Following preliminary results published in January, the Black Sea MoU has now issued its final report on the Concentrated Inspection Campaign (CIC) on Emergency Systems and Procedures, that took place from 1st September 2019 to 30th November 2019.
This campaign involved all member States of the BS MoU to the Emergency Systems and Procedures, and was conducted in conjunction with Tokyo MoU, Paris MoU and other MoUs. The campaign took place under the campaign coordination of Turkey, using Paris and Tokyo MoUs guidelines and questionnaire.
During the campaign, a total of 781 inspections took place, involving 781 individual ships. A total of 139 questionnaires had at least a non-compliance to any of the requirements, resulting 17.8% of CIC inspections.
Key findings
- The results of the CIC reveal a total of 316 non-conformities and 139 CIC inspections with at least one non-compliant response recorded, as a direct result of this campaign on board 781 individual vessel subjected to CIC inspections.
- A total 139 questionnaires had at least one non-compliant response, which resulted 17.8% of CIC inspections not conforming the requirements set out in questionnaire. The overall average per cent of non-conformities was 6.6.
- CIC inspected ships not detained for CIC-related deficiencies which comprises no CIC topic related detentions.
-The most favourable results, related to whether:
- bunker delivery notes indicate that fuel oils delivered and used on board is not exceeding the maximum allowed sulphur content appropriate -Q2 (0.3%);
- bunker delivery notes kept available on board for the required period of 3 years -Q1 (1.2%); and
- ships which are using separate fuel oils to comply with the maximum sulphur content of 0.10% m/m in fuel oil and entering or leaving SOx emission control areas record detailed information showing that the ship has completed/initiated the change-over in the logbook prescribed by the Administration -Q5 (1.2%).
Lack of alternative arrangements, (e.g. scrubbers) installed on board according to regulation 4.1 approved by the flag State (46.32%); lack of rechargeable systems containing ozone-depleting substances, have the ozone-depleting substances record book maintained (30.46%) raise concerns.
-The most un-favourable results are: 4, 6 and 7, which asked for:
-Question 4: Are alternative arrangements, (e.g. scrubbers) installed on board according to regulation 4.1 approved by the flag State? (46.3%)
-Question 6: Do ships which have rechargeable systems containing ozone-depleting substances (refer to the supplement to the IAPP Certificate, item 2.1) have the ozonedepleting substances record book maintained? (30.5%)
-Question 7: Where an Approved Method in accordance with Annex VI, regulations 13.7.1-13.7.5 is installed, has such an installation been confirmed by a survey using the verification procedure specified in the Approved Method File, including appropriate notation on the ship’s International Air Pollution Prevention Certificate of the presence of the Approved Method? (21.2%).
A total of 206 (65.2%) non-conformities out of 319 total non-conformities due to: Q4: 63 (46.3%); Q6: 92 (30.5%) and Q7: 51 (21.6%).
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Compliance to the requirements which non-compliance might be considered detentions:
-Question 2: Do bunker delivery notes indicate that fuel oils delivered and used on board is not exceeding the maximum allowed sulphur content, as appropriate? (99.9%)
-Question 4: Are alternative arrangements, (e.g. scrubbers) installed on board according to regulation 4.1 approved by the flag State? (53.7%).
By flag state
- Most inspections were carried out on board ships flying the flags of Panama with 128 (16.4%) inspections, Marshall Islands with 90 (11.5%) inspections, Malta with 80 (10.2%) inspections and Turkey with 70 (7.1%) inspections.
- A total of 24 flags, covering 9.8% of the total CIC inspections, had no CIC topic nonconformities
By ship type
- A total of 271 (38.2%) CIC inspections concerned bulk carriers ships, followed by general cargo/multi-purpose with 264 (33.8%) inspections, oil tankers with 122 (15.6%) inspections and chemical tankers with 52 (6.6%) inspections, which comprises 736 (94.24%) total CIC inspections.
By ship age
- By ship age, ships under 15 years reported the most favourable results, but the situation worsened as the age of ships increased.
- Older ships, particularly those 30 years and older, reported the least favourable results. Although they comprised 20.6% of the total non-compliant they accounted for 10.8% of total inconvenience of 315.
Recommendations
Non-compliance of the exhibition of navigation/signal lights in accordance with the requirements of Emergency Systems and Procedures. Thereby, it is recommended:
- Basic findings of the report in general, analysis of the responses to the questionnaire and breakdown of major non-conformities by ship flag, ship type to be submitted IMO III SubCommittee.
- Master and crew familiarity with essential shipboard procedures in the approved VOC Management Plan relating to the prevention of air pollution from ships.
- PSC Officers should be instructed to submit CIC Questionnaire for each initial PSC inspection during the campaign; and
- Continue to put emphasis on the vital requirements of the MARPOL ANNEXES when performing PSC inspections, particularly the requirements that raised the most concern in the CIC Emergency Systems and Procedures.
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