PSC - Seminar

PSC Seminar

PSC Seminar

Port State Control and ISPSBackground, Preparation and Prevention

Seminar Documentation

Contents

Contents21PSC Overview41.1History41.2Legal Background51.2.1Instruments51.2.2Conventions51.3Regional Agreements61.3.1Aims71.3.2Scope of Inspections82Procedure of PSC92.1Procedure onboard92.1.1selecting of ships92.1.2General Procedure102.1.3Scopes of Inspection102.1.4Detention122.2Special Inspection Campaigns132.2.1ISM Check132.2.2Bulk carrier Check142.2.3GMDSS Check142.2.4ISPS Checklist143Statement of Deficiencies153.1Definition of deficiencies153.2Documentation of deficiencies163.2.1Information onboard183.2.2Co-operation Master - PSCO183.2.3Information to third party183.2.4Costs193.3Possibilities for appeal203.4 New regulations within PARIS MOU213.5 Roll of GL223.5.1Assistance on-scene224Preparation for PSC234.1Steps for preparation234.2Prevention234.2.1Use of GL Checklist234.3Experiences / Statistics244.3.1 Germanischer Lloyd statistical data244.3.2External Statistics254.4ISM Inspections264.4.1PSC activities264.4.2 Procedures in case of ISM deficiencies265Summary276Attachments286.1Attachment 1296.2Attachment 2306.3Attachment 3316.4Attachment 4326.5Attachment 5336.6Attachment 6346.7Attachment 7356.8Attachment 836

1 PSC Overview

1.1 History

As a result of the Titanic Conference on 12th November 1914 the implementation of international regulations for the safety at sea had been started. Certain governments with a shipping industry in their country demanded unified regulations about minimum standards for ship constructions.

Among these regulations the basis for mutual acceptance of certifications and rules about safety at sea and control of ships was laid down. Due to the war these agreements had to be postponed.

Already with the ratification of SOLAS '29 (Safety of Life at Sea, 1929) the possibility was implemented to inspect ships of foreign flags in port. Since that time the regulations for inspection of ships had been amended and also copied within other international conventions.

In SOLAS 74/78, Chapter I, General Provisions within Reg. 19 Port State Control is defined by reference to IMO Resolution A.787(19). This regulation forms the legal basis for the work of PSCOs (Port State Control Officers).

In 1978 the first Agreement called The Hague Memorandum of Understanding had been worked out by a number of european shipping authorities. In March 1978, the "Amoco Cadiz" disaster happened at the Britanny coast causing a catastrophic oil spill. This incident demanded even stronger political activities towards safety at sea.

Consequently in Europe the "Paris Memorandum of Understanding on Port State Control" was signed by European governments with the aim to start unified regulations for watching

Standards for improving the safety of life at sea,

Standards for preventing environmental pollution and

Standards for improving living conditions onboard.

1.2 Legal Background

Each coastal country has the right to inspect ships of foreign flag in their ports for checking whether they comply with the international convention regulations.

Thus Port State Control is to be seen as a instrument

to control safety standards,

to protect the own territory against hazards from pollution

to keep "substandard" ships off their coasts.

1.2.1Instruments

The legal background for carrying out Port State Control is laid down in the IMO Resolution A.787(19) (amended by Res. A.882 (21)) which forms the foundation of world wide PSC activities.

Furthermore PSC is regulated by following agreements:

Regional Agreements called "Memorandum of Understanding on Port State Control",

European Union Directive 95/21/EC dated 19.06.1995, as amended in 2001 International Shipping Conventions in which the right for PSC inspections is laid down.

1.2.2Conventions

The right to inspect ships is laid down in following Conventions:

SOLAS Convention 74/78

MARPOL Convention 73/78

Loadline Convention 1966

STCW Convention 1995

Collision Prevention Regulations 1972, (COLREG 72)

International Convention on Tonnage Measurement of Ships 1969 (TONNAGE 1969)

Merchant Shipping (Minimum Standards) Convention, 1976 (ILO Convention)

Consequently a port state can check compliance with these convention regulations on each inspected ship.

1.3 Regional Agreements

In several areas in the world coastal countries have signed agreements about PSC, the so called "MEMORANDUM OF UNDERSTANDING ON PORT STATE CONTROL".

Following agreements are presently existing:

1982 PARIS MOU for the European region

1992 Vina del Mar MOU for Latin-America region

1993 TOKYO MOU for the East Asian region

1996 Caribbean MOU for the Caribbean region

1997 Mediterranean MOU for the East/South Med region

1998 Indian Ocean MOU

1999 Abuja MOU for the West African region

2000 Black Sea MOU

United States Coast Guard for USA coasts

Canada is member with PARIS MOU and TOKYO MOU

Russia is member with PARIS MOU and TOKYO MOU

Australia is member with Tokyo and Indian Ocean MOU

Some PSC-Organisations are publishing information about their work, aims and campaigns as well as detained ship lists and other statistical data in the Internet:

PARIS MOU: http://www.parismou.org

Tokyo MOU: http://tokyo-mou.org

USCG/PSC: http://www.uscg.mil/hq/gm/pscweb/index.htmlPSC Agreement Areas in the world:

List of Members of the different MOU agreements:

PARIS MOU:

Belgium, Canada, Croatia, Denmark, Finland, France, Germany, Greece, Great Britain, Ireland, Iceland, Italy, Netherlands, Norway, Poland, Portugal, Russian Federation, Slovenia, Sweden, Spain

TOKYO MOU:

Australia, Canada, Chile, China, Fidschi, Indonesia, Japan, Republic of Korea, Malaysia, New Zealand, Papua New Guinea, Philippines, Russian Federation, Salomon Islands, Singapore, Thailand, Vanuatu, Vietnam, Hongkong (China)

ViA DEL MAR MOU:

Argentine, Brazil, Chile, Cuba, Ecuador, Columbia, Mexico, Panama, Peru, Uruguay, Venezuela

CARIBBEAN MOU:

Anguilla, Antigua and Barbuda, Aruba, Bahamas, Barbados, Bermudas, British Virgin Islands, Cayman Islands, Dominica, Grenada, Guayana, Jamaica, Monserrat, Netherlands Antilles, Saint Kitts & Nevis, Saint Lucia, St. Vincent and the Grenadines, Suriname, Trinidad & Tobago, Turks and Caicos Islands

MEDITERRANEAN MOU:

Algeria, Cyprus, Egypt, Israel, Libanon, Malta, Morocco, Tunesia, Turkey, Palestine Authority

INDIAN OCEAN MOU:

Australia, Eritrea, India, Iran, Kenia, Maledives, Mauritius, Oman, South Africa, Sri Lanka, Sudan, Tanzania, YemenABUJA MOU:

Benin, Cape Verde, Congo, Cote d'Ivoire, Gabon, Gambia, Ghana, Guinea, Liberia, Mauretania, Namibia, Nigeria, Senegal, Sierra Leone, South Africa, Togo.

BLACK SEA MOU:

Bulgaria, Georgia, Romania, Russian Federation, Turkey, Ukraine

1.3.1Aims

The coastal countries have joined in the PSC Memoranda with following aims:

Unified training of the PSCOs,

Inspections under unified regulations,

General agreement about criteria for deficiencies justifying a detention,

Installation of a central data bank about inspected ships,

Number of ships to be inspected per year and per member country; (i.e. in Europe each country shall inspect 25% of all ships entering port(s)).

1.3.2Scope of Inspections

Generally Port State Control is entitled to inspect ships under foreign flags in their port(s) only for compliance with all mentioned international conventions.

Just the USCG as PSC authority in the USA is checking ships also for compliance with certain national regulations:

33 CFR 154-156 and 164 (pollution prevention, safety of navigation)

These regulation within the "Federal Code of Regulations" of the USA are valid as national law also for foreign ships trading in national US waters.

Furthermore some countries are checking non-convention ships for complying with national minimum requirements for the safety equipment.

2 Procedure of PSC

2.1 Procedure onboard

2.1.1selecting of ships

In the regional agreements it is agreed on the number of ships to be inspected per year per country In the PARIS MOU area it is agreed to inspect 25% of the ships entering ports of a member state.

Ships are selected according to a targeting system. In the regional area's computer data base ships are shown with certain priority for inspection according to the targeting points imposed on the ships due to following rules:

Type and age of ship

PSC history of the ship

PSC history of the company

PSC history of the flag and class

Claims about condition by received third party (crew, pilot, etc.)

Outstanding rectification of deficiencies from last port's inspection

Report by another PSC authority to inspect or redetain a ship in port

Further information about the European targeting system you find as per Attachment 9 in the new Target Factor Calculator in the PARIS MOU Internet.

Ships without targeting points according o the above mentioned criteria which were inspected without any deficiencies will not be inspected for the next 6 months within one MOU area.

2.1.1 General Procedure

The PSCO has to announce his visit with the Master. On his way upstairs he will get a first general impression about the ships condition.He has to check the certificates of the ship and to get an impression of the conditions onboard. It is his decision how he gets this impression: looking around on Deck, in the engine room, on the bridge. 2.1.3Scopes of Inspection

Three different types of inspections regarding the scope can be carried out:

General Inspection:

The PSCO is boarding a ship without announcement. On his way to the Master he is gaining a first impression about the ship's condition.

He introduces to the Master and in any case checks the ship's certificates and makes a tour around the ship to get an impression about the condition of the ships and the state of maintenance.

"more detailed" inspection:

If The PSCO discovers reasons to suspect that the ship is substantially not complying with the international convention regulations("clear grounds") he should decide to carry out a "more detailed" inspection.

Some PSC authorities have published checklists for the PSCOs as a basis of the inspection scope. A detailed checklist however is not required by any international agreement.

IMO Resolution A.787 (19):

2.3CLEAR GROUNDS

"Clear grounds" to conduct a more detailed inspection include:

.1the absence of principal equipment or arrangements required by the conventions;

.2evidence from a review of the ship's certificates that a certificate or certificates are clearly invalid;

.3evidence that the ship's logs, manuals or other required documentation are not on board, are not maintained, or are falsely maintained;

.4evidence from the PSCO's general impressions and observations that serious hull or structural deterioration or deficiencies exist that may place at risk the structural, watertight or weathertight integrity of the ship;

.5evidence from the PSCO's general impressions or observations that serious deficiencies exist in the safety, pollution prevention, or navigational equipment;

.6information or evidence that the master or crew is not familiar with essential shipboard operations relating to the safety of ships or the prevention of pollution, or that such operations have not been carried out;

.7indications that key crew members may not be able to communicate with each other or with other persons on board;

.8absence of an up-to-date muster list, fire control plan, and for passenger ships, a damage control plan;

.9the emission of false distress alerts not followed by proper cancellation procedures;

.10receipt of a report or complaint containing information that a ship appears to be substandard.

According to the MOU agreements certain types of ships will be inspected once each year in the scope of an"expanded inspection": Passenger ships,

Bulk carrier with more than 12 years,

Oil tanker over 20000GRT, Oil Product Carriers over 30000GRT and 20 years of age

Gas- and Chemical tankers of more than 10 years of age

More detailed inspectionThe scope of a more detailed inspection will include a complete tour around the ship, the detailed inspection of the safety equipment and arrangements as well as the arrangements for environment protection, the crew accommodation and the operational knowledge of the crew.

The decision for a more detailed inspection is lying within the PSCO's professional judgement and will be generally made if

deficiencies are observed in the certification (certificates invalid or absent)

the general impression of the ship's condition gives rise to suspecting that international regulations are not complied with.

Reports about deficiencies from third parties are known which require such inspection.

The agreements just contain examples for clear grounds for a more detailed inspection. A detailed definition for such ground does not exist.

A more detailed inspection does not claim to be complete. The PSCO decides about the scope of such inspection by his own judgement.

Special inspection campaignsConcentrated Inspection Campaigns are periodically carried out by regions to focus on special topics during the normal inspections. Special focus is put on scopes like ISM, GMDSS, bulker safety etc.

The regions are carrying out these campaigns during three months.

Following inspection campaigns are presently planned and announced:

Starting October 2004: : ILO regulations concerning working and living conditions of the crew

including a check of working and rest hours (PARIS MOU)

Planned within 2005: GMDSS arrangements and use

2.1.4Detention

If the PSCO finds clear grounds that the ship by it's condition forms a hazard to the safety onboard and/or to the environment, he has the right to detain the ship until the hazardous deficiencies have been rectified.

Within the agrements there is no detailed definition or list for ground for detention. Again there are only examples mentioned which may lead to the conclusion that a ship is "substandard".

Following examples are mentioned in the IMO resolution:

IMO Resolution A.787 (19):

4.1IDENTIFICATION OF A SUBSTANDARD SHIP

4.1.1In general, a ship is regarded as substandard if the hull, machinery, equipment, or operational safety is substantially below the standards required by the relevant conventions or whose crew is not in conformance with the safe manning document, owing to, inter alia:

.1the absence of principal equipment or arrangement required by the conventions;

.2non-compliance of equipment or arrangement with relevant specifications of the conventions;

.3substantial deterioration of the ship or its equipment because of, for example, poor maintenance;

.4insufficiency of operational proficiency, or unfamiliarity of essential operational procedures by the crew; and

.5insufficiency of manning or insufficiency of certification of seafarers.

4.1.2If these evident factors as a whole or individually make the ship unseaworthy and put at risk the ship or the life of persons on board or present an unreasonable threat of harm to the marine environment if it were allowed to proceed to sea, it should be regarded as a substandard ship.

4.1.3The lack of valid certificates, as required by the relevant conventions, will constitute prima facie evidence that a ship may be substandard and will form the basis of a decision to detain the ship forthwith and to inspect it.The PSCO again decides by his professional judgement which circumstances are justifying a detention.

Where deficiencies definitely can not be remedied in the particular port, the PSCO may allow the ship to proceed to another port for rectification. He will advise the next port about such decision and probably ask for redetention.

2.2 Special Inspection Campaigns

The MOU areas periodically decide to mount their inspections by a special inspection campaign focussing on special items onboard.

Following inspection campaigns lasting over a period of 3 months have already been carried out:

focussing bulk carriers - cargo holds

focussing regulations of ILO Convention no. 147 - crew accommodation

focussing ISM Certification on ships where ISM became mandatory in 1998

focussing bulk carriers above 30000GRT/15 years of age in view of structural integrity in holds and tanks

focussing GMDSS arrangements and operation by crew

focussing on Tankers above 3000GRT and 15 Years of age

focussing Cargo Securing

focussing the ISPS implementation as being compulsory for all ships focussing on ILO requirements for living quarters starting in October 2004 Next Inspection Campaign planned: GMDSS arrangements and use

GL in connection with these Campaigns had published special checklists which can be further used onboard for checking the ships condition as a precaution for PSC inspections:2.2.1ISM Check

Amendments to the IMO Resolution A.787(19) as well as the regional MOU-Agreements stipulate the regulations about inspections of the implementation of the ISM Code onboard.

IMO in this respect has published a guideline with a list of 11 questions. This shall enable the PSCO to check the system.

Checklist:

GL has published a checklist containing the 11 questions out of the IMO guidelines which can be used for preparation of the crew for such inspection. It may still be used to check the knowledge of the crew regarding the SMS.

This checklist you find in the Attachments .

2.2.2Bulk carrier Check

The PARIS MOU region had performed an Inspection Campaign on Bulk Carriers focussing on cargo hold and ballast tanks. The results according to press releases show that the conditions on those ships have improved although still structural deficiencies are found forming a hazard to the ship. 79 bulk carriers were inspected out of which 10 ships had to be detained.

GL has published a special checklist in connection with this campaign. It shall assist owners to check the structural conditions onboard of bulk carriers. It may be used as an aid to detect deficiencies and as a report for regular condition checks.

This checklist you find in the Attachments .

2.2.1 GMDSS Check

In the Asian region a Concentrated Inspection Campaign was carried out on the GMDSS arrangement and it's handling. Special focus was put on the ability of the crew members holding a GMDSS licence to handle the equipment

In view of the amount of emergency alarms sent out erroneously in the past PSCOs asked the responsible crew members to show the cancellation procedure for such transmissions.

For preparation on the campaign but also for regular checking onboard GL has published a checklist, which you find in the Attachments .

2.2.2 ISPS Checklist

During the ISPS Inspection Campaign the PSCOs used a list of questions to be asked onboard to verify compliance with the ISPS Code.

This checklist can be further used to check onboard whether the ship in completion of the regulations and whether the crew is familiar with the security system.3 Statement of Deficiencies

3.1 Definition of deficiencies

Deficiencies are seen as non-conformities with the international convention regulation. They can be defined as:

technical deficiencies

operational Deficiencies

deficiencies in the documentation

For statistical purposes a coding system for listing the deficiencies is internationally in use.

The complete list of codes you can find in Attachment 5.

The time window for rectification stated by the PSCO for each deficiency is also mentioned in the report in coded form.

Following Codes are in use:

10 deficiency rectified

12all deficiencies rectified

15rectify deficiencies at next port

16rectify deficiency within 14 days

17Master instructed to rectify deficiency before departure

18rectify non-conformity within 3 months

19rectify major non-conformity before departure

26ISPS competent authority informed

27ship expelled for security grounds

30grounds for detention

40next port informed

45next port informed to re-detain

47as in agreed class condition

50flag state consul informed

55 flag state consulted

65operation stopped

70classification society informed

80temporary substitution of equipment

81temporary repair

85investigation of contravention of discharge provisions (MARPOL)

95letter of warning issued

96letter of warning withdrawn

99other (specify in clear text)

Only some of the codes you will find in the PSC-Reports, the others are mainly used for the input in the PSC computer data base.

Some areas are using some different action codes however the main codes are used worldwide.

The codes A Q used presently by PARIS MOU are cancelled and the number codes used again!

3.2 Documentation of deficiencies

An official PSC Report, which is handed over to the Master, consists of 2 parts (the format may look different in different PSC areas):

Form A: (example see below) ship's data,

validity of certificates,

dates of last surveys,

declaration about a detention

Form B:

List of deficiencies, with respective coding

relevant Convention Regulation

time window for rectification in coded form

3.2.1Information onboard

Finalizing a Port State Control the PSCO presents the report to the Master, in which he states the deficiencies found with the time window for rectification for each deficiency.

In case the PSCO decides to detain the ship, the Master will receive an official note of detention. In the report the PSCO determines whether the resurvey for verifying rectification of the detainable deficiencies shall be carried out by the authority or whether a class surveyor shall be called to furnish such report. In this case the PSC authority will raise the detention on receipt of the surveyor's report.

The PSCO has to inform the Master about the rights to appeal against a detention. The owner has the right to appeal against the detention with the national PSC authority, which however does not suspend a detention.

Addresses of the national PSC Authorities, as far as known today, are copied from the Internet and to be found in the Attachments .

According to an agreement between the PSC authorities and the member societies of IACS the PSCO has the right to ask for attendance of a class surveyor to discuss appropriate steps in view of rectification of detainable deficiencies.

The surveyor will announce his visit if called by PSC to the owner's representative and discuss matters with the PSCO and, if found necessary, inform him about last survey results and outstanding recommendations.

3.2.2Co-operation Master - PSCO

Master shall be advised to co-operate with the PSCO when boarding in a friendly and open atmosphere. Documentation and other evidence shall be provided as requested.

In case of doubt about a deficiency listed by PSC a question should be raised against the PSCO against which convention regulation the ship is contravening.

The Master should arrange an office to accompany the PSCO on his tour having keys for any rooms locked in port.

The PSCO should not be seen as an enemy to the ship but a collegue.

3.2.3Information to third party

According to IMO Res. A.787(19) the PSC authority has to inform following administrations about any detention by forwarding a copy of the PSC report

the flag state authority

the classification society

IMO

Within an MOU area the member state' PSC authorities receive information about PSC inspections by entering the data of each inspection into the area's computer data base.

This information enables the PSC authorities of the members to check the PSC history of ships entering their ports in view of a choice for inspection (Targeting!).

Official Search Data Bases in the Internet:PARIS MOU: www.parismou.org => Inspection Database

TOKYO MOU: www.tokyo-mou.org => PSC Database

USCG: http://cgmix.uscg.mil/psix/psix2/ => vessel search

Indian Ocean MOU: www.iomou.org => Inspection Data

IMO Resolution A.787 (19):

5.1PORT STATE REPORTING

5.1.1Port State authorities should ensure that, on the conclusion of an inspection, the master of the ship is provided with a document giving the results of the inspection, details of any action taken by the PSCO, and a list of any corrective action to be initiated by the master, owner or operator. Such reports should be made in accordance with the format in appendix 5.

5.1.2Where, in the exercise of port State control, a Party denies a foreign ship entry to the ports or offshore terminals under its jurisdiction, whether or not as a result of information about a substandard ship, it should forthwith provide the master and flag State with reasons for the denial of entry.

5.1.3In the case of a detention, notification shall be made to the flag State Administration. If such notification is made verbally, it should be subsequently confirmed in writing. Likewise, the recognized organizations which have issued the relevant certificates on behalf of the flag State should be notified, where appropriate.

5.1.4If the ship has been allowed to sail with known deficiencies, the authorities of the port State should communicate all the facts to the authorities of the country of the next appropriate port of call, to the flag State, and to the recognized organization, where appropriate.

5.1.5Parties to a relevant convention when they have exercised control giving rise to detention, should submit to the Organization reports in accordance with regulation 19 of chapter 1 of SOLAS 74, article 11 of MARPOL 73/78, article 21 of Load Lines 66, or article X(3) of STCW 78. Such deficiency reports should be made in accordance with the form given in appendix 5 or 6, as appropriate.

5.1.6Copies of such deficiency reports should, in addition to being forwarded to the Organization, be sent by the port State without delay to the authorities of the flag State and, where appropriate, to the recognized organization which had issued the relevant certificate. Deficiencies found which are not related to the applicable conventions, or which involve ships of non-convention countries or below convention size, should be submitted to flag States and/or to appropriate organizations but not to IMO.

5.1.7Relevant telephone numbers and addresses of flag States headquarters to which reports should be sent as outlined above as well as addresses of flag State offices which provide inspection services should be provided to the Organization.

3.2.4Costs

PSC - Inspections generally are free of charge.

In case of a detention the PSC authority is entitled to charge the costs for their duties to the owners. The payment has to be settled prior to release from detention.

The right for charging the costs is laid down in the PSC agreements and for the European countries by an EC directive.

Recent information via ship owners show that the member authorities of the West African MOU charge for every visit!

3.3 Possibilities for appeal

The owner has the right to appeal against unjustified detention of his ship with the local PSC authority. This right is laid down in the amendments to the IMO Resolution A. 787 (A.828 Para. 2.6.11). As also mentioned the appeal is not automatically suspending the detention.

"2.6.11 The company or its representative have a right to appeal against a detention taken by the Authority of a port State. The appeal should not cause the detention to be suspended. The PSCO should properly inform the Master of the right to appeal."

If a ship unlawfully had been detained as has been proved, the owner has to right for reimbursement of his costs by PSC.

Any appeals has to be clarified with the national PSC authority. As long as the ship is still in port, an appeal should be addressed to the local PSC office. At a later stage the appeal should be sent to the national PSC authority's office.

The addresses of the national PSC authorities in the European and Asian region you find in the Attachments.

The updated address data you may find also in the Internet under following addresses:

PARIS MOU:

http://www.parismou.org/adreslijst.htmlTOKYO MOU:

http://www.tokyo-mou.org

3.4 New regulations within PARIS MOU

Ships with Target Factor above 50:

Those ships will be inspected again after one month.

Compulsory annual Expanded Inspections:

Oil tanker above 3000 GRZ and 15 years of age Product and Gas Carrier over 10 years of age

Bulk carriers over 12 years of age

Passenger ships over 10 years of age

The Master has to announce to PSC when the next annual inspection is due again. The local PSC authority will decide whether the inspection is carried out in port or not.

On tankers the inspection of one ballast water tank is required.

Boat and fire drill has to be shown to PSC on passenger ships.

Further details about carrying out these inspections, especially regarding feasibility, are not known yet.

Banning Rules:Member states of the EC and of PARIS MOU have to implement EC Banning rules for banning certain ships from EC waters und following circumstances:

Valid for all oil tankers, bulk carriers, product and gas carriers an passenger ships

Banning of ships flying a flag as per PARIS MOU Black list

After the second detention within 3 years under a very high risk flag

After the third detention within 2 years under a medium high risk flag

The number of detentions are counting from 22nd January 2002.

The banning can only be lifted after a thorough survey both by class and flag administration.

The owners have to send a formal request to the local PSC authority which issued the banning order, together with a statement of the class and of the flag that the ship complies with all relevant class and convention regulations. PSC finally will carry out another inspection to verify the compliance and lift the ban.

3.5 Roll of GL

GL can render assistance onboard if invited by the owners.

Furthermore GL is assessing each PSC case on GL classed ships with the aim to check the own survey activities. The assessment is used for quality control of our duties as well as for conclusions about in which areas onboard more attention has to be paid for in the future.

As carrying out surveys on behalf of the flag state authorities GL is obliged to report the authorities about the cases and our responsibility.

3.5.1Assistance on-scene

Assistence can be rendered at any time by a local surveyor in case of need. The surveyor can assist in reporting about rectification of deficiencies to PSC and thereby possibly speed up the release.

Furthermore the surveyor may discuss with the PSCO about unclear deficiencies as well as about the time frame for rectification to be given.

As mentioned previously the surveyor may discuss about legitimacy of deficiencies and time frames.

However it has to be clearly pointed out that the final decision definitely lies with the PSC authority !

4 Preparation for PSC

4.1 Steps for preparation

The company should take appropriate steps to avoid problems with PSC inspections.

Following steps are to be taken onboard which to be checked by the company:

Continuous maintenance of the equipment in accordance with manufacturer's requirements, actual condition onboard and professional knowledge of the ship's command. . This includes especially prevention of corrosion, periodical tests and check of validity data of respective equipment in order to renew in time.

Periodical training of the crew for emergency cases.

Check of the ship's certificates in view of validity and dates of due surveys.

Check of the general condition of the ship, especially the gangway and entrance area of the ship (first impression to the PSCO!).

Reporting to the harbour authorities prior arrival, if the ships arrives with major damages (due bad weather, collision, etc.) which to be repaired in port. If such damages are repaired in port, PSC shall not detain the ship (Res. A.787 Reg. 2.6.7).

4.2 Prevention

For preventing problems the company should implement a procedure which should verify that the preventive measures have regularly been carried out onboard.

4.2.1Use of GL Checklist

GL has published a "Maintenance Checklist" which could be used as documentation for preventive steps onboard. It is based on the statistics in view of the frequency of deficiencies found by PSC on GL classed ships. The list does however not claim to be complete.

It can be filled in onboard in regular intervals and be sent to the company as verification for the preventive steps according to company order.

The checklist may be included into the ISM documentation as a verification for carried out maintenance acc. to Para 10 ISM Code ("Maintenance")

The checklist is not required by PSC. It might be shown to a PSCO, but only in case a deficiency has been discovered recently and taken or arranged steps to rectify can be shown to PSC in this way.

This checklist you find in Attachment 2.

4.3 Experiences / Statistics

4.3.1 Germanischer Lloyd statistical dataSince 9 years GL is analysing all known PSC cases on GL classed ships by a computerized system. All cases are entered into the data bank and statistics can be drawn about the kind and frequency of deficiencies found in order to trace areas to be watched more carefully and generally to improve our quality.

In the Attachments you find some statistics about kinds and frequency of deficiency groups.

These figures clearly show that the areas which have to be focussed are lying within the safety equipment with fire fighting and lifesaving appliances.

On the basis of these statistics the GL Maintenance Checklist has been prepared.

Our analysis furthermore showed that more than 50% of the deficiencies obviously were caused by lack of maintenance and care and lack of regular checking by the crew. Consequently it can be highly recommended that maintenance and regular checks get top priority within the routine work onboard.

4.3.2External Statistics

Some MOU regions are publishing annual statistics which are listing the detentions by classes and consequently evaluate the quality of the classification societies' duties.

Generally the statistics base on a ratio between the number of inspections and the number of detentions in order to calculate a ranking. Further criteria are different within the areas:

The USCG already publish statistics since 9 years, always basing on the average data of the previous 3 years. Used figures are the number of ships entering US waters per year and the number detentions for which they determine the class being responsible. For this decision USCG has implemented a filtering system for determining class responsibility for the detainable deficiencies.

The region of TOKYO MOU also since some years is publishing data on the basis of inspections and detentions per year. A class relation filtering process has been implemented in 2002.

The region of PARIS MOU is publishing class ranking statistics since 2000 on the basis of inspections and detentions of the previous year. The members are using the same filtering criteria as USCG and are only taking into account the class related detentions for calculating a class ranking.

A summary of the statistics of these three regions for 2002 shows a quite positive record for GL in all regions. The 2003 statistical data about class performance have not yet been published.According to a three year rolling average statistics within PARIS MOU GL is seen on the best position.

Class related detentions PARIS MOU

IACS Societies (3 year rolling average)

2001 - 2003classInspectionsClass related detentionsratio

GL11037590,53%

DNV7039470,66%

RINA1723170,98%

BV7506781,03%

ABS3757411,09%

LR99211121,12%

CCS46261,29%

NK4377571,30%

RS5062691,36%

KR42992,09%

For taking into account the relation of much differing numbers of inspection PARIS MOU has published another statistics about a Performance Level of Classification Societies with GL ranking on first place too.4.4 ISM Inspections4.4.1PSC activitiesWithin IMO Res. A.882(21) it is laid down that PSC can check the implementation of the ISM system onboardFollowing definitions have been made:

The PSCO is not carrying out an audit (unless trained as auditor)

He checks the presence and validity of the ISM certificates DOC and SMC.

In case of incomplete ISM implementation plus technical deficiencies or a summary of minor deficiencies is leading to the suspicion that the ISM system is not implemented in full, the PSCO may decide to carry out a more detailed inspection of the ISM system onboard.

The PSC can list a deficiency stating that it is alleged that the ISM system is not working properly and further actions have to be arranged by the owners in connection with the ISM certifying authority. He may require that such actions are taken prior to departure or within a certain timeframe after the detention.In order to assist the PSCO in checking the system IMO has published a question list with 11 questions to be asked to provide an overview about the implementation of the system. This list of questions can be found in the ISM Checklist published by GL (see Attachments).

4.4.2 Procedures in case of ISM deficienciesPSC expects a reaction by the owners to arrange a verification of the ISM system onboard by an auditor of the certifying authority within the given timeframe.

Owners should get in contact with the auditor if rectification is requested prior to departure. The report made by auditor showing the results of the system verification including possible corrective actions to be carried out has to be sent to PSC as a confirmation of actions requested.5 Summary

We hope that we have been able to assist you with our information so that you can take the necessary steps to reach the aim that your ships in future will be found without deficiencies and consequently the probability for an inspection on your ships is declining.

We are prepared to render assistance for answering your questions and for attendance on board.

Persons in charge in GLHO:

Peter Graaf

Tel. 36149 189

Gerhard Bpple

Tel. 36149 496

Jens Pltz

Tel. 36149 7913

Fax:

36149-7766For special ISPS matters:

Dirk Eggers

Tel. 36149 7055

Fax:

36149 7007

6 Attachments

Attachment 1:

GL Maintenance Checklist

Attachment 2:

GL ISM Checklist

Attachment 3:

GL Bulk Carrier Checklist

Attachment 4:

GL GMDSS Checklist

Attachment 5:

GL Statistics about found deficienciesAttachment 6:

Addresses of PSC Authorities

Attachment 7:

Target Factor Information published by the

European RegionAttachment 8:

GL ISPS Checklist6.1Attachment 1

GL Maintenance Checklist

6.2Attachment 2

GL ISM Checklist6.3Attachment 3

GL Bulk Carrier Checklist6.4Attachment 4

GL GMDSS Checklist

6.5Attachment 5

GL Statistics about found deficiencies6.6Attachment 6

Addresses of PSC authorities6.7Attachment 7

Target Factor - Information published by the European Region6.8Attachment 8

GL ISPS - ChecklistEastcoast Russia with TOKYO MOU

( Germanischer Lloyd

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