Alert on detainable deficiencies

12 October 2020 |  C20041

Following a recent Port State Control (PSC) inspection, a number of deficiencies have been imposed that resulted in the detention of the vessel. Dromon wishes to draw attention to these detainable deficiencies to avoid re-occurrence.

Ship Owners/ Managers/ Operators | Surveyors / Auditors


Through the PSC Inspection, it was noted that:

  1. the safety equipment certificate indicated that no exemption was issued but no lifeboats on board were fitted – not in accordance with the Regulation; and
  2. an exemption certificate has been submitted as copy and no original was on board.

SOLAS Chapter III/Regulation 31-1.3 requires that cargo ships of less than 85 m in length other than oil tankers, chemical tankers and gas carriers, may comply with the following:

  1. they shall carry on each side of the ship, one or more inflatable or rigid liferafts complying with the requirements of section 4.2 or 4.3 of the Code and of such aggregate capacity as will accommodate the total number of persons on board;
  2. unless the liferafts required by paragraph 1.3.1 are of a mass of less than 185 kg and stowed in a position providing for easy side-to-side transfer at a single open deck level, additional liferafts shall be provided so that the total capacity available on each side will accommodate 150% of the total number of persons on board;
  3. if the rescue boat required by paragraph 2 is also a totally enclosed lifeboat complying with the requirements of section 4.6 of the Code, it may be included in the aggregate capacity required by paragraph 1.3.1, provided that the total capacity available on either side of the ship is at least 150% of the total number of persons on board; and
  4. in the event of any one survival craft being lost or rendered unserviceable, there shall be sufficient survival craft available for use on each side, including any which are of a mass of less than 185 kg and stowed in a position providing for easy side-to-side transfer at a single open deck level, to accommodate the total number of persons on board.

In the case where above requirements cannot be fulfilled, an exemption certificate may be requested by the relevant flag administration and the original exemption certificate must exist on board. Similarly, the Safety Equipment Certificate (point 4), needs to indicate that an exemption certificate has been issued.


The PSC report indicated that the davit launchable liferaft, according to the Safety Equipment, was not available on board.

SOLAS Chapter III/Regulation 31-1.2.2 mentions “The liferafts on at least one side of the ship shall be served by launching appliances.”

A wrong entry regarding liferafts has been recorded in the Safety Equipment Certificate (Form E).

Surveyors are requested to note above requirement and apply the correct entries on the issued Certificates in order to avoid similar incidents in the future.


During the PSC Inspection, it was noted that:

  • the main fire pump was found inoperative due to missing parts;
  • the emergency fire pump and fire line could not be tested due to the forward isolation valve which was stuck in close position and the fire line was not ready for use.

SOLAS Chapter II/Regulation 14-2 defines that the fire-fighting systems and appliances should always be kept in good working condition and readily available for immediate use.

[1]The operation of the main and emergency fire pump must be checked frequently especially during the emergency fire drills. The record of the checks made on the emergency and main fire pump must be done on Saturday or Weekly routine book. Some of the general checks include:

  • Oil and grease the bearings;
  • Check the bearing temperature;
  • Check the condition of gland packing;
  • Check for any leakages from mechanical seal, if fitted;
  • When the fire pump will not be used for a longer duration (in dry docks or layups), keep the discharge and suction valve closed;
  • When sailing in the cold region, keep the pump drained off the water;
  • Check the standby pump when operating the other fire pump. If it is also reversing, the non-return associated with the standby pump is leaking;
  • Check for abnormal noise and vibrations;

Other precautions:

  • In freezing weather conditions, keep the fire and deck wash water line drained;
  • Never close or throttle the suction valve when the fire pump is running;
  • When glad packing is used, little water leakage is considered fine. For the mechanical seal, no water leakage should be observed; and
  • When filling the grease, ensure to open the drain plug open which makes the old grease come out.

Dromon Publication on onboard maintenance and Drills agenda lists the maintenance programme that should be followed for the fire pumps according to MSC.1/Circ.1432.

Ship Masters should ensure that the maintenance programme is always followed according to the Regulations.


During the PSC Inspection, it was noted that the nautical chart for trading area has been found not updated and tide tables, list of lights and pilot haven’t been on board.

SOLAS Chapter V/Regulation 27, refers that the nautical charts and nautical publications, such as sailing directions, lists of lights, notices to mariners, tide tables and all other nautical publications necessary for the intended voyage, shall be adequate and up to date.

Ship Managers are requested to follow the nautical publications’ updates and ensure that same are kept on board, as required.


Through the PSC Inspection, it was noted that the echo sounder has been found malfunctioning.

The above should comply with the performance standards of IMO Resolution MSC.74(69) stated that, alarm signals, both visual and audible (with mute function) to the navigator on the watch should be provided to indicate failure or a reduction in the power supply to the echo sounder which would affect the safe operation of the equipment.

In addition, the equipment should:

  • be provided with an indication of manufacturer, type and/or number; and
  • be so constructed that it is readily accessible for maintenance purposes.

Information should be provided to enable competent members of a ship’s staff to operate and maintain the equipment efficiently.


The PSC noted that the forecastle store room and cargo hold vents have been found holed due to heavy corrosion.

The causes for these deficiencies are:

  • the combined effect of the marine environment and the high humidity atmosphere within cargo hold that gives rise to a high corrosion rate; the lack of planned maintenance properly followed by the crew on board,
  • the lack of Crew Familiarization with SMS system;
  • and the lack of monitoring by the ISM Company.

Shipowners / Managers / Operators are kindly requested to pay special attention into such serious deficiencies.


Lastly, during the PSC inspection, it was noted that the CO2 room bulkhead, on aft main deck, found heavy corroded and holed.

Following the corroded vents, again this deficiency shows same lack from the crew. With the proper maintenance procedures, vessels are less likely to suffer from corrosion. A maintenance plan shall assist to identify any signs of damage and take the necessary precautions for their rectification.

Act now

Surveyors / Auditors must take note on the above detainable deficiencies and give special attention during forthcoming class and statutory surveys and audits, irrespective of scope.

Shipowners / Managers / Operators are kindly requested to pay special attention into those deficiencies, note the Regulations requirements and to inform Masters on taking corrective actions, if necessary.

[1] Source: MarineInsight

Share this post:

Related Posts