August 2, 2011
With the continued expansion in Europe of port state control inspections to yachts, a number of “lessons learned” have been discovered.
In addition, various new directives have been announced by other worldwide jurisdictions that will affect yachts.
Fire pump failed after undocking
After the drydocking of a yacht carrying out a periodical bottom survey, the fire pump was tested. It failed to build up the required pressure. The yacht was properly trimmed and the sea valve was dismantled and examined. All was found to be in a satisfactory condition.
However, the internal investigation of the sea chest revealed an item blocking the flow, a small bucket of anti-fouling paint. After removing it, the sea chest was blown through and the pump was re-tested with positive results.
This experience is publicized to bring attention to yacht crew for the need of a final check of the underwater portion of the hull before undocking. The fire pump is a port state control focus item and remains on the list of the top detainable deficiencies.
Reporting of defective equipment
Due to an increase in the number of vessels failing to report incidents, accidents, breakdowns and defective equipment as required by SOLAS Ch. 1 Reg.11 (c) and various national and state laws, the Australian Maritime Safety Authority (AMSA) sent a notification to ships and yachts calling upon ports in the country.
The correct method of reporting to AMSA is by using the AMSA Form 18 Incident Alert (to be completed within four hours) and AMSA Form 19 Incident Report (to be completed within 72 hours).
These forms are available from the AMSA Web site. It should be noted that Australian legislation provides significant penalties for failing to comply with any reporting requirements. Failure to report accidental damage and implement the necessary rectification measures may lead to a yacht’s detention.
Similar laws are in effect in the United States and European Union.
USCG inspection of fuel oil quick-closing valves
In 2008, the U.S. Coast Guard published a Safety Alert on the inspection of fuel oil quick-closing valves QCVs). More than two years later, the USCG found it necessary to issue another Safety Alert on the same issue.
USCG Port State Control officers are discovering fuel oil QCVs that are intentionally blocked, modified or poorly maintained. This prevents them from operating as designed during an emergency.
The USCG strongly recommends that personnel involved with the technical examination of machinery space equipment fully understand the critical nature and importance of the fuel oil QCVs and associated systems.
During Coast Guard inspections, engineers should be able to explain the system’s general maintenance requirements and provide operational test and maintenance records. The engineer should also be able to explain how the valves are tested and reset following closure.
USCG begins VGP inspections
The USCG and Environmental Protection Agency (EPA) have signed a Memorandum of Understanding (MOU) regarding matters related to the Vessel General Permit (VGP). The VGP applies to discharges incidental to the normal operation of commercial vessels of 79 feet (24m) or more in length, and it covers 26 types of discharges, many of which have not previously been covered by U.S. regulations.
The VGP requires certain training, inspections, monitoring and reporting ,and to undertake assessments and corrective actions as necessary. Commercial vessels are required to submit a Notice of Intent (NOI) to receive permit coverage and to submit a one-time permit report 30-36 months after obtaining permit coverage.
Providing a false statement, record or certification, or tampering with, or knowingly rendering inaccurate any monitoring device or method required to be maintained under the permit may result in fines, a jail sentence or both.
Commercial yachts may be subject to inspection by the USCG to verify compliance during routine inspections on both U.S.- and foreign-flagged vessels subject to the VGP that operate in U.S. waters. Any deficiencies found will be reported to the EPA as the enforcement authority to address VGP violations.
Unnecessary detention due to documentation
A vessel was detained in the Paris MoU region for having two sets of Safety Management Certificates (SMC) and International Ship Security Certificates (ISSC) on board.
The vessel had undergone renewal ISM and ISPS audits. As is normal, new certificates were issued. During the review process by the issuing classification society, it was noted that the expiry date of the SMC was incorrect and the certificate was re-issued. The ISSC certificate was also re-issued in order to be harmonized with the SMC.
Regrettably, the obsolete certificates were not removed from the ship’s certificate file. During a port state inspection, almost two years after the re-issuance of the certificates, the vessel was detained.
Normally, errors on certificates do not constitute grounds for detention. However, the PSC officer may consider this to be a clear ground for a more detailed inspection.
To avoid similar situations, yachts are reminded that the captain is responsible for ensuring that the yacht carries valid and correct certificates. Whenever new certificates are received on board, they should be checked to ensure that they are correct. Any obsolete certificates should be removed from the file (ref. ISM Code, Section 11 – Document Control).
CIC on Structural Safety and Load Lines
The Concentrated Inspection Campaign (CIC) on Structural Safety and Load Lines will be carried out from Sept. 1-Nov. 30.
In a show of cooperation, the Paris MoU Secretariat confirmed that its member states will be joining the Tokyo MoU in this CIC. It is expected that port state control inspectors will verify that commercial yachts remain in compliance with the operational limits placed on the International Load Line Certificate.
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