Bahamas: notice on the deficiencies at PSC inspections

The Bahamas Maritime Authority (BMA) has released an information notice addressed to ship owners, managers, masters, approved nautical inspectors, recognized organizations, and surveyors regarding the deficiencies at Port State Control (PSC) inspections that resulted in a PSC detention.

This notice was issued on 12 September 2023.

Purpose

1.1. This Information Notice is to bring to the attention of Companies operating Bahamian ships a number of recurring deficiencies raised at Port State Control (PSC) inspections that resulted in a PSC detention.

Application

2.1. This Notice is applicable to all Bahamian ships on international voyages that visit ports of countries outside The Bahamas.

General

3.1. The Bahamas Maritime Authority (BMA) as a Flag State Authority is committed to ensuring that all Bahamian ships are always fully compliant with international Convention requirements and national regulations and fully supports the objectives of the PSC inspection process in eliminating sub-standard shipping.

3.2. Analysis of detainable deficiencies recorded against Bahamas flagged ships has identified the following unacceptable, easily identifiable and wholly avoidable deficiencies:

i. Deficiencies/failures have not been reported to the BMA or Classification Society (Recognised Organisation) for agreed acceptance pending temporary arrangements in place;
ii. Any arrangement that bypasses essential safety or environmental monitoring equipment (e.g. “magic pipes” bypassing Oily Water Separator (OWS)/15ppm monitor);
iii. Equipment has been poorly maintained and/or maintenance has been inappropriately documented or not documented within the shipboard planned maintenance system (PMS);
iv. Crew are unfamiliar with essential equipment or systems they are responsible for (e.g. OWS, ECDIS, GMDSS equipment, etc.);
v. Equipment which requires Flag State/Classification Society approval has been fitted, modified, or removed, or structural changes have been made without proper consultation with the Flag State/Classification Society/Recognised Organisation.
vi. Critical equipment has not been subject to regular testing as required (e.g. emergency equipment such as fan dampers and emergency fire pump).
vii. Logbooks, record books, hours of rest records and other documents are incomplete or inaccurate. It should be noted that PSC authorities may in some cases instigate criminal proceedings for alleged falsification of records where records are incomplete or inaccurate (in particular for hours of rest records and Oil Record Books).
viii. Navigation conducted in an unsafe manner. Whether by the use of out of date publications or incomplete passage plans, or by avoidable violations of the COLREGs such as lights, shapes and sound signalling devices not in working condition.

3.3. It should be noted that even though individual minor deficiencies may not qualify to be graded under Code 30 (detention), multiple minor deficiencies can be linked to failure of the Safety Management System (SMS) and result in detention of the ship.

Multiple deficiencies cannot be expressly quantified in number because certain PSCOs may consider five (5) deficiencies sufficient to justify detention whilst others may not detain a ship even with 10 deficiencies.

Hence, it is recommended for ship’s senior management to take a round on deck and engine room with an aim to identify minor deficiencies and rectify prior to arrival port.

3.4. Further advice is provided in the following sections for recurrent PSC deficiencies based on the specific risk area.

Fire Safety

4.1. There have been several PSC detentions involving defective firefighting and fire prevention equipment.

4.2. It is a requirement of Regulation 14.2.1 of Chapter II-2 of the International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS) that all firefighting equipment shall be kept in good order and readily available for use.

4.3. It is also a requirement of Regulation 11(c) of SOLAS Chapter I that any defects which affect the safety of the ship or its continued compliance with statutory requirements are to be reported to the flag administration and the Recognised Organisation who issued the affected certificate on behalf of the flag administration.

4.4. The deliberate deactivation of firefighting and fire prevention systems, without due cause, is not acceptable.

Where such circumstances are brought to the attention of the BMA they will be investigated and, where appropriate, further action will be taken by the BMA.

4.5. The most recurrent recent deficiencies related to fire safety are specifically due to:

i. Fire doors condition; held open by hooks/ropes, defective sealing material, defective latches doors closing either too slow, too quickly, or not at all.
ii. Fire dampers; operational remotely but not locally, able to operate from either control but not closing entirely, corrosion preventing full closure.
iii. Fuel oil leaks; pipelines leaking fuel oil.
iv. Fire pump and its pipes; insufficient pressure and/or not operational.

4.6. Fire Doors

4.6.1. All owners, managers and masters of Bahamian ships are to ensure that all firefighting and fire prevention equipment shall be kept in good order and readily available for use.

The following deficiencies should be noted in particular:

i. Gasket seals badly damaged causing door to not seal correctly.
ii. Doors either do not move at all when operated locally, or close too slowly. Some fire doors were flagged for closing too quickly, thus giving personnel insufficient time to react in an emergency.

4.7. Fire Dampers

4.7.1. Deficiencies related to fire dampers are considered major deficiencies and generally warrant the detention of the ship.

i. Crews should ensure that fire dampers which are required to be closed remotely can still also be closed locally as well.
ii. During testing, crew should verify that full closure is achieved by physically looking at the damper itself and not just relying on the position of the indicator. There have been instances where dampers have been indicated as closed but are held open by corrosion or some other object blocking the damper.

4.8. Fuel Oil Leaks

4.8.1. Fuel oil leaks are considered a major deficiency as they present a significant fire risk.

The presence of fuel oil leaking in combination with various sources of ignition in the engine room have resulted in catastrophic fires in the past, which is why fuel oil leaks should be contained and repaired as soon as possible.

4.8.2. In addition to the fire risk, leaking fuel also contributes to an unsafe working environment for the crew and can increase the risk of slips, trips and falls in the workplace.

In this regard some PSCOs will record fuel or lube oil leaks as a Maritime Labour Convention (MLC) deficiency in addition to the SOLAS aspect.

4.9. Fire Pump and its Pipes

4.9.1. A ship’s fire pumps are some of the most basic but also most essential firefighting equipment on board. It is essential that these pumps are tested as per the ship's PMS without fail.

4.9.2. Should the ship need to take one of the SOLAS required fire pumps out of service due to a failure and/or regular service, crew members should be aware of which pump to use in the place of the main fire pumps as per Regulation 10.2.2.1 of SOLAS Chapter II-2 and be able to demonstrate this to the PSCO as required.

Life Saving Appliances

5.1. The area of Life Saving Appliances (LSA) has also been recorded in several detainable deficiencies recently with 23 detainable deficiencies recorded in 2022 and with a similar trend for the first and second quarter of 2023.

5.2. The most common detainable deficiencies for LSA are:

i. Stowage of survival crafts
ii. Launching arrangements for survival crafts
iii. Maintenance and inspection of LSA
iv. Crew unfamiliarity with operation of LSA

5.3. Stowage of survival craft

5.3.1. This deficiency has been cited against liferafts and rescue boats. With liferafts, several instances were noted of expired hydrostatic release units being in place which the crew was unaware of.

There was also an instance of excessive lashing on a liferaft which would prevent the float free arrangements from operating as designed.

5.3.2. For the rescue boats and particularly with rescue boats which are not lifeboats, deficiencies were cited for boats not being connected to the davit at the time of inspection.

While this in itself is not a deficiency, the crew must be able to demonstrate the full launching of the rescue boat in the water within the 5 minutes required by Regulation 14 of SOLAS Chapter III – this must be inclusive of the time it takes to connect the davit hook.

5.4. Launching arrangements for survival craft

5.4.1. Launching arrangements have been cited in the past particularly with some frequency and several of the deficiencies have been noted as detainable.

Most commonly would be deficiencies related to the davit.

The davit must be able to function as designed and this is to include limit switches, condition of wire ropes, emergency source of power (including accumulators where applicable).

5.4.2. The launching arrangements have also been cited because of the resting position of the lifeboat at the boarding position.

Crew are to ensure that tricing pendants and/or other devices to keep the lifeboats alongside are operating as intended.

5.4.3. Inclusive of the launching arrangements would be the recovery requirements for rescue boats. This too should be checked by the crew during regular drills.
Regulation 17.4 of SOLAS Chapter III requires a rescue boat to be recovered within 5 minutes. Any defects which can affect the davit and/or its motor will also affect the speed of recovery.

5.5. Maintenance and inspection of lifesaving appliances

5.5.1. LSA are to be inspected as per SOLAS requirements and as per the company’s SMS procedures.

All required inspections and maintenance are to be properly recorded as required in the SMS logs and or ships logbook.

It is important to remember that during an initial inspection it is quite possible that a check of documentation and logbook entries can be the extent of the inspection.

If documentation and logbook entries are not as required it will trigger a more detailed inspection and could lead to more deficiencies being identified.

5.6. Crew unfamiliarity with operation of LSA

5.6.1. With most PSC inspections, even in cases where the PSCO has not requested a drill, crew members will be asked questions regarding specific duties and functioning of equipment.

It is important that crew members who have responsibilities on the muster list are familiar with those responsibilities.

If the PSCO determines that a crew member is unfamiliar with required duties this again will trigger a more detailed inspection and could lead to more deficiencies being identified.

MARPOL Annex I (Oil)

6.1. Compliance with Annex I of the International Convention on the Prevention of Pollution from Ships 1973, as amended (MARPOL) is one the most common items subject to inspection on any PSC inspection.

6.2. The most common recent deficiencies related to MARPOL Annex I are:

i. Crew unable to demonstrate correct operation of the OWS;
ii. Crew not able to conduct the 15ppm oil content monitor (OCM) function test;
iii. Previous Oil record books (ORB) not available (these should be preserved for a period of three years after the last entry has been made);
iv. ORB missing entries of weekly sounds of oil residues in tanks listed in the supplement to the IOPP Certificate;
v. Incinerator refractory deteriorated;
vi. Unauthorized modifications to OWS and OCM.

6.3. Deficiencies indicated in 6.2 above may be indicative of failings in the effectiveness or implementation of the company’s SMS, which could warrant detention of the ship and to a request for additional external audits by PSC prior to the ship being allowed to depart port.

6.4. The BMA recommends that the following steps be considered by the company to enhance engine room crew members’ awareness of OWS and 15ppm oil content monitor operations and the ORB procedures:

i. Produce a set of clear instructions for Chief Engineer Officers and other Engineering Officers with regards to correct and consistent entries in Oil Record Book;
ii. Produce a ship-specific set of instructions addressing correct OWS operation and include same within the on-board training program for all engine room crew;
iii. Include bilge holding tank internal inspection and cleaning, where necessary, in the ship’s planned maintenance system;
iv. Include OWS and 15ppm oil content monitor operational tests in the ship’s PMS. Should such tests be unsuccessful, the BMA and ships Classification Society should be informed immediately so that suitable short-term arrangements can be agreed.

Further Information

7.1. The previous revisions of this Notice are available on request.

7.2. A Pre-arrival checklist based on the most frequent recurrent deficiencies is provided in the Annex to this Notice to assist with preparation for PSC inspections and is available for download as FORM060.

This form must be submitted to the BMA for calls to US ports as per Technical Alert 23-02 v2.0.

For more information, please see the document below (available only to subscribers):