3 Nationalities of companies managing ISM non-compliant ships 28
Chapter 5 Analysis of ISM Non-compliant Ships based on Open Information
5.1 General 29 5.2 ISM non-compliant ships sorted by Flag State 29 5.3 ISM non-compliant ships sorted by Type of Ship 30 5.4 5.5 5.6 5.7
ISM non-compliant ships sorted by Age of Ship ISM non-compliant ships sorted by Gross Tonnage ISM non-compliant ships sorted by Port State Nationalities of companies managing ISM non-compliant ships
30 31 32 33
Conclusions 34
Introduction This Annual Report summarizes reports collected by the Head Office of ClassNK from its Branch and Overseas Offices, Flag States and various ship management companies on current activities relating to PSC all over the world, during the year 2004, from January to December. Also included is information revealed on web sites by the PSC authorities about the ships against which actions had been taken by them, especially regarding ISM Code related deficiencies. ClassNK has compiled this Annual Report in the hope that such information be helpful to all personnel concerned, in order to better their understanding of PSC’s attitude to the ISM Code and for the further improvement of their safety management systems. Chapter 1 presents various tables and figures that show the number of ships against which action had been taken by PSC for ISM Code related deficiencies (hereunder referred to as “ISM non-compliant ship”) among those ships classed with NK or ships for which the SMC was issued by NK (hereunder referred to as “NKSMC ship”). Analyses were made for five types of breakdown, namely by Flag State, Type of Ship, Age of Ship, Gross Tonnage and Port State. Chapter 2 presents the results of analyses of ISM deficiencies pointed out by PSC. The breakdowns of deficiencies have been analyzed by number of ISM deficiencies per ship, by the requirements referring to each section of the ISM Code, and by those examples that resulted in the detention of ships. Chapter 3 presents the results of analyses of the actions taken by PSC for ISM deficiencies and their relation to each section of the ISM Code. Chapter 4 presents the actual situation of companies that are managing ships identified with ISM deficiencies, including the size of company and the relationship between years of system operation experience and number of ISM non-compliant ships. Chapter 5 presents the results of various analyses of ISM non-compliant ships (NKSMC ship) based on information gained from the web sites of the Tokyo MOU, Paris MOU and USCG, the data of which shows more than 4 times the number of ISM non-compliant ships compared with ClassNK data.
Note: Definitions of key words used in this Report: PSCO: Port State Control Officer ISM deficiency: a deficiency related to the requirements of the ISM Code ISM non-compliant ship: a ship where action is taken by PSC due to ISM Code related deficiencies, i.e. due to non-compliance with the ISM Code. Action taken by PSC: directives given by PSCO to a ship to take corrective action to rectify an ISM deficiency(non-compliance with the ISM Code) pointed out by PSCO NKSMC: a ship holding a Safety Management Certificate issued by NK NKDOC: a company holding a Document of Compliance issued by NK RO: (Recognized Organization) an organization recognized by a Flag State to conduct audits and issue certificates on its behalf
1
Chapter 1 ISM Non-compliant Ships 1.1 General During the one year period from January to December 2004, NK Head Office received reports from its Branch and Overseas Offices, ship management companies, Flag States and other parties, on a total of 150 ISM non-compliant ships, which was 0.6 times the 249 ships of 2003. Of the total of 150 ISM non-compliant ships, 137 ships were NKSMC ships; of which 122 ships were classed with NK and 15 ships were classed with other societies. The total number includes 13 ships classed with NK but in possession of SMCs issued by other ROs. The number of ISM non-compliant ships during the past five years sorted by SMC issuing organizations is shown on Table 1.1.1 and Fig. 1.1.1.
Table 1.1.1 ISM non-compliant ships sorted by SMC issuing organization ISM non-compliant ships 2000 2001 2002 2003 2004
NK classed ships with SMC issued by other RO 9 11 53 77 13
NKSMC ships classed with other society 14 5 16 17 15
NKSMC ships classed with NK 45 70 135 155 122
Total 68 86 204 249 150
Fig.1.1.1 ISM non-compliant ships sorted by SMC issuing organization The total number of ISM deficiencies for all 150 ISM non-compliant ships was 250 items, which was a steep decrease of 0.71 times that of 2002 and 0.51 times that of 2003.
Fig.1.1.2 Total number of ISM deficiencies for the past four years
0 50 100 150 200 250 300 350 400 450 500
2004
2003
2002
2001
Number of ISM deficiencies
132 350
250
491
46 45
0
2 0
4 0
6 0
8 0
1 0 0
1 2 0
1 4 0
1 6 0
2 0 0 0 2 0 0 1 2 0 0 2 2 0 0 3 2 0 0 4
N K c la s s e d s h ip s w it h S M C is s u e d b y o t h e r R O
N K S M C s h ip s c la s s e d w it h o t h e r s o c ie t y
N K S M C s h ip s c la s s e d w it h N K
135
155
Number of ISM non-compliant ships
122
70
45
2
1.2 ISM non-compliant ships sorted by Flag State
1.2.1 ISM non-compliant ships sorted by Flag State in 2004 Flag states of ISM non-compliant NKSMC ships (137 ships) and the percentage of non-compliance are listed in Table 1.2.1 and Fig. 1.2.1. (Percentage of noncompliance = Number of ISM non-compliant ships/ Number of NKSMC ships x 100)
Tab.1.2.1 ISM non-compliant ships sorted by Flag State in 2004
Flag State No. of ISM
non-compliant ships(A)
No. of NKSMC ships(B)
Percentage（％）
(A/B)
St.Vincent 7 37 18.9
Cyprus 6 92 6.5
Turkey 4 64 6.3
Hong Kong 13 219 5.9
Malta 8 142 5.6
Liberia 9 169 5.3
Singapore 14 391 3.6
Panama 64 1954 3.3
Japan 4 144 2.8
Malaysia 2 75 2.7
Thailand 2 86 2.3
Bahama 1 61 1.6
Others 3 206 1.5
Total 137 3640 3.8
Fig.1.2.1 Percentage of non-compliant ships sorted by Flag State（2004）(%) ＊ This data includes only those Flag States which have 30 or more NKSMC ships.
0
2
4
6
8
10
12
14
16
18
20
St.V
incent
Cyp
uru
s
Turk
ey
Hong
Kong
Mal
ta
Lib
eria
Sin
gapore
Pan
ama
Jap
an
Mal
aysi
a
Thai
land
Bah
ama
Oth
ers
Percentage of ISM non-compliant ships
3
1.2.2 ISM non-compliant ships sorted by Flag State for over four years. The total numbers and percentages of ISM non-compliant NKSMC ships sorted by Flag State over four years are shown in the following Tables (1.2.2 & 1.2.3) and Figures (1.2.2 & 1.2.3). As for the number of ISM non-compliant ships, Panama decreased by about 25% over the previous year, Cyprus reduced to half of the previous year, while Japan and Malta showed a slight decrease, and Hong Kong and Liberia a slight increase. On the other hand, Saint Vincent showed a marked increase. Tab. 1.2.2 Number of ISM non-compliant NKSMC ships
Flag State 2001 2002 2003 2004 Panama 36 79 87 64
Singapore 8 9 15 14
Hong Kong 3 5 9 13
Liberia 4 10 6 9
Malta 2 6 9 8
St.Vincent - - - 7
Cyprus 3 13 14 6
Turkey 6 7 3 4
Japan 2 1 6 4
Malaysia 1 5 2 2
Other 4 13 13 3
Total 75 151 172 137
Fig.1.2.2 Number of ISM non-compliant NKSMC ships
Number of ISM non-compliant ships
0
10
20
30
40
50
60
70
80
90
Pan
ama
Sin
gapore
Hong
Kong
Lib
eria
Mal
ta
St.V
incent
Cyp
rus
Turk
ey
Jap
an
Mal
aysi
a
Oth
er
2001
2002
2003
2004
4
Percentages of ISM non-compliant ships are shown in Table 1.2.3. and Fig.1.2.3. As the percentage of ISM non-compliant ships for Saint Vincent was a first up figure, and these ships were mainly managed by companies located in China and Greece. Cyprus was drastically improved but still remained high. Hong Kong and Malta were still above the average although decreasing, and Singapore, Panama and Japan were improving and below the average. On the other hand, Turkey and Liberia had bad percentages of more than 5%.
Tab.1.2.3 Percentage of ISM non-compliant ships(％) Flag State 2001 2002 2003 2004
St.Vincent - - - 18.9
Cyprus 3.3 11.3 12.8 6.5
Turkey 9.2 9.3 4.8 6.3
Hong Kong 3.9 4.3 6.3 5.9
Malta 3.0 6.7 7.4 5.6
Liberia 3.0 6.7 3.9 5.3
Singapore 2.3 2.4 4.0 3.6
Panama 2.4 4.0 4.6 3.3
Japan 1.5 0.7 4.2 2.8
Malaysia 2.0 7.8 2.7 2.7
Thailand 0 1.2 5.8 2.3
Total 2.7 4.4 5.0 3.8
Fig.1.2.3 Percentage of ISM non-compliant NKSMC ships (%) ＊This data includes only those Flag States which have 30 or more NKSMC ships.
0
2
4
6
8
10
12
14
16
18
20
St.Vincent Cypurus Turkey Hong Kong Malta Liberia Singapore Panama Japan Malaysia Thailand
2001
2002
2003
2004
Number of ISM non-compliant ships
5
1.3 ISM non-compliant ships sorted by Type of Ship. The total number of NKSMC ships (3640 ships) can be sorted into various types of ships as shown in Table 1.3.1. Reflecting the good shipping market, the total number of registered ships with NKSMC increased 6% compared with the previous year, of which the increased ratios for “bulk carriers” and “gas carriers” were relatively high at 8% and 9% respectively. The percentage of ISM non-compliant ships for all NKSMC ships improved to 3.8%. The breakdown of this percentage for each type of ship was: bulk carriers 4.4%, other cargo ships 4.2%, oil tankers 2.5%, chemical tankers 2.4%, gas carriers 0.6%. The decreasing percentages for “chemical tankers” and “gas carriers” were remarkable, and “other cargo ship” also showed a tendency towards decreasing. As for “oil tankers”, it had no particular variation between 2% and 3%. Tab.1.3.1 ISM non-compliant ships sorted by Type of Ship
Percentage (%) （A/B）
Type of Ship
No. of ISM
non-compliant
NKSMC ships
(A)
No. of NKSMC
All Ships
(B) 2001 2002 2003 2004
Percentage of
each Ship’s
Type (B/C)
Bulk Carrier 53 1196 4.8 4.5 4.9 4.4 33
Other Cargo 64 1517 0.8 5.1 6.8 4.2 42
Oil Tanker 18 709 2.2 3.0 1.5 2.5 19
Chemical Tanker 1 42 0 6.7 5.0 2.4 1
Gas Carrier 1 170 2.7 2.0 5.1 0.6 5
Passenger & HSC 0 6 0 0 0 0 0(0.2)
Total 137 3640(C) 2.7 4.4 5.0 3.8 100
Fig1.3.1 Percentage of NKSMC Ships sorted by Type of Ship（％）(2004)
Gas Carrier 5% Oil Tanker 20%Chemical Tanker 1%
Fig. 1.4.2 Percentage of ISM non-compliant ships sorted by Type of Ship
0
1
2
3
4
5
6
7
B u l k C a r r i e r O t h e r C a r g o O i l T a n k e r C h e m i c a l T a n k e r G a s C a r r i e r P a s s a n g e r & H S C
2 0 0 22 0 0 32 0 0 4
Fig 1.3.2 Percentage of ISM non-compliant ships sorted by Type of Ship
Percentage of ISM non-compliant ships (%)
B u lk C a r r i e r
G a s C a r r i e r
O i l T a n k e r
C h e m ic a l T a n k e r
O t h e r C a r g o
P a s s a n g e r & H S C
Passenger & HSC 0.2%
Other Cargo 42% Bulk Carrier 33%
Gas Carrier 5% Oil Tanker 19%Chemical Tanker 1%
6
1.4 ISM non-compliant ships sorted by Age of Ship The number of ISM non-compliant ships and their percentage of the total NKSMC ships, sorted by Age of Ships over the past four years are shown in Table 1.4.1 and Fig. 1.4.1. Tab.1.4.1. ISM non-compliant ships of NKSMC ships sorted by Age of Ship
ISM non-compliant ships(A) NKSMC Ships(B) Ship's Age 2001 2002 2003 2004 2001 2002 2003 2004
0 to 4 10 27 16 17 848 959 866 898
5 to 9 19 29 39 21 690 952 1039 1087
10 to 14 5 15 25 22 342 471 452 522
15 to 19 22 49 39 21 486 510 467 392
20 to 24 13 21 40 46 315 369 424 529
25 and more 6 10 13 10 121 186 186 212
Fig.1.4.1. Percentage of ISM non-compliant ships of NKSMC ships sorted by Age of Ship (%)
＊ Percentage = A/B x 100(%) In general, the higher the age of ship, the higher the percentage of ISM non-compliance, as we have seen in every year. In 2004, the percentage for ships of 10 years and above exceeded the average of the total and also for ships between the age of 20 and 24 years. Fig.1.4.2 shows the percentage of ISM non-compliant ships sorted by Age of Ships for three different types of ships. The percentage for “bulk carrier” increases rapidly if the age is over 15 years, and as for “other cargo ship” and “oil tanker”, these also increase between the age of 20 and 24 years.
Fig. 1.4.2 Percentage of ISM non-compliant ships sorted by Age of Ship
for three types of NKSMC ships
0
2
4
6
8
1 0
1 2
1 4
1 6
0 t o 4 5 t o 9 1 0 t o 1 4 1 5 t o 1 9 2 0 t o 2 4 2 5 a n d m o r e
O t h e r C a r g o
B u l k C a r r i e r
O i l T a n k e r
Percentage of ISM non-compliant ships (％)
Percentage of ISM non-compliant ships (%)
0
1
2
3
4
5
6
7
8
9
1 0
0 t o 4 5 t o 9 1 0 t o 1 4 1 5 t o 1 9 2 0 t o 2 4 2 5 a n d m o r e
2 0 0 1
2 0 0 2
2 0 0 3
2 0 0 4
7
1.5 ISM non-compliant ships sorted by Gross Tonnage The number of ISM non-compliant ships and their percentage of NKSMC ships sorted by Gross Tonnage is shown in Table 1.5.1 and Fig. 1.5.1. Tab.1.5.1 Number of ISM non-compliant ships sorted by Gross Tonnage
ISM Non-compliant ships(A) NKSMC ships(B) G/T (x 1000) 2001 2002 2003 2004 2001 2002 2003 2004
0 to 10 20 70 83 54 826 1239 1228 1264
10 to 20 14 26 42 36 677 763 716 731
20 to 30 16 31 13 15 362 396 426 474
30 to 40 8 8 15 11 335 383 366 402
40 to 50 4 5 6 8 209 221 235 251
50 to 60 0 3 0 5 97 108 119 140
60 to 80 10 1 4 6 88 107 102 115
80 and more 3 7 9 2 217 235 242 263
Fig.1.5.1 Percentage of ISM non-compliant NKSMC ships sorted by Gross Tonnage
for over past four years (%)
＊ Percentage = A/B x 100 (%)
In 2004, the percentage of ISM non-compliant ships increased in ships of 20,000 G/T and smaller and also for between 60,000 and 80,000 G/T, which exceeded the average percentage. Half of the ships not more than 20,000 G/T consisted of “other cargo ships”, and 5 ships among 6 ships between 60,000 and 80,000 G/T were “bulk carrier”, which would be ‘Panamax’ bulk carriers without cargo handling gear. This type of ships can be considered as easier maintenance and operation on board compared with ‘Handy’ bulk carrier with gear due to simple installation and equipment, therefore, the companies are requested to enhance their monitoring for shipboard maintenance.
G/T ( x 1000)
0
2
4
6
8
10
12
0 to 10 10 to 20 20 to 30 30 to 40 40 to 50 50 to 60 60 to 80 80 and more
2001200220032004
Percentage of ISM non-compliant ships(%)
8
1.6 Port States of ISM non-compliant ships The numbers of ISM non-compliant ships sorted by Port State and six regional areas of the world are shown in Table 1.6.1 and 1.6.2, and Figure 1.6.2. In comparison with the previous year, the numbers in Asia and Europe have been decreasing, but in Oceania have been increasing. The percentage of ships for respective areas in 2004 was almost same as 2002 year. Tab.1.6.1 Number of ISM non-compliant ships sorted into six regional areas and their percentage.
Percentage
(A／B) (%) Area
No. of ISM
non-compliant
ships (A) 2002 2003 2004
Asia 64 43 54 43
Europe 36 28 26 24
Oceania 28 15 9 18
North America 18 10 8 12
South America 3 2 2 2
Russia 1 2 1 1
Total 150（B） 100 (%) 100 (%) 100(%)
Fig.1.6.1 Percentage of ships sorted by area
Asia 43％ Europe 24%
0 5 1 0 1 5 2 0 2 5 3 0
C hile
P o rtug al
F ranc e
S ing ap o re
G e rm any
Ind ia
I taly
C anad a
K o re a
C hina
U.K .
Ne the rland
Ho ng K o ng
U.S .A .
A us tralia
J ap an
Country No. of non-compliant
Ships
Japan 30
Australia 27
U.S.A 12
Hong Kong 9
Netherlands 9
U.K. 8
China 8
Korea 8
Canada 6
Italy 6
India 5
Germany 4
Singapore 3
France 3
Portugal 2
Chile 2
Tab.1.6.2 Number of ISM non-compliant ships sorted in Port State (2004)
Fig.1.6.2 Number of ISM non-compliant ships sorted in Port States(2004)
Number of non-compliant ships
Asia 43 ％
Europe 24 ％
Oceania 18 ％
North America 12 ％
South America 2 ％
Russia 1％
9
The numbers of ISM non-compliant ships sorted by Port State over four years are shown in Table 1.6.3 and Figure 1.6.3. Total numbers of ISM non-compliant ships were drastically decreased compared with the previous year, and among those Port States, it was remarkably decreased in Japan and Hong Kong, and also showed a tendency towards decreasing in European countries. Tab.1.6.3 Number of ISM non-compliant ships sorted by Port State
Number of ISM non-compliant ships Port State 2001 2002 2003 2004
Japan 14 38 63 30
Australia 8 31 23 27
U.S.A 8 15 11 12
Hong Kong 1 23 39 9
Netherlands 13 21 11 9
U.K. 10 5 17 8
China 2 10 13 8
Korea 5 7 11 8
Italy 0 5 6 6
Canada 1 6 10 6
India 2 4 3 5
Germany 4 7 7 4
Singapore 2 5 3 3
France 1 3 3 3
Portugal 3 8 2 2
Chile 4 2 0 2
Belgium 2 3 11 1
Spain 1 2 1 1
Russia 0 3 1 1
Greece 1 1 1 1
Vietnam 0 0 2 1
Ireland 0 0 1 1
New Zealand 1 0 0 1
Colombia 0 0 0 1
Argentina 1 2 2 0
Brazil 1 0 3 0
Malta 0 1 1 0
Others 1 2 2 0
Total 86 204 249 150
10
Fig.1.6.3 Number of ISM non-compliant ships sorted by Port State
0 10 20 30 40 50 60 70
Poland
Malta
Brazil
Argentine
Colombia
New Zealand
Ireland
Vietnam
Greece
Russia
Spain
Belgium
Chile
Portugal
France
Singapore
Germany
India
Canada
Italy
Korea
China
U.K.
Netherland
Hong Kong
U.S.A.
Australia
Japan
2001
2002
2003
2004
11
Chapter 2 Analysis of deficiencies related to the ISM Code
2.1 ISM deficiencies classified by dominant cause During 2004, the total number of ISM deficiencies reported for all 150 ISM non-compliant ships was 250 items as shown in Table 2.1.1. The average number of deficiencies per ship was 1.67/ship, which was a decrease from 2003 as shown in Fig. 2.1.1. Tab.2.1.1 Number of ISM deficiencies of ISM non-compliant ships
Numbers of ISM deficiencies in 2004 sorted by ISM Code sections are shown in Table 2.1.2 and Figure 2.1.2
0
0.5
1
1.5
2
2.5
2001 2002 2003 2004
Year
No. of
deficiency
(A)
Ships
(B)
Rate
(A/B)
2001 132 86 1.53
2002 350 204 1.71
2003 491 249 1.97
2004 250 150 1.67 Fig. 2.1.1 Number of ISM deficiencies
per ship
0 25 50 75 100
Certification 13.
Company Review 12.
Documentation 11.
Maintenance 10.
Non-conformity 9.
EmergencyPreparedness 8.
Shipboard Operation7.
Resources andPersonnel 6.
Master'sResponsibility 5.
Designated Person 4.
CompanyResponsibilities 3.
Safety Policy 2.
General 1.
ISM Code section No of ISM
deficiencies
1.General 2
2.Safety Policy 18
3.Company Responsibilities 8
4.Designated Person 0
5.Master's Responsibility 8
6.Resources and Personnel 29
7.Shipboard Operation 24
8.Emergency Preparedness 37
9.Non-conformity 9
10.Maintenance 88
11.Documentation 16
12.Company Review 9
13.Certification 2
Total 250
Tab.2.1.2 Number of ISM deficiencies sorted by ISM Code section（2004）
Fig. 2.1.2 Number of ISM deficiencies sorted by ISM Code section
Number of ISM deficiencies
(%)
12
2.2 Number of ISM deficiencies sorted by section of the ISM Code for the past four years
The number of ISM deficiencies sorted by ISM Code section for the past four years is shown in the following Tables 2.2.1 and Figures 2.2.1. Tab.2.2.1 Number of ISM deficiencies sorted by ISM Code section for the past four years
ISM Code section Year
1 2 3 4 5 6 7 8 9 10 11 12 13 Total 2001 5 0 1 0 10 16 18 27 4 28 19 2 2 132
2002 6 9 1 3 20 53 37 46 18 101 31 10 15 350
2003 1 8 12 1 24 60 45 96 23 159 43 13 6 491
2004 2 18 8 0 8 29 24 37 9 88 16 9 2 250
In general, despite the drastic decrease in the total number of ISM deficiencies to a half of the previous year, deficiencies relating to Section 2 “Safety and Environmental Protection Policy” increased drastically, which, resulted from Canadian PSC conducting a concentrated inspection campaign on ‘Enclosed space entry procedure’, checking gas detectors, O2 meters, etc. onboard, and pointing out 11 of deficiencies as Section 2. As for Section 10 “Maintenance”, Section 3 “Company Responsibilities” and Section 12 “Company Review”, the number of deficiencies decreased, but their percentage for respective Sections shows a tendency towards increasing. On the other hand, both number and percentage for Section 5 “Master’s Responsibility”, Section 8 “Emergency Preparedness’, Section 9 “Non-conformity” and Section
Fig.2.2.1 Number of ISM deficiencies sorted by ISM Code section for the past four years
0 20 40 60 80 100 120 140 160
Certification 13.
Company Review 12.
Documentation 11.
Maintenance 10.
Non-conformity 9.
Emergency Preparedness 8.
Shipboard Operation 7.
Resources and Personnel 6.
Master's Responsibility 5.
Designated Person 4.
Company Responsibilities 3.
Safety Policy 2.
General １.
2001
2002
2003
2004
Number of ISM deficiencies
13
11 “Documentation” were decreasing. As for Section 10 “Maintenance”, it occupied 35% of the total number of deficiencies and maintained a high percentage of deficiencies. During PSC inspection the matters relating to maintenance of the ship and equipment are addressed with greatest care and their deficiencies are comparatively easy to find. As the number of these deficiencies pointed out increases, the company and ship should be advised of their insufficient control over the maintenance system of SMS, which is further pointed out as ISM-related deficiencies. Therefore, the companies are requested to enhance monitoring of the appropriate ship’s maintenance plan and its proper implementation onboard. 2.3 Number of ISM deficiencies sorted by the States of PSC The number of ISM deficiencies pointed out by respective Port States is shown in Table 2.3.1 and Figure 2.3.1. A feature of 2004 is a decrease by 0.51 over the previous year. Particularly in the Tokyo MOU, a remarkable decrease in the number from the previous year was noted in Japan (107 to 54), Hong Kong (93 to 16), China (25 to 8) and Korea (22 to 11). Also in the Paris MOU, it was also noted in the U.K. (38 to 12), and Belgium (38 to 4). In the meantime, in U.S.A. it decreased back to the level of 2001. These results can be considered as good management for “other cargo ship” being implemented and executed effectively in accordance with the ISM Code in the two years from the effective date of Phase II. Tab.2.3.1 Number of ISM deficiencies sorted by the State of PSC (2001-2004)
Port State 2001 2002 2003 2004 Japan 23 77 107 54
Australia 16 37 31 38
Canada 1 8 20 20
Hong Kong 2 59 93 16
Netherlands 16 31 20 16
Italy 0 9 14 15
U.S.A. 13 25 24 13
U.K. 17 9 38 12
Germany 6 10 11 11
Korea 7 7 22 11
China 3 15 26 8
India 4 5 5 6
Singapore 2 6 5 5
Chile 4 2 0 5
France 1 6 9 4
Belgium 4 5 38 4
Portugal 6 22 2 2
Greece 2 1 4 2
Ireland - - - 2
Colombia - - - 2
Spain 1 2 1 1
Russian 0 6 1 1
Vietnam 0 0 3 1
New Zealand - - - 1
Other 4 8 18 0
Total 132 350 491 250
14
0 20 40 60 80 100 120
Other
New Zealand
Vietnam
Russian
Spain
Colombia
Ireland
Greece
Portugal
Belgium
France
Chile
Singapore
India
China
Korea
Germany
U.K.
U.S.A
Italy
Netherland
Hong Kong
Canada
Australia
Japan
2001
2002
2003
2004
Fig. 2.3.1 Number of ISM deficiencies sorted by the State of PSC(2001-2004)
Number of ISM deficiencies
15
2.4 Particulars of deficiencies sorted by PSC The number of ISM deficiencies sorted by their ISM Code sections, and the number identified that caused the detention of ship (Action Code 30) sorted also by the ISM Code sections in eight port States are shown in Table 2.4. These eight States are Japan, Australia, Canada, Hong Kong, Netherlands, U.S.A., Germany and Korea, which identified a greater number of ISM deficiencies than other States. Actual examples of statements of PSC pointing out the deficiencies that caused the detention of ships are also shown under each State. Tab. 2.4. No. of ISM deficiencies sorted by the ISM Code section for each PSC
ISM Code section PSC
1 2 3 4 5 6 7 8 9 10 11 12 13 TotalISM Deficiencies
1 6 7 5 3 26 3 2 1 54Japan Ship detained 1 1 1 1 1 1 6 ISM Deficiencies
3 6 6 18 2 3 38Australia Ship detained 1 1 7 9 ISM Deficiencies
11 1 4 4 20Canada Ship detained 2 1 3 ISM Deficiencies
1 7 1 5 2 16Hong Kong Ship detained 7 1 4 12ISM Deficiencies
1 3 1 2 2 2 4 1 16Netherlands Ship detained 1 2 3 ISM Deficiencies
1 1 1 2 4 1 2 1 13U.S.A. Ship detained 1 1 3 1 1 1 8 ISM Deficiencies
2 3 3 3 11Germany Ship detained 1 1 1 3 ISM Deficiencies
1 3 2 1 3 1 11Korea Ship detained 1 1 1 3 ISM Deficiencies
3 2 2 11 5 13 2 24 6 2 1 71Other Ship detained 1 3 3 1 8 ISM Deficiencies
2 18 8 8 29 24 37 9 88 16 9 2 250Total Ship detained 1 4 2 2 8 1 7 4 20 2 3 1 55
＊ ISM Deficiencies: Total number of ISM deficiencies pointed out by the PSC officer Ship detained : Total number of ISM deficiencies pointed out by the PSC officer with Action Code 30
16
2.4.1 JAPAN
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Total
Ship detained 0 0 0 0 0 1 1 0 1 1 0 1 1 6 ISM Deficiencies 0 0 1 0 0 6 7 5 3 26 3 2 1 54
Fig. 2.4.1 ISM Deficiencies that caused ship’s detention, sorted by ISM Code section
ISM Code
section
Action
Code Deficiencies
6 30 Application for endorsement of Captain and C/O not held. GMDSS application for endorsement of
Captain not held
７ 30 Procedures for watch keeping in restricted visibility condition – not understood by duty officer.
9 30 Report of non-conformities with regard to Program for drills/exercises to the company – not
reported.
10 30 Procedure for maintenance – not implemented enough and not understood.
12 30 Internal audits – not carried out within the required interval.
13 30 Safety Management Certificate – not valid (ex. Ship’s name)
2.4.2 Hong Kong
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Tota
l Ship detained 0 0 0 0 0 7 0 1 0 4 0 0 0 12
ISM deficiencies 0 0 0 0 1 7 0 1 0 5 2 0 0 16
Fig. 2.4.2 ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section
0
5
1 0
1 5
2 0
2 5
3 0
1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3
S h i p s d e t a i n e d
I S M d e f i c i e n c i e s
ISM Code section
0
2
4
6
8
1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3
S h i p d e t a i n e d
I S M d e f i c i e n c i e s
ISM Code sections
17
ISM Code
section
Action
Code Deficiencies
6 30 Medical certificates of Master, 2/O and other 3 crew members expired.
6 30 Medical certificate for C/E expired..
6 30 Operation and risk in operating the fixed CO2 fire-extinguishing system not familiar and no
identified.
6 30 All crew without medical certificates for fit for working as seafarer as required by ILO.
6 30 Non-conformity on ISM resources and personnel. (GMDSS officer not familiar with test of
equipment/false distress alert cancellation procedures.
6 30 Oiler, Mr.Win found without medical fitness certificate.
6 30 Officer did not know how to cancel false distress signal.
8 30 Insufficient equipment was maintained for oil spill emergency and there was no regular check for
its minimum quantity.
10 30 Following deficiencies resulted in being detained (1.E/R door frame cut away, left open all time and
lock handle broken 2.Em.Fire Pump not delivery pressure 3.Cargo hold’s ventilators not able to
be closed 4.Lifeboat and inventory found in poor condition)
10 30 Pressure test of 40 CO2 bottles (50% of total) plus 2 pilot cylinders overdue.
10 30 Non-conformity on ISM maintenance of ship and equipment (Installation of jacketed piping
system/dynamic load test of survival craft/Chart/ITU publications/weekly test of HF
GMDSS/etc.).
10 30 The ship failed to be maintained in conformity with provisions of relevant rules and regulations.
(Numerous deficiencies related to LL, SE, SC were found during the course of PSC inspection.)
2.4.3 Canada
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Tota
l Ship detained 0 2 0 0 0 0 0 1 0 0 0 0 0 3
ISM Deficiencies 0 11 0 0 0 0 1 4 0 4 0 0 0 20
Fig. 2.4.3 ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section
ISM Code
section Action Code Deficiencies
2 30 Enclosed space entry procedures could not be found for 90 minutes.
2 30 Operating procedure manual requires testing for oxygen, hydro carbon and toxic gases, but
no toxic gas detector and no test gas available on board.
8 30 Crew not familiar with abandon ship procedure. (Crew abandon ship drill not satisfactory.)
0
3
6
9
12
1 2 3 4 5 6 7 8 9 10 11 12 13
Sh ip deta ined
ISM defic ienc ies
ISM Code section
18
2.4.4 Netherlands
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Total
Ship detained 0 0 0 0 1 0 0 0 0 2 0 0 0 3 ISM deficiencies 1 3 0 0 1 2 2 2 0 4 1 0 0 16
Fig. 2.4.4 ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section
ISM Code
section
Action
Code Deficiencies
5 30 Ballast tank entry not according to the company’s procedure. Enclosed space entry permit filled
in & signed but not reflecting actual situation.
10 30 Maintenance of ship and equipment not according to SMS. (Many deficiencies for poor
maintenance were found by PSC.)
10 30 Maintenance of ship and equipment not according to SMS. (Records of safety equipment
checklist have discrepancies with actual condition pointed out by PSC.)
2.4.5 Australia.
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Total
Ship detained 0 0 1 0 0 0 0 1 0 7 0 0 0 9 ISM deficiencies 0 0 3 0 0 0 6 6 0 18 2 3 0 38
Fig. 2.4.5. ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section
0
1
2
3
4
5
1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3
S h i p d e t a i n e d
I S M d e f i c i e n c i e s
ISM Code section
0
4
8
1 2
1 6
2 0
1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3
S h ip de ta ined
IS M de fic ienc ies
ISM Code section
19
ISM Code
section
Action
Code Deficiencies
3 30 Company ISM procedures not working. (1.Essential spare parts not supplied on board after
request by Master. 2.Oil pollution equipment defective.)
8 30 The safety management system does not ensure that fire dampers, life boat equipment and life
boats are ready for emergency use.
10 30 The safeｔy management system does not ensure that satisfactory maintenance is carried out on
fire dampers, life boat equipment and life boats.
10 30 ISM system on board failed to ensure maintenance of ship and equipment as evidenced by
deficiencies pointed out for fire damper flap, high pressure jacketed F.O. piping of M/E, etc.
10 30 Evidence exist that the management system on board the ship has not ensured that proper
maintenance and inspection of the hatch covers has been performed.
10 30 The SMS failed to ensure the correct maintenance of ship and equipment due to following
deficiencies: 1.Fixed firefighting foam installation is not operational. 2.Numerous access hatch
covers to the cargo holds are corroded, rubber packing is badly deteriorated.
10 30 Maintenance of the ship and equipment is not in accordance with the ISM code evidenced by
following deficiencies: 1.Several ballast tank air pipes defective. 2.Unable to start em.fire pump
within required time 3.Several jacketed high pressure F.O.line steaming end fitting broken.
4.E/R oil storage tank level indicator made from PVC and self closing valves secured open
5.E/R fire damper wasted/missing.
10 30 ISM system on board ship does not ensure that the ship complies with relevant conventions and
ready availability of safety equipment. (The ship detained last year due to similar operational
deficiency.)
10 30 ISM system is not effective in ensuring that critical safety equipment is maintained in
accordance with ISM code sect.10, as evidenced by following deficiency: Port & Starboard E/R
ventilation trunks excessively wasted through downstream of fire flaps.
2.4.6 U.S.A.
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Total
Ship detained 0 1 0 0 1 0 0 0 3 1 1 1 0 8 ISM Deficiencies 0 1 0 0 1 0 1 2 4 1 2 1 0 13
Fig. 2.4.6 ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section
0
1
2
3
4
5
1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3
S h ip d e ta in e d
IS M d e f ic ie n c ie s
ISM Code section
20
ISM Code
section
Action
Code Deficiencies
2 30 Taking into consideration the inability to respond to an emergency situation (loss of power in
channel) due to overall lack of maintenance regarding the ship fuel system and operation.
(Additional audit conducted.)
5 30 The master failed to follow the company’s drug and alcohol policy. (The master of the ship was
found intoxicated due to blood alcohol level exceeds the company’s DA policy. The company
was required to provide a properly certified master to the ship prior to movement. Additional
audit conducted.)
9 30 Objective evidence was noted that the master failed to follow the company’s drug and alcohol
policy. (The master’s blood alcohol level exceeds 0.04%. The company is required to provide a
proper certificate master to the ship prior to movement. Additional audit conducted.)
9 30 Ship was aware of holed davit on 13 July 2004 but failed to record or report to the company
via ISM system. (Additional audit conducted.)
9 30 Due to discrepancies found in ISM certificate is in question. (Grounds for deficiency: Although
there were many temporary repairs on the piping in E/R, the crew could not show any reports
which were to be informed to the company.)
10 30 ISM ineffective in documenting deficiencies onboard. (Grounds for detention: Total 22 technical
deficiencies were found.)
11 30 In log books missing pre-arrival tests and found discrepancies with radar log book in relation to
damaged radar, which combined with other deficiencies provides objective evidence that the
ship’s SMS is not fully implemented or not functioning. (Additional audit requested.)
12 30 Crew unfamiliar with company’s SMS. (Full scope ISM audit was conducted.)
-1.Repair and proper operation of stbd.Lifeboat. 2.Life rafts are to be installed in a float free
3.Provide class attest to low press. of CO2 system and ventilation system in E/R. 4.Repair
inoperable secondary radar.
2.4.7 Germany
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Total
Ship detained 0 0 1 0 0 0 0 1 0 1 0 0 0 3 ISM deficiencies 0 0 2 0 3 0 0 3 0 3 0 0 0 11
Fig. 2.4.7 ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section
ISM Code
section
Action
Code Deficiencies
3 30 The company has not ensured that the safety policy is fully implemented.
8 30 Corrective action for non-conformities from 10.02.04 insufficient regarding emergency fire
pump.
10 30 Maintenance of ship and equipment – incomplete (1.Quick closing valve not working.
2.Emergency fire pump not ready for use.)
ISM Code section
0
1
2
3
4
5
1 2 3 4 5 6 7 8 9 1 0 1 1 1 2 1 3
S h ip d e t a in e d
I S M d e f i c i e n c ie s
21
2.4.8 Republic of Korea
ISM Code section
1 2 3 4 5 6 7 8 9 10 11 12 13 Total
Ship detained 1 0 0 0 0 0 0 0 0 1 0 1 0 3 ISM deficiencies 1 0 0 0 0 3 2 1 0 3 0 1 0 11
Fig. 2.4.8 ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section
ISM Code
section
Action
Code Deficiencies
1 30 SMS does not work properly.
10 30 EM log not working since March 2003.
12 30 ISM internal audit not carried out since 4 June 2002.
0
1
2
3
4
5
1 2 3 4 5 6 7 8 9 10 11 12 13
Ship detained
ISM deficiencies
ISM Code section
22
Chapter 3. ISM deficiencies and Action Codes 3.1 ISM deficiencies and Action Codes For all 250 ISM deficiency items, analyses were undertaken to sort them by their ISM Code sections in the vertical column, and by the Action Code on the horizontal line, as shown in Table 3.1.1. 55 items (22% of all deficiency items) were related to detention of the ship (Action Code 30). This number was 0.38 times the number of 2003 where it was 146 detentions. 28 items (11%) required correction of the defect before departure of the ship (Action Code 17), 104 items (42%) required correction within 3 months (Action Code 18), and 16 items (6%) required correction within 14 days (Action Code 16). The aggregate percentage of the above was 81% of the all deficiency items. Many items relating to Action Code 18 were pointed out regarding “Maintenance”, “Emergency preparedness” and “Shipboard operation” as the functional deficiencies of key elements of the SMS, and the companies are required to carry out the investigation and analysis of the root cause, and establish measures to prevent recurrence including proper education and training. (Respective ‘Action Code’ is correspondent to that of Paris and Tokyo MOU except for 20 which is correspondent to USCG.) Table 3.1.1 ISM deficiencies arranged by matrix of Action Code and ISM Code section
Action Code 0 10 15 16 17 18 19 20 30 50 55 70 99ISM Code
section No. of ISM
deficienciesNo
action Rectified
Next
port 14 days
Before
departure
3
month
Rectify
MNC
Ship
expelled
Detain-
ed
Flag
informd
Flag
consult
Class
informd Other
1.General 2 1 1
2. Policy 18 3 6 4 4 1
3.Company 8 2 3 1 2
4. DP 0
5. Master 8 1 1 1 3 2
6. Resources 29 1 1 1 7 9 2 8
7. Operation 24 1 1 4 13 1 1 3
8.Emergency 37 1 2 5 14 7 7 1
9. NC Report 9 3 1 4 1
10. Maintenance 88 3 6 42 9 20 1 1 6
11.Documentation 16 4 2 7 2 1
12. Review 9 1 5 3
13. Certification 2 1 1
Total(2004) 250 0 1 3 16 28 104 27 1 55 1 2 1 11
Total(2003) 491 1 0 0 22 75 173 41 1 146 1 0 1 30
Fig. 3.1.1 Number of ISM deficiencies sorted by Action Code (2003,2004)
Action Code 0
2 0
4 0
6 0
8 0
1 0 0
1 2 0
1 4 0
1 6 0
1 8 0
0 1 0 1 5 1 6 1 7 1 8 1 9 2 0 3 0 5 0 5 5 7 0
2 0 0 3
2 0 0 4
Number of ISM
deficiencies
Action Code
23
3.2 Action Codes sorted by section of the ISM Code The patterns of Action Codes has been analyzed by the respective section of the ISM Code. Section numbers selected from the ISM Code are 10 "Maintenance of the Ship and Equipment”, 8 " Emergency Preparedness”, 6 "Resources and Personnel”, 7 "Development of Plans for Shipboard Operations”, and 11 "Documentation” 3.2.1 ISM Code section 10“Maintenance of the ship and equipment”
Action Code
0 10 15 16 17 18 19 30 50 55 70 99 Total
2003 1 3 17 72 13 45 8 159Number of ISM
deficiencies 2004 3 6 42 9 20 1 1 6 88
The number of deficiencies relating to ISM Code Section 10 was 0.55 times that of the previous year. Although it showed a decrease to around a half of the previous year, the percentage of the total numbers increased. PSC usually require ‘a correction within 3 months’ (Action code 18: 42), or ‘detain the ship’ (Action code 30: 20). In most cases, poor maintenance of the hardware such as fire fighting equipment, life saving appliances, bilge separator and closing appliances which are required by the relevant Conventions are pointed out, and then improper systems for the maintenance plan and its implementation are pointed out as ISM related deficiencies. It is also noted that ‘no entry or no correct entry to maintenance record compared with actual maintenance condition’ are made. Therefore, the companies are requested to conduct proper education and training and also undertake closer monitoring of ship’s maintenance on board particularly for safety equipment, as this tendency still remains unaltered. Most of ISM-related deficiencies resulting in ‘detention’ ordered by PSC inspectors are derived from non-compliance with the relevant regulations of the International Conventions or Flag State, or observation of a great deal of deficiency items for ship’s maintenance. (In Australia, ships were frequently detained due to inoperative ‘Fire dampers’ or ‘Life boats’.) 3.2.2 ISM Code section 8 “Emergency preparedness”
Action Code
0 10 15 16 17 18 19 30 50 70 99 Total
2003 7 14 29 11 32 3 96 Number of ISM
deficiencies 2004 1 2 5 14 7 7 1 37
0
20
40
60
80
0 10 15 16 17 18 19 30 50 55 70 99
2003
2004Number of ISM deficiencies
0
5
10
15
20
25
30
35
0 10 15 16 17 18 19 30 50 70 99
2003
2004Number of ISM deficiencies
24
In 2004, ISM Code 8 deficiencies were drastically decreased at 0.40 times those of the previous year, and also the percentage among the total numbers of deficiencies decreased. Although the percentage of ‘detention’ (Action code 30) was drastically decreased. Action codes 18 and 19 increased respectively. Most ship’s detentions are due to insufficient executions of drills at the required interval and lack of familiarization with fire fighting and life saving drills. Deficiencies of ‘inoperative fire dampers’, ‘insufficient pressure of self contained breathing appliance’, ‘inoperative shut down valve for F.O.’ and insufficient training records were also pointed out as a lack of emergency preparedness. Other deficiencies of ISM Code 8 such as ‘no execution for emergency steering gears drills’, ‘no checking for emergency battery’ were pointed out in relation to Code 10 and 6. In this respect, companies are requested to enhance monitoring and instructions (frequent attendance and proper reporting) to the ship to ensure more effective training and education (OJT) for ship’s crew to prepare emergency situations including proper maintenance of the relevant equipment. Also companies should pay attention to shipboard drills in order to prevent the detention of the ship due to the above reasons. 3.2.3 ISM Code section 6“Resources and personnel”
Action Code
0 10 15 16 17 18 19 30 70 99 Total
2003 2 8 19 4 21 5 60 Number of ISM
deficiencies 2004 1 1 1 7 9 2 8 29
Deficiencies relating to training and qualification of the crew and its certifications and endorsements required by STCW are often pointed out, and in cases where the application for the endorsements of several certifications, etc. particularly for GMDSS certification are not available on board, these are also pointed out as violations of ISM Code 6., and also insufficient execution of handling the equipment onboard and unsatisfactory results of the drills on board due to insufficient familiarization and education on board (OJT) are pointed out, (For example, GMDSS officer may not be familiar with the correct operation for releasing distress signals.) In the meantime, in some particular areas, it was ordered to detain the ships due to the expiry of crew’s medical certificates. Therefore, companies are requested to enhance the education and training on the SMS for the crew and undertake close monitoring for the control of licenses and certification for their crews. 3.2.4 ISM Code section 7“Development of plans for shipboard operation”
Action Code
0 10 15 16 17 18 19 30 50 70 99 Total
2003 1 10 18 3 6 1 6 45 Number of ISM
deficiencies 2004 1 1 4 13 1 1 3 24
Number of ISM
deficiencies
Action Code0
5
10
15
20
25
0 10 15 16 17 18 19 30 70 99
2003
2004
25
In 2004, insufficient ‘Chart Corrections’ or ‘Old Nautical Publications’, insufficient description for ‘Oil record book’ and ‘Garbage management book’, insufficient records for the calibration of several gas detectors, etc., insufficient ‘Voyage plan’ not complying with the relevant requirements in SOLAS were pointed out as ISM Code 7 violations. In some areas, it was pointed out that ‘Initial setting of AIS prior to departure’ was not incorporated into ‘Departure Checklist’. PSC inspectors pointed out safety awareness for cargo handling operation in addition to the safety of navigation for execution of shipboard operation. Therefore, it is necessary for the companies to pay attention to proper implementation and records of shipboard operations by close monitoring, checking and attending ships at a regular interval, and also reviewing and investigating ship’s reports. 3.2.5 ISM Code section 11 “Documentation”
Action Code
0 10 15 16 17 18 19 30 50 70 99 Total
2003 4 12 13 3 9 1 1 43 Number of ISM
deficiencies 2004 4 2 7 2 1 16
Ships are seldom detained due to deficiencies of documentation, but, in cases that ‘no entry to ship’s log book was found for the description of “Test of equipment prior to entering port”, or ‘discrepancy of the description was observed between deck log book and radar log book’, the ship was detained. Other deficiencies such as ‘No correction was made to garbage management plan in accordance with the amendments of MARPOL’ or ‘Insufficient document controls for filing and replacing the relevant pages of manual’ were pointed out. These deficiencies should be corrected by the frequent attendance of the company’s superintendents or staff.
Action Code
0
4
8
12
16
20
0 10 15 16 17 18 19 30 50 70 99
2003
2004Number of ISM deficiencies
0
3
6
9
12
15
0 10 15 16 17 18 19 30 50 70 99
2003
2004
Number of ISM deficiencies
26
Chapter 4 Companies managing the ISM Non-compliant ships With regard to those companies managing ships that have ISM non-compliant deficiencies, analysis was undertaken regarding the number of ships under their management and the duration of years of SMS operation (counting from the year when the company registered their ISM operation with ClassNK). 4.1 Management companies and number of ships Table 4.1.1 shows the relation between the number of ISM non-compliant ships and number of ships under management sorted by eight different sizes of companies which have been grouped by the number of ships under their management. For those with 1 to 5 ships, a detailed breakdown is shown. For each group, the percentage of ISM non-compliant ships was calculated. As a result, we can see that percentage of non-compliant ships for the 1-10 group, the 16-20 group and the 31-40 group exceed the average. The total number of 137 ISM non-compliant ships belong to 104 companies of which 80 companies hold DOC issued by ClassNK. 23 companies had more than one ISM non-compliant ships, and the worst companies (3 companies) had 4 ships. Table 4.1.1 Number of ISM non-compliant ships and size of company
No. of ships
managed
No. of
Managing
companies
No. of ISM
non-compliant
NKSMC ships
(A)
NO. of NKSMC
ships
(B)
Percentage (%)
(A/B)
1 134 10 134 7.5
2 85 11 170 6.5
3 59 7 177 4.0
4 50 3 200 1.5
5 31 9 155 5.8
1～5 359 40 836 4.8
6～10 103 40 784 5.1
11～15 42 15 540 2.8
16～20 10 8 176 4.5
21～30 20 13 500 2.6
31～40 8 13 275 4.7
41～50 4 3 178 1.7
50 over 6 5 351 1.4
Total 552 137 3640 3.8
Fig. 4.1.1Percentage of ISM non-compliant ships sorted by size of companies (%)
0
1
2
3
4
5
6
7
8
1 2 3 4 5 1 ～ 5 6 ～ 1 0 1 1 ～ 1 5 1 6 ～ 2 0 2 1 ～ 3 0 3 1 ～ 4 0 4 1 ～ 5 0 O v e r 5 0
Percentage of ISM non-compliant ships (％)
27
4.2 Management company and years of ISM system operation In Table 4.2.1 the calendar years are arranged vertically, and number of companies to which DOCs were issued by ClassNK (NKDOC companies) is listed corresponding to the year (when the company registered the ISM operation with ClassNK). For each year the number of ISM non-compliant ships and the number of ships managed by respective companies are listed, and percentage of ISM non-compliant ships was calculated. In general, it can be seen that generally in terms of the percentage of ISM non-compliant ships, the older the registration of the company, the lower the percentage, and in 2004, the percentage of ISM non-compliant ships for companies registered to ClassNK from 1999 to 2003 improved drastically, which was probably due to the familiarization and improvement of management jobs for “other cargo ships” (Phase II) which became registered in 2001 and 2002. Table 4.2.1 Year of ISM Register of Companies and Non-compliant Ships
Year
No. of NKDOC
company
No. of ISM
non-compliant
ships(A)
No. of NKSMC
ships (B)
Percentage (%)
A/B
1994 4 0 52 0
1995 28 12 601 2.0
1996 59 18 672 2.7
1997 99 27 684 3.9
1998 75 23 403 5.7
1999 20 5 160 3.1
2000 15 2 69 2.9
2001 37 3 157 1.9
2002 57 8 275 2.9
2003 27 3 108 2.8
2004 12 2 33 6.1
Total 433 103 3214 3.2
Fig. 4.2.1 Year of ISM Register of Companies and Percentage of ISM non-compliant ships
0
1
2
3
4
5
6
7
1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
Percentage of ISM non-compliant ships (％)
Year of ISM register
28
4.3 Nationalities of companies managing ISM non-compliant ships Table 4.3.1 shows the list of nationalities to which the companies that are managing the ISM non-compliant ships have registered. For each nationality, the percentage of ISM non-compliant ships was calculated against the total number of NKSMC ships. In 2004, the percentage of ISM non-compliant ships in China improved 37% over the previous year, and Taiwan decreased to a half of the previous year. As for Greece, Turkey and Philippines, they improved but still remained above of the average. Japan improved drastically. On the other hand, Singapore and Hong Kong worsened. (the percentage for St.Vincent Flag ships increased drastically, where the management companies belong to China and Greece.)
Table 4.3.1 Nationality of companies managing ISM non-compliant ships
Nationality
No. of NKDOC
Company No. of NKDOC
non-compliant
ships (A)
No. of NKSMC ships
(B)
Percentage
(A/B)
(％)
China 28 8 59 13.6
Greece 73 17 267 6.4
Taiwan 15 6 116 5.2
Philippines 15 6 132 4.5
Turkey 25 5 114 4.4
Singapore 51 22 530 4.2
Hong Kong 22 8 226 3.5
Malaysia 18 3 94 3.2
Japan 229 48 1711 2.8
Others 76 14 391 3.6
Fig. 4.3.1. Percentage of ISM non-compliant ships sorted by the Nationalities(%) ＊This data includes only those nationalities which have 15 or more NKDOC companies.
0
2
4
6
8
10
12
14
China Greece Taiwan Philip ines Turkey S ingapore Hong Kong Malaysia Japan
Percentage of ISM non-compliant ships(%)
29
Chapter 5 Analysis of ISM Non-compliant Ships based on Open Information 5.1 General This Chapter shows the results of analyses on actions taken by various PSCs for ISM non-compliance by NKSMC ships, based on the data collected from open information revealed on the web sites of the Tokyo MOU, Paris MOU and USCG. Until 2003, these data were collected from the detention lists of the respective data bases of the MOUs, but this time, we collected all ISM non-compliance data for respective NKSMC ships from the respective data bases of the MOUs through “Equasis”, and then investigated the ISM-related deficiencies pointed out by PSCs. Therefore, this data also included ISM non-compliant ship without detention, which was very different in numbers compared to the statistical results in Chapters 1 through 4. Also, open information in respective MOUs does not contain the details of deficiencies including applicable ISM Code and Action Code, etc., therefore, this analysis mainly applies to the raw numbers of ISM non-compliant ship (NKSMC) in line with Chapter 1 (sorted by ‘Flag State’, ‘Type of Ship’, ‘Age of Ship’, ‘Gross Tonnage’ and ‘Port State’ wise) and 4 (Nationalities of companies managing ISM non-compliant ships) The number of ISM non-compliant ships pointed out in the above three areas during the year of 2004 amounted to 585 ships, which is 16.1% of all NKSMC ships (3640).
5.2 ISM non-compliant ships sorted by Flag States The number and percentage of ISM non-compliant ships sorted by Flag State are shown in Table 5.2 and Figure 5.2. Tab.5.2 ISM non-compliant ships sorted by Flag State
Flag State
No. of ISM non-compliant
NKSMC ships (A)
No. of NKSMC All Ships (B)
Percentage of ISM non-compliant ships (A/B %)
Cyprus 28 92 30.4
St. Vincent 9 37 24.3
Hong Kong 51 219 23.3
Bahamas 11 61 18.0
Panama 342 1954 17.5
Thailand 15 86 17.4
Turkey 11 64 17.2
Philippines 15 90 16.7
Malaysia 12 75 16.0
Liberia 23 169 13.6
Malta 17 142 12.0
Japan 10 144 6.9
Singapore 24 391 6.1
Others 17 116 14.7
Total 585 3640 16.1
30
Fig.5.2 Percentage of ISM non-compliant ships sorted by Flag State 5.3 ISM non-compliant ships sorted by Type of Ship The percentage of ISM non-compliant ships for NKSMC ships in 2004 sorted by various type of ship are shown in Table 5.3. “Bulk carrier” was the worst in both the percentage and the numbers of ships. Comparing Phase I and Phase II respectively, they were almost the same percentage at 16%. Tab.5.3 ISM non-compliant ships sorted by Type of Ship
Type of Ships
No. of ISM non-compliant
NKSMC ships (A)
No. of NKSMC All Ships (B)
Percentage of ISM non-compliant ships
(A/B %) Bulk Carrier 250 1196 20.9 Chemical Tanker 8 42 19.0 Passenger & HSC 1 6 16.7 Other Cargo Ship 243 1517 16.0 Oil Tanker 68 709 9.6 Gas Carrier 15 170 8.8
Total 585 3640 16.1 5.4 ISM non-compliant ships sorted by Age of Ship The percentage of ISM non-compliant ships for NKSMC ships in 2004 sorted by age of ship are shown in Table 5.4. Percentage for ships not more than 4 years old and not less than 25 years old was not exceeding the average.
Percentage of ISM
non-compliant ships(%)
0
5
10
15
20
25
30
35
Cyp
uru
s
St.V
incent
Hong
Kong
Bah
ama
Pan
ama
Thaila
nd
Turk
ey
Phili
ppin
es
Mal
aysi
a
Lib
eria
Mal
ta
Japan
Sin
gapore
Oth
ers
31
Tab.5.4 ISM non-compliant ships sorted by Age of Ship Ship’s Age
No. of ISM non-compliant
NKSMC ships (A)
No. of NKSMC All Ships (B)
Percentage of ISM non-compliant ships
(A/B %) 0 to 4 119 898 13.3 5 to 9 179 1087 16.5
10 to 14 92 522 17.6 15 to 19 82 392 20.9 20 to 24 90 529 17.0
25 and more 23 212 10.8 Total 585 3640 16.1
The percentage of ISM non-compliant ships for “bulk carrier”, “oil tanker” and “other cargo ship” in 2004 sorted by type and age of ship are shown in Fig.5.4. of the peak age point for percentage was different for each type of ship respectively. The percentage for “Bulk carrier” of age from 15 years up to 19 years was 34.3%, which means that one in three bulk carriers was found with ISM-related deficiencies. Recognized organizations and companies should pay attention to this fact.
Fig. 5.4 Percentage of ISM non-compliant ships sorted by Age of Ship for respective Type of Ship 5.5 ISM non-compliant ships sorted by Gross Tonnage
The percentage of ISM non-compliant ships for NKSMC ships in 2004 sorted by gross tonnage are shown in Table 5.5. The percentage increased for ships of 20,000 G/T and smaller and exceeded the average. Particularly, the percentage for “bulk carrier” not more than 20,000 G/T (27.2%) is much higher than that for “other cargo ship” in same size (18.5%). Tab 5.5 ISM non-compliant ships sorted by Gross Tonnage
G/T (x 1,000)
No. of ISM non-compliant
NKSMC ships (A)
No. of NKSMC All Ships (B)
Percentage of ISM non-compliant ships
(A/B %) 0 to 10 218 1264 17.2
10 to 20 149 731 20.4 20 to 30 61 474 12.9 30 to 40 61 402 15.2 40 to 50 36 251 14.3 50 to 60 16 140 11.4 60 to 80 20 115 17.4
80 and more 24 263 9.1 Total 585 3640 16.1
Percentage of ISM
non-compliant ships(%)
0
5
1 0
1 5
2 0
2 5
3 0
3 5
4 0
0 t o 4 5 t o 9 1 0 t o 1 4 1 5 t o 1 9 2 0 t o 2 4 2 5 a n d m o r e
O t h e r C a r g o
B u lk C a r r ie r
O i l T a n k e r
32
5.6 ISM Non-compliant Ships sorted by Port State
The number of ISM non-compliant ships acted against in four regional areas is shown in Table 5.6.1 and Figure 5.6.1.
Tab.5.6.1 ISM non-compliant Ships sorted by Port State Regions ISM non-compliant ships Percentage (％)
Asia 310 53
Oceania 138 24
Europe 101 17
North and South America 36 6
Total 585 100
In 2004, more than half the Port State identified ISM-related deficiencies in the ships, were
in Asia. Among such areas, Japan and Australia identified a large number of non-compliant ships compared with other Port States.
Tab 5.6.2 ISM non-compliant Ships sorted by Each PSC State
Country No. of non-compliant
Ships
Country No. of non-compliant
Ships
Japan 189 Italy 10
Australia 127 Spain 7
China 58 Germany 7
Korea 23 Philippines 5
United Kingdom 23 Portugal 5
Canada 22 Ireland 1
Netherlands 20 Chile 1
Singapore 17 Malaysia 1
Hong Kong 14 Thailand 1
France 13 Vietnam 1
U.S.A. 12 Belgium 1
New Zealand 11 Greece 1
Russia 11 Poland 1
A s ia
O cean ia
Eu rop
N orth & Sou th A m e ric a
Asia 53% Oceania 24%
Europe 17％ North/South America 6%
Fig.5.6.1 Percentage of ISM non-compliant ship sorted by PSC areas(%)
33
5.7 Nationalities of Companies Managing ISM non-compliant Ships Table 5.7 and Fig. 5.7 shows the list of nationalities to which the companies that are managing the ISM non-compliant ships in 2004 have registered. The percentages of ISM non-compliant ships in China and Taiwan show high figure.
Tab 5.7 Nationality of Companies Managing ISM non-compliant Ships
Nationality
No. of
NKDOC
Company
No. of NKDOC
non-compliant
ships (A)
No. of NKSMC
ships (B)
Percentage (A/B %)
China 28 19 59 32.2
Taiwan 15 37 116 31.9
Greece 73 49 267 18.4
Philippines 15 23 132 17.4
Japan 229 281 1711 16.4
Hong Kong 22 37 226 16.4
Turkey 25 17 114 14.9
Malaysia 18 13 94 13.8
Singapore 51 54 530 10.2
Others 76 55 391 14.1
Total 552 585 3640 16.1
Fig.5.7 Percentage of ISM non-compliant ships sorted by the Nationalities (%)
＊This data includes only those nationalities which have 15 or more NKDOC companies.
0
5
10
15
20
25
30
35
China Taiwan Greece Philipines Japan Hong Kong Turkey Malaysia Singapore Others
Percentage of ISM
non-compliant ships(%)
34
Conclusions This report is the 6th “Annual Report on Port State Control regarding the ISM Code” issued by ClassNK, summing up the detained ships and deficiencies in relation to the ISM Code for all types of ships who have NK SMCs, through the year of 2004. The number of ISM non-compliant ships (NKSMC) has decreased compared with the previous year and the average percentage of ISM non-compliant ships in 2004 was 3.8%. It may be that one of factors behind decreasing ISM-related deficiencies is that it has been 2 years since ISM Code Phase II entered into force, and the implementation of the ISM Code by the management companies for “other cargo ships” (Phase II ships) has become comparatively stable and effective. As before, the deficiencies related to ISM Code section 10 ‘Maintenance of the ship and equipment’ and section 8 ‘Emergency Preparedness’ still remained too high. Therefore, companies are requested to enhance their monitoring of their ship’s maintenance condition and also offer further training and education for the said purpose. In general, the data shows that the longer management under SMS has been implemented, the lower the deficiencies of a ship pointed out by PSC, however, in 2004, there was a comparatively high percentage of ISM non-compliant ships managed by the companies registered for NKDOC around 1998, when ISM Code Phase I entered into force. On the contrary, the percentage for companies registered in 1999 through 2003 was drastically improved, which was coincided with a tendency toward decreasing deficiencies for “other cargo ship”, and was considered to be an improvement of management skill of the companies. As for “tankers” and “gas carriers”, they were still remained at low levels for percentage of deficiencies due to high awareness of safety and environmental protection by their companies. As for age of ships, it can be said that the percentage of non-compliant ships of age exceeding 10 years old was above the average in all types of ship, and was increasing for “oil tanker” and “other cargo ship” when exceeding 20 years, as well as drastically increasing for “bulk carrier” when exceeding 15 years old, which can be considered as being due to the company’s policy or plan for the maintenance of old-aged ships. The ships and their management company should take prompt actions and countermeasures if a ship is detained or has pointed out a major non-conformity due to ISM related deficiencies by PSC. Most detentions may be released for departure if the relevant repair or maintenance works or successful drills for emergency preparedness can be completed, however, it still remains to analyze the root causes of the ISM related deficiencies, to review the system and the education and training of crew, which should be resolved by both the management companies and the ships. Therefore, it is important that the company and the ship should have good communications between them for reporting any deficiencies from the ship and their rectification actions through support from the company, and also proper monitoring of the performance of the ship’s operation and maintenance condition onboard via the internal audits by the company or frequent attendances on the ships, etc. The SMS should be implemented not only for the avoidance of major casualties or maritime pollution accidents, but also for the enhancement of actions and decision-making and support activities by the company and the ship for restoration at an early stage in order to minimize any damage. This can be achieved by continuous routine works on board, education and training under the SMS, and also the investigations of root causes of deficiencies, rectification actions, and reviews and analysis of the system which are essential for the development of the system. We hope this report will be helpful for the SMS review activities of your company and ships.
Key Contacts
Head office Information Center Safety Management Systems Department Nippon Kaiji Kyokai 1-8-5 Ohnodai, Midori-ku, Chiba 267-0056 Tel:+81-43-294-5999 Fax:+81-43-294-7206 E-mail: [email protected] Regional Offices South Asia and Oceania Singapore Office Nippon Kaiji Kyokai 101, Cecil Street, #21-01 Tong Eng Building, Singapore, 069533 Tel: +65-62223133, Fax: +65-62255942 E-mail: [email protected] Middle East, East Mediterranean and Black Sea Piraeus Office Nippon Kaiji Kyokai 39-41 Akti Posidonos, Moschato 183 44, Piraeus, Greece Tel: +30-1-09420020, Fax: +30-1-09420079 E-mail: [email protected]
Europe and Africa London Office Nippon Kaiji Kyokai 6th Floor, Finsbury Circus House, 12-15 Finsbury Circus, London, EC2M 7EB, United Kingdom Tel: +44-20-7621-0963, Fax: +44-20-7626-0383 E-mail: [email protected] The Americas New York office Nippon Kaiji Kyokai One Parker Plaza, 11th Floor 400 Kelby Street, Fort Lee, N.J. 07024, U.S.A. Tel: +1-201-944-8021, Fax: +1-201-944-8183 E-mail: [email protected]
For more information on this publication, please contact the Safety Management Systems Department 1-8-5, Ohnodai, Midori-ku, Chiba 267-0056, Japan
TEL：+81-43-294-5999 FAX：+81-43-294-7206 e-mail: [email protected] http://www.classnk.or.jp
