Documente Academic
Documente Profesional
Documente Cultură
OCIMF
Ktenas Panagiotis MA Inter. Relat., MSc. Urban Plan , BSc Econ and Mech. Eng.
Certified Adult Trainer, Registrar N.EA24815 (EOPPEP).
ex. Lt Cdr Hellenic Navy
pktenas@gmail.com
November 2019
1
Module 1 – Introduction & Knowing The Rules
Understanding Oil Company vetting systems and managing SIRE report comments to reduce inspector
observations and deliver continuous improvement
Safety first
a/ An engine room ?
b/ External areas ?
c/ External areas on ships with breadth > 30 meters
SOLAS II-2 Reg.10 2.3.1.1
Module 1 - Short quiz tests your knowledge of these important
documents
a reply that:
• identifies the root cause of the deficiency
• fixes the existing cause of the deficiency
• identifies changes to operating procedures to reduce the chance
of the deficiency occurring again
Module 1-Some replies which are not accepted
• “Rectified. (trust me!)”
• “When convenient…”
• “At the earliest opportunity…”
• “We have reminded the Master/Chief ...”
• “The parts have been delivered on board.”
• “He has been cautioned and instructed to…”
Better reply:
Recognizing that the Master was not aware of the location of the vapor release plan within our
SMS manual, we sent our superintendent on board 11 Oct 18, and he conducted SMS training
with all officers so that they are now fully aware of all contents of our SMS procedures manual.
Module – Bad Example #2
Observation:
“The main engine is covered with oil.”
Initial Reply:
“The main engine has been cleaned.”
Better reply:
During the shipyard period Nov 18, we have arranged for a factory representative to supervise
work to eliminate all fuel and lube oil leaks from the main engine, after which the engine will be
cleaned and re-painted.
Module – Bad Example #3
Observation:
A June inspection found a C-of-C issued Feb, due in July: “vessel to submit results of stern tube
lube oil analysis”.
Initial Reply:
“Condition of class will be attended to in due course.”
Better reply:
Stern tube lube oil sample test results were submitted to class on 17 March and Condition of
Class was deleted on 22 April 2018. Deletion of C-of-C will appear on 1 July class quarterly
report.
Module – Remember that:
a. Recognize that the SIRE inspector can use questions that come from many differing
sources.
b. Improve your familiarity with all the source documents that may be used by a SIRE
Inspector and the guidance in the SIRE VIQ.
c. Use the vast internet resources to keep up to date.
d. Understand that the more you are familiar with the contents of the SIRE VIQ, the easier
it will be to deal with questions from the Inspector.
e. Relish the contact with the inspector, treat him as a fellow professional who is no better,
nor, no worse than you.
f. Set yourself a challenge that you will see fewer Observations with each successive
inspection.
Module 2 – The history of OCIMF, why SIRE was
needed, Risk Management, Spot Chartering and
Vetting.
in Figure 1. It is of note that 19 of the 20 largest spills and did not impact coastlines. For this reason, some
recorded occurred before the year 2000. SANCHI, the of the names listed may be unfamiliar. EXXON VALDEZ
latest addition to the top 20 major spills, is the only major and HEBEI SPIRIT are included for comparison although
spill of non-persistent oil featured here and it resulted these incidents are further down the list. PRESTIGE is also
Table 1: Major oil spills since 1967 (quantities have been rounded to nearest thousand) * The only spill of non-persistent oil
+ Included for comparison
21 PRESTIGE+ 2002 Off Galicia, Spain 63,000
36 EXXON VALDEZ+ 1989 Prince William Sound, Alaska, USA 37,000
132 HEBEI SPIRIT+ 2007 South Korea 11,000
Module 2 – Awareness of the Pollution threat from Tankers
Table 1: Major oil spills since 1967 (quantities have been rounded to nearest thousand) * The only spill of non-persistent oil
+ Included for comparison
3
Module 2 – The impact of OPA ‘90
Liability and Compensation – Applying the “Polluter Pays
Principle” OPA 90 is based on a polluter pays principle
holding the owner /operator strictly liable. It establishes
limitations of liability at higher levels than international
conventions and removes limitation protection if the
incident was caused by gross negligence, wilful
misconduct or violations of Federal safety, construction or
operating regulations by the responsible party.
In normal circumstances the owner will respond to the spill
and his insurance ($1 billion cover for pollution is typical)
will fund the response. This framework ensures that the
ship owner takes on the major proportion of the liability
risk and this structure has been instrumental in
discouraging low quality operators from trading in the
USA.
Module 2 – The impact of OPA ‘90
LAUNCH AGREEMENT
1991 1992
Full scale Oil Co
SHORTCOMINGS Report sharing concept
BREAKTHROUGH
Inspections commence agreed among OCIMF
1991-2 Members. Development of 1993
SIRE commenced.
Severe shortcomings in the First inspection report
“Go it alone” approach submitted to SIRE
recognized at OCIMF
Module 2 – Participating Members’ Companies
identifying trends and revealing patterns in the data to progressive reduction in the number of large spills is
present the most accurate result. significant when data is analysed per decade rather
than annually, as demonstrated in Figure 4. Data
The number of large spills has decreased significantly recorded from 1970 to 2018 illustrate fluctuations in
over the last few decades and since 2010 averages the yearly values within a decade.
Module 2 – Number of large spills (>700 tonnes)
1970-79:
24.5 spills
35
per year on
average
30
25
1980-89:
Number of spills
9.4 spills
per year on
20
average
1990-99:
7.7 spills
per year on
average
15
2000-09:
3.2 spills
per year on 2010-18:
average 1.9 spills
10 per year on
average
0
1970 1973 1976 1979 1982 1985 1988 1991 1994 1997 2000 2003 2006 2009 2012 2015 2018
400
Thousand tonnes
ERIKA
20,000 Tonnes
HEBEI SPIRIT
11,000 Tonnes
100
0
1970 1973 1976 1979 1982 1985 1988 1991 1994 1997 2000 2003 2006 2009 2012 2015 2018
Figure 9: Quantities of oil spilt 7 tonnes and over (rounded to nearest thousand), 1970–2018
A part from a fall in the early 1980s during the
worldwide economic recession, seaborne oil
trade has grown steadily from 1970 (Figure 10). While
it is encouraging to observe that the downward trend
in frequency of oil spills continues despite an overall
increase in oil trading over the period.
Module 2 – Growth in Trade Vs Oil Spills
increased tanker movements might imply increased risk,
3500 140
Decline in Number of Tanker Spills
vs
3000 Growth in Crude, Petroleum and Gas loaded 120
2500 100
2000 80
OIL TANKER SPILL STATISTICS 2018
1500 60
1000 40
500 20
0 0
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
Number of spills >7 tonnes Total Crude Oil, Petroleum product and gas loaded (million metric tons) (Data source: UNCTADStat)
Figure 10: Decline in number of tanker spills vs growth in crude, petroleum and gas loaded
10
1990s
the decade 2000 to 2009 (196,000 tonnes) was spilt in 19%
2000s
3%
several single years in earlier decades. 2010s
3%
The total volume of oil lost to the environment recorded Figure 7: Oil spilt per decade as a percentage of the total spilt
in 2018 was approximately 116,000 tonnes, the majority between 1970 and 2018
Ship Owners
Charterer
Vetting Dept
Oil Cos’ own Shipping
Operations
Module 2-The Function of the Oil Company
Charterer
1. Charter most cost effective (aka Cheapest) freight where the
vessel meets all criteria i.e. vetting, marine assurance, credit, etc.
2. The Charterer will:
a. Make freight calls about the forward market (when traders
are doing spot deals & in anticipation of system cargoes)
b. Provide shipping market intelligence for traders, monitor what
competitors are doing.
c. Provide alternative freighting solutions
d. Provide chartering expertise and guidance to other parts of
the company
Module 2 – The Three Categories of Shipping Risk
1. Owned Vessels
a. Least risk
b. Greatest control
2. Time Chartered Vessels
a. Better than “Spot” but falls short of owning
3. Voyage “Spot” Chartered Vessels
a. Most Voyages
b. Greatest risk
c. Least knowledge of quality by charterer
Module 2 – Oil Majors
– Date of loading
– Cargo type
– Load port
– Discharge Port
– Account / Costs
Module 2-Typical Oil Company Charterer’s
Vetting Enquiry To The Internal Vetting System
Input Ship for Vetting :
lay can, load port , cargo
No Maybe
type, for whose account is
vl to be chartered
Discard or find
other ship Vetting &
Assurance Dept
Issues resolved
Voyage Performance OK?
Monitored
Resolve Issues with
Owners
Module 2 - Summary
160,000
140,000
120,000
100,000
80,000
60,000
40,000
20,000
0
2008
2014
2011
2005
2006
2007
2009
2010
2012
2013
2015
2016
2017
2018
Downloaded Submitted
Module 3 – The numbers
Administration Counts
Count Name
94 Submitting Members
1678 Sire Reports Submitted per month (avg from last 12 months)
498 SIRE Reports Submitted Per Month (avg from last 12 months)
9650 Sire Reports Purchased Per Month (avg from last 12 months)
797 Sire Reports Purchased Per Month (avg from last 12 months)
62 Sire Reports Purchased by Port States per month (avg from last 12 months)
0 SIRE Reports Purchased by Port States Per month (avg from last 12 months)
Module 3
Module 3
The Home page contains any open task messages and actions as well as access to other
useful
Modulepages.
3
Module 3
Validate Organisation Users
The operator
Module 3 reviews list of Organisation Users.
NEW: All vessels are now assigned a unique reference called OCIMF-ID. This can be
Module
viewed on3the Vessel Index page or Vessel Details page.
Here is a summary of each section of the vessel details page. Further details are
Once the particulars document has been created the details page will be shown as
below.
Module 3
Click the blue arrow to the right of the incident’s row to show the incident details page.
This area allows the ship operator to create and manage crew record for their vessels.
Selecting the “edit” button from the screenshot above (or the “create” button on first
use of the 3
Module crew matrix for a vessel) shows the crew matrix details page for the vessel.
The crew matrix screen separates officer and engineer crew on to two tabs as shown on
Module 3 - The SIRE Report Contents
Sect 3 All Questions answered “No” with Observations, or answered “Yes” WITH
Other comments and Chapter – End Additional Comments (if any)
Module 3 - The Delivered Report : Inspector Observations,
Other Comments and Additional Comments
• Whenever a question has a response from the inspector, the question is shown in
Section 3.
• Other Comments are “Value added”. They are provided to separate negative
Observations, from positive comments. They are shown in blue.
• Additional Comments at the end of each VIQ Chapter may be used to record
Observations that are not covered under any of the questions that are listed in the
Chapter.
Module 3 – Example – Section 2
Module 3 – Example – Section 3
34% Collision/conduct
24%
Misc/unknown
Grounding
Fire/explosion
13%
Hull & Machinery
9% 20% Tanker Safety and
Pollution Prevention.
The problem areas
relating to oil spills
Module 4 - Getting ready and staying ready
1. Conduct regular self – inspections using “Cold Eyes.”
2. Correct the shortcomings that are uncovered.
3. If shortcomings are known but not fixed, ensure that proof of Work in
Progress (WIP), Purchase Orders and corrective actions etc. are shown
to the inspector.
4. Ensure personnel are aware of the inspector’s expectations, responsible
officers must be able to understand and respond to questions from the
inspector.
5. Ensure all documents and equipment that the inspector wants to see, is
set out and ready for inspection, in the order that the inspector wants
to see it.
6. Discuss Sect 4. of the VIQ Intro
Module 4 - Understand the Rules of Engagement
• This is intended to save time and reduce the overall time the inspector
spends on board.
• Ensure that the person responsible ashore to keep the matrix up to date,
does so.
Module 4 - Overall Safety During SIRE Inspections
1. Ensure full PPE is worn at all times when
outside accommodation or in
machinery spaces.
2. If H2S or Benzene is present in the cargo,
make this known to the inspector
immediately on boarding.
3. Ensure ISGOTT Chapter 10 and OCIMF
guidance on entering encloses spaces
is followed TO THE LETTER.
4. Ensure that if any unusual situation
exists, this is fully explained PRIOR to the
commencement of the inspection.
(Even better if its done by email).
Module 4 – The theatrical Part
Module 4 – First Impressions
Moorings
• Are sufficient mooring lines deployed?
• Any mixed moorings?
• Condition of the mooring lines?
• Are synthetic tails are properly attached to
wires?
• If required by the terminal, are Emergency
Towing Off Pennants (ETOPs) correctly
rigged?*
*Note : OCIMF no longer recommend the use of
ETOPs. All questions relating to ETOPs have been
removed from the VIQ.
Module 4 – Boarding
• It is safe enough to permit the inspector to
proceed?
• Is the gangway rigged correctly, with
stanchions and manropes in place?
• What does it comprise?
• Unless a shore gangway is used, a safety net
should be fitted (5.47)
• Are a heaving line, lifebuoy and light
available?
• Is the “No Visitors” notice posted where it can
be seen from the shore?
• Does it state “No Photography”?
18.2.3
Gangways and other access equipment should not be rigged on ships rails unless the
rail has been reinforced for that purpose. They should comply with the guidance in
Annex 18.1
Module 4 – MSC.1/Circ.1331
MSC.1/Circ.1331
11 June 2009
3.3 Lifebuoy
A lifebuoy equipped with a self-igniting light and a buoyant lifeline should be
available for immediate use in the vicinity of the embarkation and
disembarkation arrangement when in use.
Module 4 – Coming on Board
Security
• Have a reliable rating on duty
• Ensure that the gangway is manned
• Equip the gangway watchman with a
walkie-talkie
• Ensure that the gangway watchman
challenges the inspector
• He must :
– Ask for SIRE ID
– Ask the inspector to sign a Visitor’s Book
– Provide the inspector with an Emergency
Stations Card
– Ask to see inside the inspector’s bag
– Ask to check inspector’s mobile phone is switched off
Module 4 – First Impressions – The walk to the
accommodation • Are all dipping / sampling points closed ?
• Is small spill clean-up equipment provided near
manifold?
• Are fire hoses rigged in vicinity of manifold?
• Are bolts inserted into all the manifold flanges?
• Are all unused manifolds blanked / fully bolted?
• Is the manifold drip tray free of oil?
• Are pressure gauged fitted outboard of the
manifold valves?
• Are all scupper plugs in place and tight?
• Are scuppers free of rainwater?
• Are portable pumps rigged for immediate use
at aft end of main deck?
Module 4 – Problems ahead?
The inspector has been on board for only a few minutes, he has not
yet met the Master, but … what he has already seen is important
Inspector Observations: Pod storage place located next to the oven was found to have fatty
deposits which could represent a fire hazard.
Initial Operator Comments: The mentioned stainless steel pot storage place was thoroughly
scrubbed and cleaned the same day (see attached photo). Meantime, the vetting
observations were discussed in the Safety Committee Meeting on 29 Sep 2018 to good order for
all crew awareness to prevent such a recurrence (see attached). A verbal warning was given
to catering staff by the Master and reminded them that proper housekeeping and cleanliness
in there area of responsibility must be observed at all times. A Near Miss Report was created to
prevent reoccurrence of such practice and to improve proper housekeeping in general (see
attached report).
Module 4 – Internal Accommodation
5.9 Are the officers and ratings aware of the requirements of the ISGOTT Ship/Shore Safety
Check List (SSSCL) and are the provisions of the check list being complied with?
Inspector Observations: Cigarette lighters were observed in the crew smoke room and Suez
canal boatman’s cabin. The door to the crew smoke room was open, as was door to main cross
alleyway, therefore only one door separating outside and smokers.
Initial Operator Comments: This is a gross negligence on the part of ship staff. Ship staff has been
reprimanded and a Circular sent out to the whole Fleet reminding all concerned of dangers
and prohibition of carriage of matches and lighters through terminals which may result in severe
penalties in case of non-compliance. Fleet personnel dept. has been requested to obtain an
affidavit from all on-signers that they will not be carrying cigarette lighter on any ship at any
time. Masters have been requested to hand – over printed hard copies of Company’s safety
requirements to all visitors boarding any of NITC ship.
Module 4 – The Pre- Inspection Meeting
Who attends the opening meeting?
Agenda
1. The order of the inspection. (Docs,
wheelhouse, external etc.)
2. What equipment does the inspector want to
see operating?
3. What ballast tanks does he want to sight from
the deck?
4. Are there any unusual conditions that need to
be pointed out?
5. Are there defects that exist which will be seen
by the inspector?
6. Discuss Section 4 of the VIQ Intro and recap
inspector’s responsibilities.
1. The inspector must introduce themselves to the Master or the Master’s authorised deputy, explain the
scope of the inspection and discuss the preferred order in which it will be carried out, prior to
commencement of the inspection. Inspectors should co-operate fully to conduct the inspection in the order
that will cause the least disruption to the vessel’s operations. The inspector must be accompanied by a
member of the ship's staff at all times during the course of the inspection.
2. Inspectors may, on occasion, have observers with them during an inspection. Where the inspector has an
observer accompanying them, the inspector must introduce the observer to the Master at the same time
and in the same manner as they introduce themselves. Inspectors must clarify the extent and scope of the
observer’s role during the inspection.
3. The inspector must set a good example with respect to their communications, behaviour and own
personal safety procedures whilst on board the vessel and in the terminal and must wear appropriate
personal protection equipment at all times.
Module 4 – SIRE Provisions
4. Electrical or electronic equipment of non-approved type, whether mains or battery powered, must not be
active, switched on or used within any gas-hazardous or other hazardous areas. This includes torches, radios,
mobile telephones, calculators, computers, photographic equipment and any other portable equipment that
is electrically powered but not approved for operation in a gas-hazardous area. It should be borne in mind that
equipment such as mobile telephones and smart watches, if switched on, can be activated remotely and a
hazard can be generated by the alerting or calling mechanism and, in the case of mobile telephones, by the
natural response to answer the call. Any specific Terminal requirements must be adhered to.
5. Any Observations that the inspector intends to record in the VIQ must be pointed out and discussed ‘on site’
at the time with the member of the ship's staff assigned to accompany the inspector. This ensures that the
nature of the Observations are fully understood and can also avoid extended discussion at the end of the
inspection.
6. On completion of the inspection, some Submitting Companies require the inspector to provide a list of the
inspection findings in the form of written observations, others do not. In either case, the inspector must discuss
the inspection findings with the Master or the Master's authorised deputy before leaving the vessel. Other than
to prepare these observations, however, the inspector must not remain on the vessel to complete the
inspection report. It is recognised that on occasions this may not be possible, especially when leaving and
joining the vessel is done by helicopter on vessels doing STS operations.
Module 4 – SIRE Provisions
7. It is recommended that the inspection be completed in about 8 to 10 hours (refer section 4.3.5). It is also
expected that documentation checks carried out as part of the inspection should not exceed 3 hours. All
other time onboard should be used to conduct the inspection of the vessel, interact with crewmembers,
compile the observation list if appropriate, and conduct the close out meeting. The completion of the report
using the report editor software before the inspector leaves the vessel must not occur as this reduces the time
that the inspector will spend conducting the physical inspection of the vessel. As specified in section 4.1.1.6,
the inspector must leave the vessel on completion of the inspection and must not remain on board to
complete entering the report details into the report editor.
8. The time of 8 to 10 hours specified in section 4.3.5 is guidance, however the actual time taken to complete
the inspection may differ. All inspectors must take into account their own rest hours including travel time and
fatigue levels when conducting inspections. ‘Back to back’ inspections are discouraged, and inspectors
should complete and submit the report for one vessel before commencing an inspection on another vessel.
Module 4 – SIRE Provisions
4.3 Other Inspection Requirements
1. Ship inspections shall not be conducted at night unless requested by the OCIMF Inspecting
member. The vessel’s operator must also concur that it is safe to carry out a night inspection and
that this will not negatively impact the vessel’s compliance with work and rest hour requirements.
2. Inspectors shall limit advance communications with vessels and vessel operators to that
information necessary to arrange access and appropriate arrival to and from the vessel, or to
communicate intended inspection plans. Inspectors shall not request information concerning the
VIQ in advance of their arrival to a vessel. Inspectors shall not communicate with the vessel or
vessel operator after completion of OCIMF inspection activities. Following an inspection all
communication concerning the inspection shall be managed by the commissioning member.
3. The inspector should consider requesting that equipment be run and tested to confirm that it is in
operational order and that officers and crew are familiar with its operation. The inspector must
ensure that such requests do not cause delay or interfere with the safety and normal operation of
the vessel and do not contradict any terminal requirements.
4. It should be recognised that the overall objective of the inspection is to provide the user of a SIRE
Report with a factual record of the vessel’s condition and standard of operation at the time of
the inspection and, in turn, allow an assessment of the risk that use of the vessel might pose
Module 4 – SIRE Provisions
5. A SIRE inspection is expected to be accomplished within an 8-10 hour period. The inspector
must plan their time accordingly and make sufficient allowances to have this period of time
available for the inspection. Inspectors must take into account the hours of rest requirements
for the vessel’s staff that must be observed and ensure that the SIRE inspection does not
interfere with these.
6. Under normal circumstances, a SIRE inspection will take place when a vessel is alongside in
port whilst discharging or loading cargo. During the course of the inspection entry into ballast
tanks and/or /void-spaces is discouraged. Assessment of the physical condition of ballast
tanks/void spaces etc. can be made only in circumstances where the access hatches or
plates can be removed, and the internals sighted from the deck. In any event, actual entry
should only be made following specific written request from the inspecting company, with
the authority of the Master and provided that port and terminal regulations allow it. In all
cases, the enclosed space entry procedures set out in ISGOTT Chapter 10 must be strictly
observed.
7. Travel for ship inspections on behalf of OCIMF member companies must, at all times, be
conducted in a safe manner with due regard to industry best practice and any agreements
between the inspector and member companies. Inspectors must ensure that they are able
to safely conduct an 8-10 hour inspection without undue fatigue.
Module 4 - Summary
• Understand and ensure that the inspector follows the expectations set out in the
introduction (Sect 4) to the VIQ
• Remember what the inspector is, and is not, allowed to do
• Make sure that the “First Impressions” are favorable
• Ensure that the gangway watch when the inspector boards and that he knows how
to deal with the inspector
• Ensure the accommodation atmosphere is under positive pressure
• Have all senior officers present for the pre-inspection meeting
• Get a clear understanding of what the inspector wants testing
• Change the route of the inspection if necessary
Module 5 – Certificates and Documentation
Module 5 – Documents and Certificates
VIQ 2.1
Are all the statutory certificates listed below, where applicable, valid and have the annual and
intermediate surveys been carried out within the required range dates?
2.1.1 Certificate of Registry
2.1.2 Continuous Synopsis Record
2.1.3 Document of Compliance (Doc)
2.1.4 Safety Management Certificate (SMC)
2.1.5 Safety Equipment Certificate, supplemented by Form E Set out
2.1.6 Safety Radio Certificate, supplemented by Form E certificates
2.1.7 Safety Construction Certificate
exactly as they
are listed in 2.1
2.1.8 IOPP Certificate, supplemented by Form A or B Statement of Compliance supplement
of the VIQ
2.1.9 What is the vessel’s designation as recorded in the IOPP Certificate, Form B, Question
1.11?
2.1.10 Minimum Safe Manning Document
2.1.11 Certificate of Fitness for the Carriage of Chemicals or Gas
2.1.12 Noxious Liquid Substances (NLS) Certificate
2.1.13 Civil Liability Convention (1992) Certificate
2.1.14 Name of P and I Club
Module 5 – Documents and Certificates
Note: Inspectors should review the number of personnel on board against the vessel’s trading pattern and
level of operation and should consider issues such as whether:
• The bridge is being adequately manned under all sailing conditions;
• There are sufficient personnel to moor the ship safely;
• The cargo operation is being effectively controlled (if two deck officers alternate the cargo watches, is
the second officer adequately experienced and qualified and are ratings
sufficiently familiar with the operation);
• Safety functions are being adequately addressed (drills, ship security issues, equipment maintenance);
and
• The quality of rest is adequate considering the trading area and the workload.
Module 5 – Key Questions in the VIQ Relating to Hours of Rest
3.2 Are the STCW and flag Administration’s regulations that control hours of
work to minimise fatigue being followed and are all personnel maintaining
hours of rest records in compliance with MLC or STCW requirements?
Module 5 – Key Questions in the VIQ Relating to Hours of Rest
The “Anomalies” between MLC 2006 Hours of Work and STCW 2010 Hours of Rest
Calculations. (VIQ 3.2)
At the flag Administration’s option, these may be calculated under two formulas,
relating either to Hours of Work or Hours of Rest. The resulting stipulated minimum
hours of rest are not the same.
Under the hours of work calculation, the maximum hrs of work shall not exceeded
14 in any 24 hrs period and 72 in any 7 day period.
Under the Hours of Rest calculation, a seafarer must have at least 10 hrs rest in any
24 hrs period and 77 hrs in any 7 day period.
Inspectors must therefore ascertain under which formula the vessel is obliged to
comply, to confirm that the mandatory hours of rest, or hours or work are being
observed when responding to Question 3.2
Module 5 – Key Questions in the VIQ Relating to Hours of Rest
Minimum restrictions include that the Hours of rest :
May be divided into no more than two periods, one of which shall be at least
6 hours in length, and the intervals between consecutive periods of rest shall
not exceed 14 hours.
Musters, fire-fighting and lifeboat drills, and drills prescribed by national laws
and regulations and by international instruments, shall be conducted in a
manner that minimizes the disturbance of rest periods and does not induce
fatigue.
Module 5 – Master’s Overriding Authority
Nothing shall be deemed to impair the right of the master of a ship to require a seafarer to
perform any hours of work necessary for the immediate safety of the ship, persons on board
or cargo, or for the purpose of giving assistance to other ships or persons in distress at sea.
Accordingly, the master may suspend the schedule of hours of rest and require a seafarer
to perform any hours of work necessary until the normal situation has been restored.
As soon as practicable after the normal situation has been restored, the master shall ensure
that any seafarers who have performed work in a scheduled rest period are provided with
an adequate period of rest.
Module 5 – Master’s Overriding Authority
If the Master is exercising his rights to Overriding Authority, a clear entry that
records the circumstances must be made in the ship’s log book.
This must be shown to port State, flag State or SIRE Inspectors who uncover
what appear to be hours of Rest irregularities.
Module 5 – Comparisons between MLC2006 and STCW 2010
Regulation Work/Rest in any Work/Rest in 7 No. and Length of rest periods Schedule Records and
24 hrs days exceptions
ILO 180/MLC Max 14 hrs of work Max 72 hrs of work Not more than 2 periods of rest, one Specific format Daily hours records to
2006 Or Or of which must be at least 6 hrs. table for all be maintained.
Min 10 hrs of rest Min 77 hrs of rest Interval between rest periods not to seafarers.
exceed 14 hrs Competent authority
Actual times for at may allow exception
sea in the port if by collective
agreement
STCW 2010 Min 10 hrs of rest Min 77 hrs of rest Not more than 2 periods of rest, one Specific format Daily hours records to
(Manila of which must be at least 6 hrs. table as ILO, but be maintained.
amendments) Interval between rest periods not to watchkeeper and
exceed 14 hrs safety pollution / Parties may allow
security positions exceptions.
only
Module 5 – Comparisons between MLC2006 and STCW 2010
//Parties may allow exceptions//
Day 1 2 3 4 5 6 7 8 9 10 11 12
1 2 3 4 5
Rest Hours 13 13 13 13 13 13 13 10 10 10 10 11
Last 7 days 91 88 85 82 79 77
Module 5 – Remember Anomalies between STCW and MLC2006
Does keeping records for both makes things easier
when dealing with SIRE?
ILO MLC rules on record keeping that every seafarer
hours of rest / work should comply with the rule :
(a) maximum hours of work shall not exceed:
(i) 14 hours in any 24 – hour period; and
(ii) 72 hours in any seven – day period; or
(b) minimum hours of rest shall not be less than:
(i) ten hours in any 24-hour period; and
(ii) 77 hours in any seven-day period.
Module 5 – Doing the math!
• 1 day (24hrs) minus Min of 10 hours of rest minus Max 14 hours of work
= ZERO hrs
• 1 week (7X24=168 hrs) minus Min 77 hours of rest minus Max 72 hours
of work leaves a balance of NINETEEN (19) hours.
In this calculation you lose/gain: 19 Hrs.
• The obvious result from the above is than in case you need to fully
comply with BOTH STCW and MLC plus minimizing the liability of false
record keeping you need to keep records of hours of rest ONLY!
Module 5 – Hours of work – The Shell Position (20 Feb 2012)
From the 1st of Feb. 2012 Shell International Trading and
Shipping Co Ltd (STASCO) has raised the risk level from
Ship Inspection Report Exchange (SIRE) inspection
observations relating to hours of work, specifically
questions 3.2 and 3.3 of the Vessel Inspection
Questionnaire (VIQ 6 - 2014). You should also be aware
that significant non-conformance or evidence of
record falsification may lead to vessels being deemed
unacceptable for Shell Group use.
Module 5 – The OCIMF Recommendation
It should be ensured that, at any time during
the working period, in the past 24 hours the
seafarer should always be in compliance with
the requirements. The seafarer should have
had a minimum of 10 hours rest which was
divided into no more than 2 periods, one of
which was of a minimum of 6 hours.
Module 5 – STCW Hours of rest compliance …. either difficult or
impossible (1)
The actual Manning level aboard and trading pattern of the vessel is
key
• Accuracy in the completion of the Hours of Rest Log
• Documents that may be reviewed to check the accuracy of the
Hours of Rest Log:
– Oil Record Books Parts 1 and 2 (Engine & Deck – if an oil tanker)
– Enclosed Space Entry Permits & Entry Logs
– Log Book Entries for port entry / Departure and Mooring / Unmooring Ops
– Tanks Washing – details of wash times
– Purging, Gas freeing and re-inerting
– Records of Drills – if outside normal work hours, are they logged?
– ISPS Compliance.
Module 5 – Hours of rest compliance (2)
• Manning Levels
– Two or three deck officers will arouse suspicion
– If manning is at, or close to the minimum as stated in the Minimum
Manning Department.
– Vessels Operating under UMS at or close to the stated MMC levels.
Inspector observations :
Some of the hour of rest records were inaccurate, showing that staff
worked same hours everyday, i.e. Bosun and Pumpman working eight hours
daily without overtime.
Deck department forms had not been completed by head of department
inputting totals as required by the form.
Initial Operator Comments : This is a mistake on the part of ship staff. Master,
officers and crew are briefed about the importance of accuracy of rest
hours records. Departmental Heads are advised to be careful while
reporting rest hours.
Module 5 – General Paris MOU findings following CIC 4Q 2010
relating to work /rest hours
• Hours of rest not being complied with in port resulting in
watch keepers on duty for departures and first sea
watches not being adequately rested;
• Records of hours of work/rest are not being maintained;
• Records of hours of work / rest do not reflect the actual
working arrangements; and
• The Safety Management System of the ship is deficient in
ensuring compliance.
Module 5 – Hours of Rest - Conclusions
• Logs are being completed by a single person – not by the individuals
concerned.
• Many people assume a 00-24hr day is used – this is not the case. STCW
uses the term, “ In any 24 hour period”
• Most entries are simply fictitious and errors are easily able to be detected
!!!
• Port State and Oil Cos are taking a much harder line where non-
compliance is uncovered.
Module 5 – Specialized Training requirements in the VIQ
3.6 Are those officers who have immediate responsibility for cargo transfer, in possession
of the Certificates of Specialized Training as applicable to the type of cargo being
carried?
Note : The term "Person with immediate responsibility" as used in paragraphs 3 and 5 of
regulation V/1-1 and paragraph 3 of regulation V/1-2 means a person being in a decision
making capacity with respect to loading, discharging, care in transit, handling of cargo,
tank cleaning or other cargo related matters". (STCW Code B V-1).
It is interpreted that a 'Person with immediate responsibility' includes all watch keeping
officers in charge of cargo related operations whether the vessel is at sea or in port. This
includes 2nd Officer, 3rd Officer, 4th officer, Gas/Cargo engineer.
It should be noted that persons with immediate responsibility may include pumpman and
other ratings engaged in direct supervision of the cargo operation.
Module 5 – Certification and documentation (1)
• General information for Chapter 1 of the VIQ should be taken by
the inspector from original documents – not the HVPQ
• Inspector should cross – check the HVPQ for accuracy
• Operator’s Policies and Operating Procedures Manuals
• Class Condition Survey files
• Enhanced Survey Program (ESP) files
• Condition Assessment Scheme (CAP) if applicable
• IOPPC with Part A or B
• Oil Record Books (Both Part 1 and Part 2 checked at same time)
• Garbage Management Books
• Annex VI Logs
Module 5 – Certification and documentation (2)
• Nautical Publications Library – usually checked during wheelhouse
inspection.
• Crew overtime logs
• Crew licenses and records of sea service
• Drug and alcohol policy and records of unannounced drills and
attendance by shore testing Company.
• Safety management meetings
• Minutes of safety meetings, actions, follow-up and close-out
• Records of drills, training and familiarization (Paper records vs Reality)
• Near-Miss reports and actions
• Health and Safety committee Meeting minutes and actions.
• Record of Visits by Operator’s Superintendent
Module 5 – Certification and documentation (3)
Important :
Inspectors should review the Condition Evaluation Report and
Executive Summary
(Operator initiated manual collections where oil residues (sludge) is transferred into the oil residue (sludge)
holding tank(s)
*tanks listed in item 3.1 of forms A and B of the international Oil Pollution Prevention (IOPP) Certificate, and
only these tanks. Other tanks and bilge water should be included under a different heading.
Manual collection should be recorded when they occur and separate to the weekly ROB sludge records.
Module 6 – Entries relating to the use of the Oily Water
Separator
Example 1: Disposal of bilge water overboard via 15ppm equipment
Date Code Item Record of operations / Signature if officer in charge
12/Dec/2018 D 13 2.5m3 of bilge water from Dirty Bilge Tank, capacity 27m3, 14,3m3 retained
Signed :
Note : Code I entries for the unsealing and re-sealing of the overboard valve will also be required as detailed below.
Module 6 – Voluntary entries under Code 3.3
Example 5: Voluntary weekly declaration of bilge tank retention quantity.
Date Code Item Record of operations / Signature if officer in charge
12/Dec/2018 I Weekly inventory of Bilge Water Tank(s) (listed under item 3.3)
Signed :
Note : This item should be recorded every week directly after the weekly record of items under Code C 11.1/C 11.2/C 11.3
for oil residue (sludge) tank(s) in section 3.1 of Form A (or B).
Module 7 – Wheelhouse, Navigation &
Communication
Navigation Policies, Logs and Records, Condition of Equipment, Officers’
Competence
Module 7 – C/S Costa Concordia – 13 Jan 2012
Clipperton Island
BA Chart 4802
United States
and Mexico
Module 7 – The Case of M/S “Oliva”
First impressions
• Company policies
General
The Master must understand that nothing contained in this chapter is to be construed
in any way to relieve him of his full responsibility for the safe navigation of his ship and
the efficient organisation on board.
The Master has overall responsibility for the safe operation of his vessel in accordance
with flag state laws and international regulations. Under no circumstances is
commercial pressure to justify the taking of an unnecessary risk. The Company will
support a decision taken by a Master in good faith and in the interests of safety.
Module 7 – Company’s Standing Orders
4.1 Are the deck officers’ familiar with the Company navigation procedures and instructions and are the Company
navigation procedures comprehensive?
Inspector Observations : Company Marine Operations Manual (Section 1-02-02-4) required for Master to be called at 4nm if
restricted visibility encountered. Masters standing orders noted as requiring call at 3nm in congested waters and 2nm in open
waters.
Other inspector Comments: During close out meeting Master acknowledged the conflicting situation and reported he had
updated his standing orders to be in line with company directions.
Initial Operator Comments : Root Cause;
Company procedure has been noted to be contradictory as regards Master’s standing orders in that the procedure makes
specific requirements while the specimen Standing Orders appear to give the Master feeway to use his own experience for
Standing orders appear to give the Master feeway to use his own experience for setting minimum call out ranges for reduced
visibility. The Master had used his own experience and judgment to assess calling out distances that were suitable to him
based on his experience in ships of this size and speed overlooking the procedural requirement.
Correction :
This was corrected on the spot and the revised Standing Orders printed out and signed by the Bridge officers as per the
attached.
Action to prevent reoccurrence :
A proposal has been made to Group to revise the company specimen Standing Orders, MAROPS 001, to bring these into line
with company procedures. In addition relevant procedure s are also proposed for inclusion. Pending issue of the proposed
revision a local instruction has been issued to the fleet to clarify the point.
Attachment : Extract master standing orders.
Module 7 – Master’s Bridge Order Book
Q . Are Bridge Orders made by the
master every day when the vessel is at
sea and when at anchor?
Initial Operator Comments : The end of sea passage position was clearly
marked on the chart and anchor position detail was kept in a separate log in
detail, but we make sure to correct procedure shall be followed in future as
per required. We intend to dispatch our head marine superintend to verify
and make sure all officer are familiar.
Module 7 – The Standard Magnetic Compass
• Easy of viewing
• Lighting
• Clarity of Lens
• Compass heading
• Comparison with
Steering Gyro
• Magnetic Compass
Repeater
Module 7 – Adjustment of the Magnetic Compass
4.9 Are the Standard Magnetic and Gyro compasses in good order and is the OOW aware
of the requirements for taking compass errors and is the compass error book maintained.
The compass shall be adjusted if a period of two years has elapsed since the last
adjustment and a record of compass deviations has not been maintained, or the
recorded deviations are excessive or when the compass shows physical defects.
Magnetic and gyro compass errors should be checked and recorded each watch, where
possible, using either azimuth or transit bearings. A deviation card for the magnetic
compass should be maintained and be available to the Bridge Team. (5th edition BPG
4.3.4)
Q. What is the permitted time interval when magnetic compass need to be adjusted ?
Q. What is the maximum allowable tolerance between the actual deviation and the
deviation recorded on the Deviation Curve?
Module 7 – The Magnetic / Gyro Compass Comparisons
• Magnetic compass deviation should “broadly agree” with
the curve
compartment
• Parallel indexing;
• Chart changes; T&P Notices logged and recorded on charts
• Methods and frequency of position fixing;
• Prominent navigation and radar marks;
• No-go areas (DO NOT USE EXCESSIVE SHADING);
• Landfall targets and lights;
• Clearing lines and bearings;
• Transits, heading marks and leading lines;
• Significant tides or current;
Module 7 – Passage planning information.
Notes : At least two methods of position fixing should be charted, where possible.
Visual and radar position fixing and monitoring techniques should be used whenever
possible. GPS derived positions should always be verified by alternative methods.
The frequency of position fixing should be such that the vessel cannot run into danger
during the interval between fixes.
Module 7 – Pilot Card
4.3 Are procedures in place for the testing of bridge equipment before arrival / departure and
check-lists in effective use for pre-arrival, pre-departure, watch handover and master-pilot
exchange?
Inspector Observations: Limitations related to maximum permissible bollard pull exerted by tugs
used during berthing/un-berthing operations did not form part of Master to Pilot exchange
information.
Initial Operator Comments: Master confirms that same has been included in the pilot exchange
information.
Module 7 – The SIRE VIQ questions relating to ECDIS
3.7 If the vessel is equipped with an Electronic Chart Display and Information System (ECDIS) have the
Master and deck officers undertaken both, generic training and type-specific familiarisation on the system
fitted onboard?
Notes: ECDIS phase in started on 1st July 2012, if a fully operational ECDIS is fitted, but paper charts are
retained as the primary source of navigation (stated on Form E of the SEC), then all watch keeping officers
must have both generic training and type specific familiarization. (Type specific familiarization is not required
if the Generic training was conducted on the same unit as fitted on board).
Notes : The 2009 SOLAS Amendments mandate the carriage of ECDIS and effective 1 July 2012, new
tankers > 3,000 gt, ECDIS must be fitted not later than the first survey on or after 1 July 2015.
Operators must be aware of the fundamental changes in navigation that take place with the use of ECDIS
and a program should be in place to ensure that the transition is smooth, equipment installed and masters
and all bridge watch keepers properly trained.
Such training must be both generic and specific to the ECDIS equipment that officers will use.
Module 7 – The SIRE VIQ questions relating to ECDIS
ECDIS training must be incorporated into the company’s
SMS for the use of ECDIS in accordance with paragraph 6.5
of the ISM Code and deck officers must be fully familiar with
the operation of ECDIS prior to the first voyage after the
installation of ECDIS in accordance with paragraph 6.3 of
the ISM Code.
The full functionality of ECDIS cannot be achieved when operating in the raster chart display (RCDS) mode
and thus the system should always be operated in ECDIS mode
ECDIS that is not updated for the latest version of the International Hydrographic Organisation (IHO)
standards may not meet the chart carriage requirements set out in SOLAS V Reg 19.2.1.4 The list of current
standards is maintained on the IHO web site www.iho.int
Data input from the gyro compass, speed log, echo sounder and other electronic equipment should be
periodically monitored to ensure accuracy.
Module 7 – ECDIS questions from the inspector
Questions can be same as if checking Paper charts
The officer accompanying the inspector must be able to demonstrate the controls, features
and functions without hesitation and unnecessary browsing through the drop-down menus
Questions will likely address issues regarding:
• Position fixing intervals
• Manual plotting of RADAR positions, and
• How do you plot visual positions on the ECDIS?
• How do you set min depth contour?
• The contour and depth alarms history may be checked at the same time.
The inspector is likely to ask for a demonstration on how regular updates/chart corrections are
carried out, specifically regarding T’s & P’s procedure as this is not consistent among
manufacturers and at the present time, cannot be done automatically with the provision of
weekly updates from the supplier.
Module 7 – Radio Navigational Warnings
Module 7 – Bridge Publications (1)
• Bridge Procedures Guide
• Collision Regulations
• Bridge Team Management
• Ships Routing
• International Code of Signals
• International Aeronautical and Marine Search and Rescue Manual (Vol III)
• Peril at Sea and Salvage
• Guide to Helicopter and Ship Operations
• Recommendations for oil tanker manifolds and associated equipment
• Inert Gas Systems
• Crude Oil Washing Systems
• SOLAS Consolidated Edition
• International Life Saving Appliances Code
• International Code for Fire Safety Systems
• International Ship and Port Facility Security Code (ISPS Code)
• International Safety Management Code (ISM Code) and Implementation Guidelines.
Module 7 – Bridge Publications (2)
• International Standards on Training, Certification and Watch keeping for seafarers
• Guidance Manual for Tanker Structures
• Guidelines for the control of drugs and alcohol on board ships Guidelines on Fatigue
• It is recommended that the publication “The Human Element, a guide to Human Behavior in
the Shipping Industry” published by the UK MCA be carried on board to add further
guidance on the issue of fatigue. This question is not to be marked “NO”, if this publication is
not carried.
• Mooring Equipment Guidelines (3rd Ed)
• Recommendations for Equipment employed in the Bow Mooring of ships at single point
moorings
• Anchoring Systems and Procedures
• MARPOL 73/78 Consolidated Edition
• Guidelines for the implementation of MARPOL Annex V
• ISGOTT
• Ship to Ship Guidelines (Petroleum)
• USCG CFR 33 Parts 1-124
• USCG CFR 33 Parts 125 – 199
• USCG CFR 45 Parts 1-40
Note : These tests and checks ensure exact compliance with the specific requirements of both the GMDSS
Logbook Annex and ALRS Volume 5 (as corrected).
Module 7 – Voyage Data Recorder (VDR)
Recovery of VDR Data
Evaluations of VDR data taken from vessels following accidents provide invaluable evidence on
how vessels normally operate away from the scrutiny of company officials.
Reluctance to follow procedures, and complacent attitudes, can be identified and addressed by
monitoring the activities of ship staff during random audits of VDR data.
• EU directive 2009/18/EC7 not only encourages the use of VDR data for accident investigation but
also as a preventative tool.
• The directive advocates the routine examination of VDR data by ship managers to gain
experience of the circumstances capable of leading to accidents or incidents
• Such examination will provide them with incontrovertible information on watch keeping
standards under normal operating conditions.
Module 7 – The VDR as a navigational audit tool – How it works
Operator instructs the vessel to save VDR data for a specific port call.
This is sent to the office for audit purposes.
Data is reviewed by the office for:
• The audit checks if the vessel’s speed and course were consistent with conditions.
• Voice communications were formal and properly carried out,
• Master / pilot relationship was correct,
• Master demonstrated guidance to the bridge management team,
• The Master and watch keepers worked as a team
Module 7 – Portable GMDSS VHF Radio
SOLAS III/6.2.1
When alongside a terminal or port area where hydrocarbon gases may be present, either the AIS
should be switched off or the aerial isolated and the AIS given a dummy load. Isolating the aerial
preserves manually inputted data that may be lost if the AIS is switched off. If necessary, the port
authority should be informed.
When alongside terminal or port areas where no hydrocarbon gases are likely to be present, and if the
unit has the facility, the AIS should be switched to low power.
If the AIS is switched off or isolated whilst alongside, it must be reactivated upon leaving the berth.
The use of AIS equipment may affect the security of the ship or the terminal at which it is berthed. In
such circumstances, the use of AIS may be determined by the port authority, depending on the
security level within the port.
Module 7- Automatic Identification Systems (AIS)
Module 7- Use of AIS When Alongside a Tanker Terminal in USA
AIS Guidance was issued with the attached Coast Guard message, on the “AIS FAQ’s web page” at
https://www.navcen.uscg.gov/?pageName=AISFAQ#6. In paragraph 6 it says:
Per 33 CFR 164.46(d), vessels required to have AIS must operate it in U.S. navigable waters (as defined in 33 CFR 2.36)
at all times that the vessel is navigating (underway or at anchor) and at least 15 minutes prior to unmooring. Should
continual operation of AIS compromise the safety or security of the vessel or where a security incident is imminent,
the AIS may be switched off. This action and the reason for taking it must be reported to the nearest U.S. Captain of
the Port or Vessel Traffic Center and recorded in the ship's logbook. The AIS should return to continuous operation as
soon as the source of danger has been mitigated. Note, vessels equipped with AIS--either by mandatory carriage or
voluntarily--must abide by the requirements set forth in 33 CFR 164.46 which state an AIS must be: properly installed,
use an officially assigned MMSI, that its data be accessible from the primary operating position of the vessel, and,
always be in effective operating condition; which entails the continuous operation of AIS and the accurate input
(see USCG AIS Encoding Guide) and upkeep of all AIS data parameters. Although Coast Guard AIS authority (46 USC
70114) does not extend beyond U.S. navigable waters or to all voluntary users, mariners are reminded that
Navigation Rule 7 requires that every vessel use all available means to determine risk of collision. AIS is one of the
most effective means currently available, particularly when coupled with radar and sight, to not only determine the
risk of, but, also mitigate collisions. Thus the Coast Guard exhorts all AIS users to maintain their AIS in effective
operation, at all times.
Module 7- Annual Testing of AIS
• Installation details
• Antenna layout
• Initial configuration
• Interconnection drawings
Communications
Log :
A summary of communications
relating to distress, Urgency,
and safety.
This must include dates and
times and the names of the
vessels involved.
Details of weekly testing of the
GMDSS
Module 7- GMDSS Radio Log Book Entries
A record of important incidents relating to communications :
• Breakdown of radio equipment
• Breakdown of communication with coast stations or satellites
• Adverse propagation conditions, (Ionospheric, static or other interference)
• Serious breaches or radio procedures by other vessels.
If there are no incidences of the above, write the word “None” for every day when at sea
Distress related messages received in hard copy should be appended to the log. No need to retain
weather or navigation warnings
“The escape routes are routes for escape and also for access. Accordingly the locking arrangement should be such
that it does not obstruct these two objectives (escape and access). Doors along any designated escape routes
which require keys to unlock them when moving in the direction of escape should not permitted”.
2.6 The UK interpretation of SOLAS is that all doors on all escape routes must be accessible in both direction in an
emergency.
Module 8- Navigation Lights
4.8 Are navigation lights in good order, the OOW aware of the procedures for testing the lights and actions in event of
failure?
Inspector Observations: It was noted that the starboard navigation light (upper unit) had the arc of visibility screen set
incorrectly. It was set to be visible from approximately 4 points on the port bow through to 2 points forward of the starboard
beam. It appeared that the screen had been wrongly fitted by about 4 points at some unknown time in the past. An
attempt to move the screen was made but it required further attention, this was rectified and confirmed set correctly the
following morning.
Initial Operator Comments : Investigation revealed that the sidelights meet the rules to cover an arc of the horizon, or
sector, of 112.5 degrees. Sidelight fixtures must be installed parallel with the fore and aft centerline of the vessel and
arranged to show an unbroken light from right ahead to 22.5 degrees abaft the beam, a total sector arc of 112.5 degrees.
It appears that the upper starboard light was slightly out of line (one point inboard). By means of checklist Annex 2 “
Preparation for Sea” as part of the company bridge procedures. Chapter 5 – the navigation lights needs to checked before
departure. It is unclear why the upper starboard light was not in line with the other light and why this was not noticed during
the many inspections the vessel undergoes. It is clear that the above mentioned checklist is not enough if the navigation
lights are in compliance with the colreg’s. The upper green sidelight has been refitted and completely in line with the other
navigation sidelight and in compliance with COLREG’s Annex I. An additional maintenance job will be created to ensure
the correct alignment of navigation lights in general. All other navigation lights are inspected and no other irregularities
found.
Module 8- Air Cylinders
17.4.3.1 Side ropes and manropes must be made of good quality manila or other material of equivalent strength,
durability and grip which has been protected against actinic degradation. The acceptance of polypropylene rope
in place of manila is conditional on:
I. The rope being approved in accordance with the relevant BS EN standard (Appendix O) for use in Life Saving
Appliances.
II. Identifying tape being incorporated
III. The rope having a grip compatible to manila
IV. The seizing being of a compatible material which has good resistance to abrasion and ultra violet light (Natural
fibers such as tarred marine are generally found to be unsuitable).
17.4.3.2 The side ropes are required to be continuous with no joins below the top step and the bottom step to ensure
that persons using them as hand holds are not faced with changes in diameter from splices, shackles etc.
The method of securing the two ropes on each side below the bottom step should be adequate e.g. double seizing,
stopper knots or splices.
Module 8- Fire Hoses
Inspector Observations: There was No Warning mentioning to Start Ventilation Prior to Enter the
CO2 Room, which contained 200 CO2 was the Main Fire Extinguishing System for Engine Room
and Pump room.
A ship of 300 gross or more constructed after June 30, 1974 must have a fixed container or enclosed
deck area under or around each fuel oil or bulk lubricating oil tank vent, overflow, and fill pipe, that:
a.For a ship of 300 or more but less than 1600 gross tons has a capacity of at least one-half barrel;
and
b.For a ship of 1600 or more gross tons has a capacity of one barrel.
Module 8 - Summary
Module 9 – The Main Deck and Forecastle – Oil Tanker
Module 9- Personal Protection
Connect a grounding wire from the pump to a bare metallic point on the structure of the ship
The pump is not grounded adequately when sited on the steel deck
Module 9- Questions You Might need to answer
1920
IG INSTALLED
Chevron (Then Socal)
experimented and installed IG on
19 ships. Discontinued after 20
years on the grounds there was
no safety advantage and no
reduction in corrosion.
1932
BIDWELL EXPLOSION
Sunoco Marcus Hook refinery
tanker BIDWELL exploded at
Marcus Hook, Delaware, 18
persons killed while tank cleaning.
Scrapped 1965 – age 45.
1933
IGS INTRODUCED
SUNOCO introduced Inert Gas to
its entire fleet
1939-1944
WWII
2nd World War experiences –
more than 250 allied oil tankers
lost
1945-1960
MORE EXPLOSIONS
10 tankers exploded in
circumstances where IGS would
have helped
1960
BP IN THE GAME
BP Started testing of IG as a
means to reduce cargo tank
corrosion
1963
BP INSTALLING IGS
BP started fitting IGS to all new
crude tankers
1966 – Explosion on British steam tanker
British Crown while loading at UMM
Said, Qatar
• IMO introduced requirements for IGS on all new tankers >20k DWT built after May 1982
• Extended to existing tankers in 1985
• Chemical tankers and product tankers <40k DWT were exempted.
• Closed loading introduced at the same time
2000’s
11 Oil tankers casualties occurred during the 2000’s where inert gas would have helped.
Module 10- The VLCC disasters of after 1990
Consequences of closing
the isolation valve during
cargo transfer
Module 10 – Inert Gas System
Module 10 – The Inert Gas System – Check
Is the IGS, including instrumentation, alarm trips and pressure and
oxygen recorder, fully operational?
wet type deck water seal Semi Dry Type Deck Water Seal Dry Type Deck Water Seal
Module 10 – Typical Composition of the Delivered IG after
scrubber (ISGOTT 7.1.3)
83% 12-14% Trace 2-4% 50ppm 0.06% 200ppm 150mg
Sulphur Dioxide/Trioxide
Carbon Dioxide
(CO2)
Nitrogen (N2)
Nitrous Oxide
Oxygen
Monoxide
Carbon
per m3
Issues associated with dumping IG scrubber effluent to sea?
Module 10 – Inert Gas Blowers
Valves Inlet valve and a discharge valve
Number of Blowers 2 two blowers
Combined Capacity At least of 125% of the max discharge rate of cargo
pumps
Gas-freeing Air supply line and inlet valve
Fan casing drains No excessive water carryover
Inspection Covers No leaking gas
Alarms Discharge temp and pressure of delivered IG
Automatic shut-down provisions
In the event of :
• Low water pressure or low flow rate in the scrubber
• High water level in the scrubber
• High gas temperature
Module 10 – Inert Gas Blowers
8.25 Is the inert gas system including instrumentation, alarms, trips and pressure and oxygen recorders,
in good order?
Inspector Observations : Inert Gas Plant was malfunctioning at the beginning of the discharging
Operations. Cargo discharging operations were suspended for about 1,5 hour due to the
malfunctioning of the IG plant.
Initial Operator Comments: THE VESSEL EXPERIENCED AN IG VALVE FAIL ALARM ABOUT 3 HRS AFTER THE
START OF DISCHARGE OPERATIONS. THE FAULT WAS DUE TO THE DELIVERY VALVE OF THE IG BLOWER
BEING CLOSED BUT GIVING AN INCORRECT SIGNAL. THIS WAS BECAUSE THE CAM INSIDE THE VALVE WAS
NOT TOUCHING THE LIMIT SWITCH WAS ADJUSTED & THE VALVE FAILURE ALARM RECTIFIED.
NO ALARMS OR FAULTS HAD BEEN ENCOUNTERED DURING THE PRE-ARRIVAL CHECKS OF CARGO
SYSTEMS DOEN IN ACCORDANCE WITH OUR CARGO OPS PRE-ARRIVAL CHECKLIST.
THE VESSEL HAS RAISED A DEFECT REPORT & SYSTEM DEVIATION REPORT FOR THIS IGS FAULT. ONCE THE
LIMIT SWITCH WAS ADJUSTED, THE FAULT DID NOT RE-OCCUR. THE IGS WAS RETESTED AFTER DEPARTURE
FROM THIS PORT & ALL COMPONENTS FOUND OPERATING PROPERLY AS DESIGNED.
Module 10
SOLAS II-2 Part C Regulation 11.6.3.2
Is the key to the locking device in the custody of the responsible officer?
The purpose of secondary venting is to ensure that tanks are protected if the primary IG/Vent inlet
valve is accidentally shut or if mechanical failure results in closure of the inlet valve.
Secondary venting may be provided by a full flow pressure / vacuum valve or by means of a pressure
sensor where the readout is situated at the cargo control position.
Module 10- Secondary venting- The OCIMF position
SOLAS 2-II Reg 4 5.3.2 Venting arrangements
5.3.2.1 The venting arrangements in each cargo tank may be independent or combined with other
cargo tanks and may be incorporated into the inert gas piping.
5.3.2.2 Where the arrangements are combined with other cargo tanks, either stop valves or other
acceptable means shall be provided to isolate each cargo tank.
Where stop valves are fitted, they shall be provided with locking arrangements which shall be under
the control of the responsible ship’s officer.
There shall be a clear visual indication of the operational status of the valves or other acceptable
means.
Where tanks have been isolated, it shall be ensured that relevant isolating valves are opened before
cargo loading or ballasting or discharging of those tanks is commenced. Any isolation must continue
to permit the flow caused by thermal variations in a cargo tank in accordance with regulation
11.6.1.1
Module 10
8.19 Are the officers aware of the primary and secondary cargo tank venting systems and are
the systems functioning correctly?
Inspector Observations: There was no record for Mast Riser P/V valve pressure test since delivery
date
Other inspector Comments : The vessel was fitted with Mast Riser and individual high velocity
P/V valves sized to provide protection under maximum loading / discharging condition.
Individual high velocity P/V valves and Mast Riser P/V valve setting points were +1400 / -350
mmWG.
Initial Operation Comments : The inspection / maintenance of certain component since its
initial installation is being carried out concurrently with the group of full flow high velocity P/V
Valves which is fitted for each cargo tank, thus in accordance with Company’s PMS reference
is made specifically for the inspection/maintenance of the group of flow high velocity P/V
Valves as a whole, considered it together with the mast riser as one job’s description.
The company took under serious consideration the inspector’s observation and following the
investigation carried out by the technical department responsible for PMS implementation, a
separate job for the inspection / maintenance of the Mast Riser has already been included in
the PMS. Furthermore a Preventive Action Circular sent to all Company’s vessels for information
and actions to be taken.
Module 10- IACS UI 140: Secondary Means of Venting Cargo
Tanks
IACS UI 140: Secondary Means of Venting Cargo Tanks (Reg. II-2/4.5.3.2.2 and Reg.II-
2/11.6.3.2)
A P/V breaker fitted on the IG main may be utilized as the required secondary means of
venting.
The height requirements of Reg.II-2/4.5.3.4.1 and 11.6.2 and the requirements for devices to
prevent the passage of flame of Reg. II-2/4.5.3.3 are not applicable to the P/V breaker
provided the settings are above those of the venting arrangements required by Reg. II-
2/11.6.1.
IACS
International Association
Of Classification Societies
Module 10- IACS UI 140: Secondary Means of Venting Cargo
Tanks
(Reg. II-2/4.5.3.2.2 and Reg.II-2/11.6.3.2)
Inadvertent closure or mechanical failure of the isolation valves required by SOLAS Reg.I
2/4.5.3.2.2 and the FSS Code, Ch.15, 2.3.2.2 need not be considered in establishing the
secondary means since:
a) The valves are operated under the control of the responsible ships officer and a clear
visual indication of the operational status of the valves is required by SOLAS Reg.II-
2/4.5.3.2.2, as amended, and
b) The possibility of mechanical failure of the valves is remote due to their simplicity.
IACS
International Association
Of Classification Societies
Module 10 – An added Complication
Module 10 - Tankers Carrying High and Low Flash Cargoes
(Products and Crude Oils) Simultaneously
The regulations governing secondary protection look for full flow protection or
pressure sensors
If the IG Inlet Valves are INTENTIONALLY closed for the purposes of protection against
vapor carryover from low to high flash point cargoes, further considerations need to
be made.
In such cases BOTH the primary and secondary protection needs to be downstream
(i.e. INSIDE) of the cargo tanks themselves.
Module 10
Can double hull spaces be inerted?
Tankers required to be fitted with inert gas systems shall be fitted with suitable connections for
the supply of inert gas to double hull spaces. (SOLAS 2001 11-2/59.4.3)
Tankers required to be fitted with inert gas systems shall comply with the following provisions:
1. Double hull spaces shall be fitted with suitable connections for the supply of inert gas;
2. Where hull spaces are connected to a permanently fitted inert gas distribution system,
means shall be provided to prevent hydrocarbon gases from the cargo tanks entering the
double hull spaces through the system;
and
3. Where such spaces are not permanently connected to an inert gas distribution system,
appropriate means shall be provided to allow connection to the inert gas main. (SOLAS
2009 II-2/4.5.5.1.3)
Module 10 - Summary
Module 11 – Inspection of the Pump Room
Module 11 - Check Pump Room Ventilators are running
Module 11 - Entering the Pump Room Top
Module 11 - Pump Room Entry Procedures
• The inspector will look closely at the actions that are made prior to entry
• Tell OOW in the CCR that you are going to enter the PR
• Tell the inspector where the Emergency Escape (EEBDs) packs are located.
• Explain specific emergency signals
• Have a crewman standing by at the PR top
• Use the opportunity to zero and span the LEL instrument to show that you know how to
do it
• Ask the OOW to tell you what the gas/O2 readings are for the Upper / Mid and Lower
level sensors
• Use personal gas alarm (LEL, CO, O2 and H2S)
• Be careful about using Enclosed Space Entry
• Permits in Pump room
• Wear ear protection
Module 11 - Pump Room
• Are all cargo pumps and gauges fully
operational?
• Are pumps and pipelines free of oil leakage?
• Are bilges free of oil?
• Are pipelines free of patches?
• Is the high level alarm operational and
located at the low point?
• Do ODME sensors show any indications of
tampering?
Module 11 - Pump Room Emergency Procedures
Module 11 - Vac Strip, Rotating Shafts, Fire Fighting Equipment
Module 11 - Vac Strip, Rotating Shafts, Fire Fighting Equipment
Checklist
• Are the stripping pumps and eductors
operational?
• Are pumps and steam lines free of oil leakage?
• Is vent system operating on extraction mode?
• Are cargo / ballast line spool piece
disconnected?
• Are bilge overboard valves lashed and sealed?
Module 11 - Clean bilges, pump or line leaks prior to the
inspection
Module 11 - Summary
Module 12 – Inspection of the Cargo Control Room
Module 12 - Cargo Control Room
Is the key to the locking device in the custody of the responsible officer?
• Is it to MARPOL Requirements?
• Has the slop or COW supply tank been emptied and refilled with dry crude?
Hand 3%
Shoulder 3%
Knee 3%
Arm 7%
Death 14%
Head 7%
With the production of this document, the OCIMF position is that ETOPs are not required and have
not provided benefits in the past.
If, however, individual marine terminal risk assessments or port authorities still require the use of ETOPs,
it is recommended that options other than wire rope be considered.
Module 13 - Emergency Towing-Off Pennants (ETOPs) better
known as “Fire Wires”
Module 13 - Typical Mooring Arrangement
Module 13 - MEG 4: Winch Brake Testing
1 55 539 100
2 49 481 89
3 45 441 82
4 41 402 75
5 38 373 69
Module 13 - Emergency Towing Booklet (ETB)
For ships constructed after 1 Jan. 2010
• Bunkering
• UMS Records
• Log Books
• Planned Maintenance
• C/E Standing Orders and Night Orders
• Record of Testing of IGS
• Records of Testing of Steering Gear
• M/E Jacket / Boiler Water & Luboil logs and tests
Module 14 - The Bunkering Safety Check List (ISGOTT 25.4.3)
Port……………… Date:……………
Ship………………. Barge……………
Master…………… Master…………..
1. Bunkers to be Transferred
Grade Tonnes Volume at Loading Loading Maximum Maximum
Temp Temperature Transfer Rate Pressure
Fuel Oil
Gas Oil/
Diesel
Lub Oil in
Bulk
• Auxiliary machinery
• Cargo Pumps
• Coolers
• Cylinder heads
• Boilers
• Inert
Gas
• Workshop
• Stores
• Steering Flat
• Control Room
Module 14 – Engine Room Common Observations
10.19 Are diesel engine fuel delivery pipes adequately jacketed or screened, exhaust lines and hot surfaces
protected from spray and surrounding areas free from fuel or lube oil leakage?
Inspector Observations: There was a significant build up of oil soaked dirt and debris around the cylinders on the
main engine. This was cleaned up prior to the completion of the inspection.
Initial Operator Comments: Root Cause: The ship has completed several very long voyages in recent months
allowing little down time in which the accumulation of debris around the cylinders heads could be removed. The
time alongside in the previous port had been fully occupied with necessary operational repairs leaving this
cleaning task until the inspection port. Correction: The opportunity presented while alongside as noted by the
inspector was taken to remove this accumulation. Action to prevent reoccurrence: Housekeeping routines do
require that high standards of cleanliness are maintained throughout the machinery spaces. Where operational
demands prevent effective compliance outstanding tasks are caught up as soon as possible afterwards. Company
inspections all focus towards monitoring that standards are maintained. Further Operator Comments: Final update
Awareness of engineers and engine crew regarding good house-keeping practice is now on the desired high level
as indicated by regular work reports submitted from the ship. A review fleet-wide has confirmed that required
standards of cleanliness are being maintained overall.
Module 14 – Engine Room Common Observations
10.19 Are diesel engine fuel delivery pipes adequately jacketed or screened, exhaust lines and hot surfaces
protected from spray and surrounding areas free from fuel or lube oil leakage?
Inspector Observations: Several Lagging were observed soaked with Fuel Oil and one (1) can size container was
notices under the coupling of a FO Pump integrated to the FO Oil Heating Unit and fitted with Fuel Oil.
Initial Operator Comments: THE COMPANY SMS PROVIDES RELEVANT GUIDANCE FOR HOUSEKEEPING STANDARDS TO BE
MAINTAINED ON VESSELS.IT IS FURTHER REQUIRED AS PER # WEEKLY INSPECTIONS ARE MADE BY CHIEF ENGINEER TO ENSURE
MEETING THESE REQUIREMENTS. THE NOTED LAGGING HAD OLD OIL STAINS ON THEM FROM THE LAST PMS REPAIRS AND
MAINTENANCE CARRIED OUT. ALL OIL STAINED LAGGING HAS NOW BEEN REPLACED. THE COUPLING SEAL RENEWED AND
THE DRIP TRAY REMOVED, ON WORK ORDER NUMBER. IT SHOULD BE NOTED THAT THERE WAS NO CURRENT LEAK IN THE AREA.
A NON CONFORMITY HAS BEEN RAISED IN OUR SAFETY MANAGEMENT SYSTEM. THE ATTENDING SUPERINTENDENT DISCUSSED
THE REQUIREMENTS OF THIS WITH THE MASTER AND CH ENGINEER THE SUPERINTENDENT ALSO MADE A THOROUGH
INSPECTION OF THE ENGINE ROOM AND DID NOT FIND ANY ADDITIONAL AREAS OF CONCERN IN THE ENGINE-ROOM. IT
SHOULD BE NOTED THAT, DUE TO CUSTOMS AND BORDER CONTROL REGULATIONS. THE CHIEF ENGINEER WHO WAS ON
BOARD PRIOR TO THE INSPECTION WAS FORCED TO LEAVE THE SHIP PRIOR TO THE INSPECTION TAKING PLACE. THE CHIEF
ENGINEER WHO WAS IN ATTENDANCE DURING THE INSPECTION HAD JUST JOINED THE SHIP. THE RELIEVED CHIEF ENGINEER
WILL BE REQUIRED TO ATTEND OUR MANAGING OFFICE TO EXPLAIN THE REASONS BEHIND THIS OBSERVATION.
Module 14 – Engine Room Common Observations
10.22 Where hydraulic aggregate pumps are located within the main engine compartment, is an oil
mist detector fitted?
Inspector Observations: The hydraulic aggregate pumps, located within the main engine
compartment, were not fitted with an oil mist detector.
Initial Operator Comments: The oil-mist detector for hydraulic aggregates is not fitted as mentioned;
they are located in a room fitted with fire detectors. The equipment are also designed with oil leak
detection and level alarm system in accordance with the classification rules. Additionally, the ER is
always manned dunning cargo operations and the spaces were checked at regular and frequent
interval.
Module 14 – Engine Room Common Observations
10.29 Are machinery spaces and steering compartments clean and free from obvious leaks and is the
overall standard of housekeeping and fabric maintenance satisfactory?
Initial Operator Comments: The leakages should have not been there as Company has zero tolerance
for any leakage. Anyway all leakages have been attended and closed-out.
Module 14 – Emergency Equipment
Emergency Fire Pump
Is the emergency fire pump fully operational and
are starting instructions clearly displayed?
Emergency Generator
Has the generator been tested or run on load
recently?
Module 14 - Summary
Module 15 – Debriefing and Dealing with Inspectors
Module 15 – Debriefing and Observations – Dealing with the
Inspector
• Keep it cordial at all costs !
• Don’t overwhelm the inspector with too many
people
• Discuss observations
• Ask inspector justify Observations by pointing to
source Regulations or Industry Guidance
• If written observations are not made by the inspector,
the Master must do it.
• Remember, the inspector has the “Golden Key” that
is your prize – A report that is free of Observations!!
Module 15 – Debriefing and Observations – Dealing with the
Inspector
Remember, the inspector………
Inspector Observations: On 11-Sep-2019 the vessel carried out bunkering operation and the
following personnel (CE, 2E, Oiler, Fitter) recorded rest hours below the minimum level of 10 hours
but the review of the reporting at the end of the month between the ship and the shore office
indicated that no NC or deviation had occurred.
Inspector Observations: There was a gap of about two weeks between the summary of EGC
warnings compiled, as shown to inspector, and the officer in charge was not able to explain
how EGC warning notices were received and managed in between time period.
Inspector Observations: Although passage planning notes and records were endorsed
validated by the Master, the Master could not perform a route check when requested and he
claimed that it has not been carried out but relied on 2/O planning of the route.
Inspector Observations: The crew on top of the pump room was not able to activate the
flooding damper when requested.
Inspector Observations: A deck officer quizzed regarding the use of the surface (dump) valves
to slop tanks was unfamiliar with its operation. He was under the impression that slop tank was to
be depressurized prior to the use of the valve. Another duty officer in the cargo control room
was not able to explain the spill recovery gears provided on deck to combat cargo spills.
Inspector Observations: The vessel had transferred a total of 28m3 oily residues from engine room
on 17-May-2019 (14.4 m3 from oil bilge tank and 13.6m3 from oil sludge tank) to Slop starboard
tank, which was mixed with tank washing water (slops) already in the tank, and the entire
mixture was subsequently pumped overboard thru the ODME on 18-May-2019. There was no risk
assessment noted for this operation.
Inspector Observations: The duty officer in the cargo control room could not describe the level
alarms fitted in cargo tanks.
Inspector Observations: The oxygen sensor for the IG system had been calibrated more than 24
hours before starting the system, it was recorded done on 8-Nov-2019 and same was confirmed
by the person carrying out the test.
Inspector Observations: One of the deck officers during the review of the bridge, was unaware
of the accommodation and engine room fan and pump stop controls. The review of the same
with the engineers revealed that there had been no test of the controls located on the bridge.
Inspector Observations: The incinerator inspection door for the lower chamber was opened and
the chamber was full of ashes, in compact form, right up to the brim and the upper door could
not be opened for inspection.
Ktenas Panagiotis MA Inter. Relat., MSc. Urban Plan , BSc Econ and Mech. Eng.
Certified Adult Trainer, Registrar N.EA24815 (EOPPEP).
ex. Lt Cdr Hellenic Navy
pktenas@gmail.com
November 2019
363