DBS Port State Control Policies and Preventive Measures
09 February 2022 | C22009
With this Circular we wish to inform all partied concern on the of measures that have been set, to assist our fleet to achieving better PSC results and avoid any possible detention.
Ship Owners/ Managers/ Operators | Surveyors/Auditors
DromonClass has proceeded in an evaluation of the Port State Control cases that occurred in 2021 on board DBS Classed vessels. DBS has set a number of Port State Control preventive measures to assist all parties achieving a better performance and avoid any possible detention.
Owners/ Managers/ Operators/ Surveyors should take into serious consideration the below listed measures, actions and policies in order to comply with DBS requirements.
- DBS Detention Policy
DBS would like to remind that no vessel should be detained from PSC authorities.
Owners/ Managers should note that in case their vessel will be detained, DBS shall evaluate their vessel’s detention and take extra measures that might include, among others, issuance of a warning letter as well as suspension of their ship.
- DBS Outstanding recommendations policy
We have noticed that following completion of classification and statutory surveys a number of imposed recommendations are not rectified prior the ship’s departure from inspection port. Although recommendations and/or deficiencies are communicated to Owners/ Managers and Masters, these remain outstanding even after the completion of our survey without prior notification to DromonClass Head Office and the flag State, as applicable.
We wish to draw everyone’s attention that all recommendations relating to classification and statutory certification must be rectified prior departure from inspection port as well as issuance and/or endorsement of any Classification and/or Statutory Certificate.
In case Managers/ Owners cannot rectify the imposed recommendation at the inspection port the following actions shall be taken:
- For recommendations relating to Classification surveys a Condition of Class shall be imposed, that shall be rectified within a specified time limit. Recommendations relating to class items are corrosion, structural defects or damage to hull, machinery and/ or equipment, which based on DromonClass Rules and in the opinion of the Surveyor affect the ship’s classification status.
- For recommendations relating to Statutory surveys, Owners/ Managers must have the consent of the flag State for the recommendation not to be rectified before departure. The flag State shall agree for the imposed recommendation to be rectified within a specified time limit. The flag State may require the issuance of Conditional Statutory Certificate for the imposed recommendation to remain open for a specific time frame. In this case the Surveyor will be informed accordingly.
- DBS PSC Preventive Actions
The DBS Port State Control (PSC) Preventive Action scheme aims to:
- eliminate the number of deficiencies on board our fleet;
- identify in advance of a PSC inspection any possible deficiency and therefore reduce the likehood of a detention; and
- follow up deficiencies/ recommendations imposed by our Surveyors or PSC Authorities during previous inspections.
Eligible to the scheme is every DBS ship that calls a port of a PSC Authority of Paris MoU. Based on the Paris MoU tool, DBS will calculate the ship’s profile with an aim to identify the next Port State Control Inspection in any Paris MoU Port.
Owners/ Managers will be notified that the vessel is due for an Inspection and advise them that their vessel shall be subject to an Occasional Attendance that shall need to be carried out one (1) month prior the vessel’s due date for a Paris MoU PSC Inspection, at a convenient port of call.
During our attendance the DBS Surveyor:
- will use our PSC Checklist that can be found here;
- will identify possible deficiencies as well as detainable deficiencies; and
- review corrective actions for deficiencies imposed during previous schedule surveys and/or PSC inspections.
Any identified deficiency during a PSC Preventive Action survey will be recorded at the official survey status report of the ship. In case the due date of the ship for a PSC Preventive Inspection Scheme survey falls within the window of a schedule survey (for e.g. annual/ intermediate surveys etc.) then the schedule surveys will be carried out.
Owners/ Managers that might not follow above scheme will bear any consequences that include among others, issuance of a warning letter as well as suspension of their ship.
- Vessels’ self-inspection
A self-inspection is to be carried out by the ship’s crew prior to arrival into any Paris MoU port by using our PSC Preventive Inspection Checklist. The checklist should be submitted to DBS Head Office along with photos and/or videos as evidence that the inspection was performed.
If any of the items outlined in this checklist are not in good working condition or found not incompliance, the crew should take appropriate steps for a corrective action to be implemented prior to arrival into port.
- Most Common detainable deficiencies
DBS Marine Division has listed the most common detainable deficiencies in Paris MoU for 2021, as shown in the table below. The ship’s crew should take into consideration the below listed deficiencies and work towards the rectification of any of those that may exist on board their ship.
|Fire Safety||Water/Weathertight Conditions|
|07106||Inoperable fire detection and alarm system||03108||Damaged/seized ventilators|
|07115||Wasted/Inoperable fire-dampers||03105||Hatch covers wasted cleats and its spacers|
|07113||Malfunction of fire pump||03105||Hatch cover rubber gasket missing/wasted|
|07105||Poor closing condition of fire door||MARPOL Annex IV|
|07123||Insufficient pressure from emergency fire pump||14402||Inoperative sewage treatment plant|
|Life Saving Appliances||MARPOL Annex I|
|11101||Lifeboat engine not started easily||14104||Oil filtering equipment, 15 ppm alarm arrangements and discharge connection should be in good condition, properly calibrated, maintained and fully functional, with appropriate spares.|
|11104||Rescue boat engine not started easily||01315||Oil record book updated|
|11112||Inoperative davit for launching arrangements for survival craft||Excessive quantity in Oily bilge and Sludge tanks|
|11134||Emergency generator do not start automatically or manually||Structural Conditions|
|11134||Inoperable emergency lights||Emergency shut off valves of oil tanks inoperative|
|11108||Correctly mounted Hydrostatic Release Unit (HRU) on an inflatable liferaft||02107||Ballast tanks heavily corroded/wasted|
|Safety of Navigation||02113||Cracks in hull, keel plate connections and pin|
|10111||Charts not updated
|02114||Bulkheads heavily corroded/waste/holed|
|10111||Navigation charts for intended voyage not available||Propulsion and Auxiliary Machinery|
|10116||Nautical publication not updated||13101||Cleanliness of Engine Room insufficient|
|10116||Nautical Publication for intended voyage not available||13103||Gauges, thermometers inoperable/damaged|
|10114||Voyage data recorder (VDR / S-VDR) malfunction ‘’system error’’||ISM|
|10109||Navigation lights damaged/inoperable||15150||Records of inspection, maintenance, testing and drills and crew familiarization with fire and abandon ship drills|
|10117||Echo Sounder malfunction||15150||Lifeboat weekly test conducted and recorded|
|10104||Main gyro compass not aligned with repeaters||15150||Rescue boat weekly test conducted and recorded|
|10127||Passage or Voyage plan not as per guidelines Res A.893|
Please visit our website, where you can access various circulars, publications and get further support on many PSC related issues and deficiencies that may assist into preventing any detentions.
Ship Owners/ Managers/ Operators should take into consideration above policies and measures.
Owners/ Managers/ Operators that will not follow above measures and DBS Port State Control policies and measures will have the applicable consequences, which have been set as a result of the DBS PSC preventive measures.