Marshall Islands: Preparation for the US Coast Guard exams

The Republic of the Marshall Islands Maritime Administrator has issued the Marine Safety Advisory MSA-2022-05 about the preparation for the United States Coast Guard port State control and Certificate of Compliance exams.

This document addressed to ship owners, operators, masters, nautical inspectors, and recognized organizations was published on February 14th, 2023.

This Marine Safety Advisory underscores the extreme importance of sufficient preparation for United States (US) Coast Guard (USCG) port State control (PSC) and Certificate of Compliance (COC) exams, as well as completing, verifying, and submitting the Critical Items Checklist (MSD 340) prior to arriving in US waters.

It supplements and provides additional guidance for MSA No. 21-18.

USCG PSC Detentions

Recently, there has been a significant increase in detentions of Republic of the Marshall Islands (RMI)-flagged vessels during USCG PSC inspections.

Most of these detentions were easily preventable by proper and effective implementation of company and vessel Safety Management Systems.

It is imperative that ship managers, superintendents, senior officers, and all crew physically verify compliance and operation of onboard systems.

Systems or areas that are most affected include firefighting, life-saving, environmental compliance, load line in terms of watertight integrity of doors and ventilation, and crew familiarity and performance.

Importance of the Critical Items Checklist and Management by Walking Around

The intent of the Critical Items Checklist is to communicate preventable detainable deficiencies that could be expected in the US based on historical trends.

It was never intended to be an exhaustive list for every possible scenario.

Completing this checklist is an RMI requirement.

Refer to Marine Notice 5-034-5, Measures to Improve Compliance of Republic of the Marshall Islands Flagged Vessels in United States Ports.

Recent trends show that proper physical verification of the items on the checklist is an effective tool for preventing PSC detentions.

However, RMI-flagged vessels are also being detained for singular items found in substandard conditions that are not specifically listed on the checklist.

For this reason, it is extremely important for Masters and Chief Engineers to conduct thorough inspections of their spaces prior to arriving in the US and identify any substandard conditions.

This process is referred to as Management by Walking Around (MBWA), which has been a historically proven and effective strategy in the industry to ensure that senior management is actively looking for any issues that could hurt or impact operations.

Action

Senior management must be proactive before arriving in the US and physically inspect their spaces and systems for any condition that can be deemed substandard.

The Critical Items Checklist is a tool for inspecting the vessel but should never be used as an exhaustive list to identify all possible scenarios.

Furthermore, tank ships and gas carriers continue to schedule COC exams when unprepared, resulting in detentions.

Therefore, if there are any concerns about the material condition of the vessel, operators are encouraged to contact the Maritime Administrator at inspections@register-iri.com to schedule a special inspection prior to scheduling the COC exam.

It is understood that senior officers are extremely busy and under a lot of stress. Nevertheless, a 30 to 60-minute walkthrough inspection with a flashlight could prevent hours of lost time and laborious external audits caused by preventable detentions.

Masters and Chief Engineers are reminded to:

1. Accurately complete and verify the Critical Items Checklist. Reliance on statements that inspections are complete is not sufficient. All items must be physically checked and verified.
2. Be proactive and embrace the concept of MBWA.
3. Advise the RMI Maritime Administrator (the “Administrator”) of any non-operational equipment.

In fact, any crew member or vessel representative may alert the Administrator of potential substandard conditions onboard at inspections@register-iri.com.

All correspondence will be kept strictly confidential.