Alert on Detainable Deficiencies

C24050 | 10 September 2024

Notice to: Ship Owners / Managers/ Operators / Surveyors / Auditors :

Following recent Port State Control (PSC) inspections, several deficiencies were recorded that resulted in the detention of the vessels. Dromon wishes to draw attention to those deficiencies considered as ‘grounds for detention’ to avoid recurrence.

These detainable deficiencies, all of which led to detentions were:

SOLAS Chapter II-1: Construction – Structure, subdivision and stability, machinery and electrical installations:

• Several Emergency Lights on the Boat deck were found inoperative.
  Regulation 43 requires that provision be made for the periodic testing of the complete emergency system.
• Heavy leaking by Boiler Safety valves. Piping was found holed and a can installed to collect the boiler water leakage.
  Regulation 26.7 states that Provision shall be made to facilitate cleaning, inspection, and maintenance of main propulsion and auxiliary machinery including boilers and pressure vessels.
• The main engine remote control from the navigation bridge was found inoperative.
  Regulation 49 requires that under all sailing conditions, including maneuvering, the speed, direction of thrust and, if applicable the pitch of the propeller is to be fully controllable from the navigating bridge.
  
• Several ER alarms not functioning properly (bilge high-level alarm associated with the general alarm, and abandon ship symbol flashing in ER alarm panel).
  Regulation 53 paragraph 4.3 requires that an alarm system is provided for all important pressures, temperatures, fluid levels, and other essential parameters.
• Cargo Hold Hatch cover quick-acting cleats found missing / heavily corroded/seized.
• Several lights in the ER not working.
• Paint Room vent not operational.

SOLAS Chapter II-2: Construction – Fire Protection, Fire Detection and Fire Extinction:

• The fire control plan did not include a table of IMO graphic symbols for fire divisions, Fire doors, escape routes, etc. Primary, and secondary escape routes, escape doors and trunk from E/R lower flat, anyA-class doors, and door to the main switchboard room were not indicated on the plan.
  Regulation 15.2 para 2.4.1. requires general arrangement plans to show clearly for each deck the control stations, the various fire sections enclosed by “A” class divisions, the sections enclosed by “B” class divisions together with particulars of the fire detection and fire alarm systems, the sprinkler installation, the fire-extinguishing appliances, means of access to different compartments, decks, etc., and the ventilating system including particulars of the fan control positions, the position of dampers and identification numbers of the ventilating fans serving each section.
• Alarm system in ECR inoperative.
• RPM Indicator of Emergency Generator inoperative.
• Electrical insulation mats missing from under many electrical boxes.
• Most fire/smoke/heat detectors are not operational.
• Fire detection system displaying fault. Detectors missing.
• Blackout test failed. The Emergency Generator did not auto-sync.
• Insufficient EEBD placed in Engine Room – none found at the foot of escape ladders within the space.
• All fire hoses used in the Fire Drill were found damaged.
• Fire hose nozzles found defective, spray not operative.
• Fire hydrant leaking from gland nut.
• There was insufficient delivery pressure from the Emergency Fire Pump.
• Heat Detector tester not available onboard
  Regulation 14 – Operational readiness and maintenance requires that the following functional requirements are met:
  
  • fire protection systems and fire-fighting systems and appliances shall be maintained ready for use; and
  • fire protection systems and fire-fighting systems and appliances shall be properly tested and inspected.
• Emergency Generator Fuel Tank shut off valve inoperative.
• The quick closing valve of the settling tank is not operational.
• Engine Room bottom oil tank self-closing blanking devices not fitted with ‘self-closing’ control cocks.
  Regulation 14.2 requires the maintenance plan to include an emergency shutdown of the fuel supply.
• Emergency Exit Door from ER blocked open.
• ER workshop fire door inoperative.
• Fire Door between Galley and Messroom impaired by wire penetration.
• Self-closing Fire Door on Bridge not closing properly.
  Regulation 14.2 paragraph 2.1.1 states that structural fire protection including fire-resistant divisions, and protection of openings are to be kept in good order to ensure their required performance if a fire occurs.
  

SOLAS Chapter III: Life-saving appliances and arrangements:

• Ship specific plans for the recovery of persons from the water missing.
  Regulation 17.-1 requires all ships to have ship-specific plans and procedures for the recovery of persons from the water, taking into account the guidelines developed by the Organization (MSC.1/Circ.1447).
• The Fire Drill was not correctly performed. Only a few persons went to Muster Stations.
• Fire Drill not satisfactory. Lack of communication, fire attacked by only one crewmember, not two as required by Muster List. The injured person was rescued by a crew member not wearing any protection.
• During the Fire Drill in the Galley, firemen were not familiar with the use of the radio. No boundary cooling was carried out. Not all fire doors were closed. Firemen entered the Galley without extinguishers. The Chief Officer participated directly in the Galley.
• Emergency Crew not familiar with the use of the Emergency Fire Pump.
• During Drill the Crew did not untie Painter.
• During the Enclosed Space Entry Drill, the atmosphere was not checked properly.
• The fireman outfit’s boots were not approved for firefighting. Air bottles in use with low pressure. Firemen were not using the assigned radios and were not familiar with the radios and channels.
• Fireman’s outfit – mask missing, light not explosion proof.
  Regulation 19 Paragraph 2.1 requires every crew member with assigned emergency duties to be familiar with these duties before the voyage begins.
• Liferaft stowed as far forward of aft was not stowed to permit easy/fast manual release.
  Regulation 31 paragraph 1.4 states that Cargo Ships where the horizontal distance from the extreme end of the stem or stern of the ship to the nearest end of the closest survival craft is more than 100 m shall carry, in addition to the liferafts required by paragraphs 1.1.2 and 1.2.2, a liferaft stowed as far forward of aft, or one as far forward and another as far aft, as is reasonable and practicable. Such liferaft or liferafts may be securely fastened so as to permit manual release and need not be of the type which can be launched from an approved launching device.
  Further information is available in MSC.1/Circ.1490/Rev.1 – revised unified interpretation of SOLAS Regulation III/31.1.4
• Lifeboat clutch not working, lifeboat release lever not operating properly.
• Lifeboat reverse system inoperative.
• The fuel tank of the Rescue Boat was only half full.
• MOB Lifebuoys found blocked.
• It was not possible to lower the rescue boat because the davit was out of order.
• The embarkation ladder near the rescue boat was found not maintained.
• Launching arrangements for the Lifeboat and rescue boat are not maintained and not ready for use.
• Starboard and Port embarkation ladders were found damaged and not safe.
• Bridgewing lifebuoy smoke and light signals not installed effectively.
• Lifejackets do not comply with the LSA Code.
• After Abandon Ship Drill it was not possible to heave up the Lifeboat.
  Regulation 20-3.1 states that maintenance, testing, and inspections of life-saving appliances shall be carried out in a manner having due regard to ensuring the reliability of such appliances.
  Regulation 20 requires that before the ship leaves port and at all times during the voyage, all life-saving appliances are in working order and ready for immediate use.
  Regulation 13 requires that each survival craft is stowed in a state of continuous readiness so that two crew members can carry out preparations for embarkation and launching in less than 5 min.
  Regulation 16 Paragraph 2 requires that each lifeboat is provided with an appliance which is capable of launching and recovering the lifeboat.
  Revised guidelines for maintaining and inspecting fire protection systems and life-saving appliances can be found in MSC/Circ.1432, as amended by MSC.1/Circ.1516., and Dromon Technical Publication “Onboard Maintenance and Drills”.
  

SOLAS Chapter IV: Radio Communications:

• Original GMDSS battery and test certificate not onboard. Test between AC and DC switch of Inmarsat C not provided, MH/HF console and Inmarsat C not tested on the DC system.
• One VHF radiotelephone apparatus was inoperative and one was not ready for use.
• Crew unable to demonstrate operation of MF/HF radio installation on DC power (reserve source of energy).
• GMDSS Inmarsat-C station was not set up to receive maritime safety information for the area the vessel is navigating in.

SOLAS Chapter V: Safety of Navigation:

• The vessel did not comply with the minimum safe manning requirements (the ship was not certified for periodically unattended machinery spaces).
  The Principles of Safe Manning, Resolution A.1047(27) refers.
• Original APT of VDR not onboard, VDR CoC expired, VDR alarm not working with interface devices.
• Voyage Plan made over charts and nautical publications.
  Resolution A.893(21) guidelines for voyage planning refers. Paragraph 3.3 states that the details of the voyage or passage plan should be clearly marked and recorded, as appropriate, on charts and in a voyage plan notebook or computer disk.
  
• Nautical charts for current and intended voyages were out of date, and not updated by T&P Notices.
• Passage plan for previous and next voyages found incomplete, missing nautical charts.
• British Admiralty Sailing Directions for engaged and intended voyages not updated for years 2020 – 2023.
  Regulation 27 requires nautical charts and publications necessary for the intended voyage to be adequate and up to date.
  
• NAVTEX warnings missing (coastal warnings- bombing, gunnery, missile exercises areas).
  Regulation 34 requires the passage plan to anticipate all known navigational hazards.
  
• Gyro compass in Steering Gear Room reading 80 degrees different to the Bridge Gyro.
• Gyro repeater compass missing from steering gear room.
  Regulation 19.2.5 requires a gyro compass heading repeater, or other means, to supply heading information visually at the emergency steering position.
  
• Ship’s Radar found out of order.
  Regulation 19.2.7 requires all ships of 3000 gross tonnage and upwards to have a 3 GHz radar or where considered appropriate by the Administration a second 9 GHz radar, or other means to determine and display the range and bearing of other surface craft, obstructions, buoys, shorelines and navigational marks to assist in navigation and collision avoidance.
• Echo-sounder inoperative.
  Regulation 19.2.3 requires all ships of 300 gross tonnage and upwards and passenger ships irrespective of size to be fitted with:
  • An echo-sounding device, or other electronic means, to measure and display the available depth of water;
  • A 9 GHz radar, or other means to determine and display the range and bearing of radar transponders and other surface craft, obstructions, buoys, shorelines, and navigational marks to assist in navigation and collision avoidance.
• Approximately 5 degrees difference between the Bridge and Emergency Steering Gear rudder indicator.
• Navigation Lights alarm panel giving alarm and some lights/alarms inoperative.
• Forward anchor light and NUC light spares were found inoperative.
  Regulation 16 -Maintenance of equipment – states:
  
  • The Administration shall be satisfied that adequate arrangements are in place to ensure that the performance of the equipment required by this chapter is maintained.
  • Except as provided in regulations I/7(b)(ii), I/8, and I/9, while all reasonable steps shall be taken to maintain the equipment required by this chapter in efficient working order, malfunctions of that equipment shall not be considered as making the ship unseaworthy or as a reason for delaying the ship in ports where repair facilities are not readily available, provided suitable arrangements are made by the master to take the inoperative equipment or unavailable information into account in planning and executing a safe voyage to a port where repairs can take place.

SOLAS Chapter VI: Carriage of Cargoes and Oil Fuels:

• Cargo securing manual not approved by the Administration:
  Regulation 5 requires all cargoes, other than solid and liquid bulk cargoes, cargo units, and cargo transport units to be loaded, stowed, and secured throughout the voyage in accordance with the Cargo Securing Manual approved by the Administration.

SOLAS Chapter XI-1: Special measures to enhance Maritime Safety:

• The Condition Evaluation Report and Survey Report were missing from the Enhanced Survey Programme (ESP) File.
  Regulation 2 states that Bulk Carriers and Oil Tankers are subject to an enhanced programme of inspections in accordance with the International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers, 2011 (2011 ESP Code), paragraph 6.1 of the Code requires that a survey report file should be a part of the documentation on board consisting of:
  
  • reports of structural surveys;
  • condition evaluation report; and
  • thickness measurement reports.
• Atmosphere testing instrument for enclosed spaces – not intrinsically safe, not capable of remote sampling and detection, and no suitable means for calibration.
• Atmosphere testing instrument was found out of order.
  Regulation 7 requires every ship to which SOLAS Chapter I applies to carry an appropriate portable atmosphere testing instrument or instruments. As a minimum, these are to be capable of measuring concentrations of oxygen, flammable gases or vapours, hydrogen sulphide, and carbon monoxide. Suitable means must be provided for the calibration of all such instruments.
  

MARPOL Annex I – Prevention of Pollution by Oil:

• SOPEP not approved by the RO
• It was not clear how the quantity of sludge produced and transferred to sludge tanks, scavenge box drain tank, and waste oil tank were calculated as no sounding tables were found onboard.
• Oil filtering equipment was found out of order.
• ER bilges found with fuel, water and lub. oil mixture (pollution and fire risk), purifier room, and ER found heavy dirt and several pumps and valves leaking at seals.
• No onboard documentation found onboard relating to the OWS.
• Crew not familiar with the operation of the OWS.
• Ship found without OWS installed and outside of Mediterranean, Red, Aegean, Black, and Azov Seas.
  Oil filtering equipment relating to Regulation 14 shall be of a design approved by the Administration. The following also refer:
  
  • Recommendation on international performance and test specification for oily-water separating equipment and oil content meters (resolution A.393(X))
  • Guidelines and specifications for pollution prevention equipment for machinery space bilges of ships (resolution MEPC.60(33)
  • 2011 Guidelines and specifications for add-on equipment for upgrading resolution MEPC.60(33)-compliant oil filtering equipment (resolution MEPC.205(62))
  • Revised guidelines and specification for pollution prevention equipment for machinery space bilges of ships (resolution MEPC.107(49), as amended by resolution MEPC.285(70))
• Standard discharge connection – 1 bolt missing.
  Regulation 3 requires the Standard Discharge Connection to include 6 nuts and bolts, each 20mm in diameter and of suitable length.
  

MARPOL Annex IV – Prevention of Pollution by Sewage:

• The sewage treatment plant was found perforated due to corrosion.
• Sewage treatment system blower not operational. No chemical dosage point. The cover was kept open.
• The sewage treatment plant was found out of order and dismounted.
• Part of the sewage pipeline made of non-certified plastic.
• One ballast tank is used as a holding tank for untreated sewage. It is not recorded in the ISPP Certificate.
  Refer to:
  
  • Recommendation on international effluent standards and guidelines for performance tests for sewage treatment plants (resolution MEPC.2(VI))
  • Revised guidelines on implementation of effluent standards and performance tests for sewage treatment plants adopted by the MEPC (resolution MEPC.159(55))
  • 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants (resolution MEPC.227(64), as amended by resolution MEPC.284(70))

MARPOL Annex V – Prevention of Pollution by Garbage:

• Main garbage storage area found dirty, deck under the gratings littered, garbage drums found full, and garbage stowed outside of drums.
• Garbage found stored in non-authorised areas ( winch hydraulic room, chemical storeroom, on deck). The deck was found oily.
• Garbage receptacles found without covers or with poorly fitting covers.

MARPOL Annex VI – Prevention of Air Pollution from Ships:

• SEEMP Parts 2 and 3 not found onboard.
  Regulation 26 requires that each ship keeps on board a ship-specific Ship Energy Efficiency Management Plan (SEEMP).
  
• The vessel is equipped with an incinerator indicated in the Garbage Management Plan and in the MARPOL Annex V statement, but isn’t listed in the IAPP supplement.

MLC 2006 Title 1:

• One seafarer’s medical certificate had expired 4 months before the date of Inspection.
  Standard A1.2 states that If the period of validity of a certificate expires in the course of a voyage, the certificate shall continue in force until the next port of call where the seafarer can obtain a medical certificate from a qualified medical practitioner, provided that the period shall not exceed three months.

MLC 2006 Title 2:

• Several seafarers’ SEAs were found expired.

MLC 2006 Title 3:

• Air Conditioning was found out of order. C/E was unable to start ventilation.
• Water leakages from A/C unit.
• Galley extraction hood found dirty of grease. Cockroaches and mosquitos were noted in the galley. Crew sanitary facilities of crew members’ cabin basin not working. Toilets leaking or not flushing. The bridge toilet was obstructed.
• In several cabins it was found that hot water taps were inoperative, shower curtains missing, WCs inoperative, and water leakage from WCs and basins.
  Standard A3.1 Paragraph 11 requires all seafarers to have convenient access to sanitary facilities meeting minimum standards of health and hygiene and reasonable standards of comfort., with separate sanitary facilities being provided for men and women.
  Standard A3.1 paragraph 18 requires frequent inspections to be performed to ensure that seafarer accommodation is clean, decently habitable, and maintained in a good state of repair. The results of these inspections are to be recorded and available for review.
  

MLC 2006 Title 4:

• Washing machines stowed inside the shower room.
• Span Gas for portable gas detector calibration and bump testing missing.
• Many oil and fuel leakages were found in the Engine Room from the main engine and generators.
  Standard A4.3 requires that reasonable precautions to prevent occupational accidents, injuries, and diseases on board the ship, including through the provision of all necessary appropriately sized personal protective equipment and measures to reduce and prevent the risk of exposure to harmful levels of ambient factors and chemicals, be adopted.

ICLL (Load Line):

• Cargo hold hatch cover not closing due to damaged hydraulic pipeline.
• Doors to the aft store and refrigerator room could not be closed due to power cables feeding portable fans to cool air compressors.
  Annex 1 Regulation 16 states that the means for securing and maintaining weather-tightness shall be to the satisfaction of the Administration. The arrangements shall ensure that the tightness can be maintained in any sea conditions.
  

STCW Convention:

• Flag State endorsements for 3 Officers not found onboard.
  Regulation I/2 states that any certificate required by the Convention must be kept available in its original form on board the ship on which the holder is serving. If an electronic form is used, the minimum required data must be accessible as defined by the Administration in accordance with the STCW Code, which is necessary to initiate a verification procedure.
• No signature found on several ‘familiarisation with emergency systems’ forms. No familiarisation forms were found onboard for some seafarers.
• Responsible crew members not familiarised with emergency steering gear operations.
• SOLAS Training Manual not ship-specific.
  Regulation I/14 1.5 requires the company to ensure that seafarers, on being assigned to any of its ships, are familiarized with their specific duties and with all ship arrangements, installations, equipment, procedures, and ship characteristics that are relevant to their routine or emergency duties;
  

Act now

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

Shipowners / Managers / Operators are requested to pay special attention to those deficiencies, note the Regulations’ requirements, and ensure compliance with all Conventions / Codes and MSC / MEPC Circulars.