PSC Case Study: Bulk carrier detained in Gibraltar

1/ Ship background

The 13 years old ship (YoB 2010, Built in China) was assessed with an Inspection Window Open given the Risk Profile of the ship and the Manager in the MoU area. The ship’s DOC holder is managing a fleet of Bulk Carriers with a total of 7 ships. It is worth mentioning that the ship has been classed in the same IACS classification society since 2010.

The ship’s PSC history during Last 36 Months included 9 inspections as below:

The ship had never been detained since the date of built.

Vessel had an inspection in Trieste (Paris MoU) resulting 9 deficiencies

The last deficiency of 15150 – ISM indicates that PSCO recommended rectification actions within SMS frame work and it was to be expected by Company that in their next call within Paris MoU, the ship would be subject to follow up inspection for verification of rectified items.

The vessel called Netherlands (Vlissingen) after 1 month and as expected it was inspected. The inspection concluded in 9 deficiencies again.

The inspection revealed that 6 of previous deficiencies were rectified, 2 remained (VDR and endorsements) and 6 new deficiencies were marked.

PSCO did not detain the ship (as the action code was 17 for the deficiencies) and gave one more opportunity to the Manager to implement rectification actions and marked the Code 15150 – ISM to guide the rectification plan through SMS.

Manager should have been alerted that during the next call in Paris MoU port, the vessel was targeted (after 2 inspections with deficiencies and ISM related problems)

2/ Manager Background

Manager’s PSC record the Last 5 years (2018-2022) was 134 inspections resulting in 392 deficiencies and 7 detentions. The  inspections were almost equally distributed to Paris, Tokyo, Vina del Mar MoU and USCG. Manager’s Deficiency per inspection (DPI) is 2.93 (while the Global Benchmark for similar aged and type ships is 1.68) and the detention ratio (DER) is 5.22% (while the Global Benchmark for similar fleet is 2.13%).

Manager’s Risk Profile in Paris MoU was calculated to be Very Low based on Last 36M PSC History in MoU.

3/ Port Background

In (Port UNLOCODE GIGIB )  for the period of the last 36 months, (prior this inspection) there were 195 inspections on Bulk Carriers resulted 5 detentions. Port’s detention Rate (DER) is 2.56% which is higher than the Global Average for ports inspecting Bulk Carriers (1.96%).

Port’s Deficiency per Inspection (DPI) the last 36M is 0.78, almost half of the Global Average for ports inspecting Bulk Carriers (1.49).

Above statistics show that Gibraltar port is not a challenging port.

4/ Port Call Risk Assessment (POCRA)

The PSCI has been analyzed with the Port Call Risk Assessment (POCRA) Risk Assessment Tool of the RISK4SEA Platform with the following outcome 

PSC Inspection Probability

The ship’s prior inspection in Paris MoU was 26/07/2022, and the ship was rated HRS and the Manager’s performance in MoU was marked as very low the Inspection window opened date was opened for inspection, since December 2022

The ship inspection ratio (SIR) the last 12M in Gibraltar Port was 33%, meaning that 4 out of 10 unique Bulk Carriers conducted call in Gibraltar were inspected.

As the ship had an open Inspection window open date and the PSC history of ship and manager was well known and assessed by the local PSC authorities, the inspection probability was assessed as CERTAIN

PSC inspection Severity

Ship related factors were mostly high risk (red flagged) due to previous ship’s and Manager PSC history within MoU.

Manager PSC history within MoU was also assessed as high risked. Several parameters were red flag, specifically,

• Manager Inspections in MoU/PSC Regime
• Manager DPI in Port
• Ship DPI with the Manager
• Manager Detention Profile vs Port Detainable Items
• Manager Deficiency Profile vs Port Top 20 Deficiency Codes

Port related factors were also assessed to be high risk (red flag) as below factors are higher than relevant ports worldwide for General Cargo Ships’ inspections.

• Port Deficiency Codes Spread
• Port Detention Ratio – L12M

Overall POCRA Assessment

Taking into consideration the above Inspection Probability and Inspection Severity the overall POCRA assessment was that the call risk was Critical.

For a ship and a manager with such previous history in the MoU this should be an alert factor for preparation. 

5/ PSC Inspection Result

Ship called Gibraltar for bunkers and a short stay. PSCO boarded for inspection in order to verify the rectification of previous deficiencies and check the ship’s safety status and condition. The result of the PSC inspection was 9 deficiencies (5 detainable). As it is expected in such situations the code 15150 – ISM was marked (as detainable) in order to lead to additional onboard audit to verify the SMS implementation status on board.

Apart this code the vessel was detained for 4 deficiencies and 2 different deficiency areas:

1. 2 deficiencies related to Fire Safety (07105 – Fire doors/openings in fire-resisting divisions, 07199 – Other (fire safety)
2. 2 deficiencies related to Propulsion and auxiliary machinery (13101 – Propulsion main engine, 13103 – Gauges, thermometers, etc. )

The breakdown of the Deficiency Areas (all deficiencies of the 3 inspections in Paris MoU ) that the ship found to be unsafe were:

Having a different look on the breakdown with operational groups for all deficiencies and categories in mind the list of the deficiency findings may be breakdown as follows:

6/ Root Causes

Almost 90% of the ships being detained have NO (Zero) detentions in the 36 months prior to that detention this is a strong and clear indicates that all ships may be detained if they are not properly prepared. Research has provided evidence that the ships are being detained for the following key reasons

1. Inadequate identification that the ship will be inspected : It is evident in this case by the end result
2. Inadequate Preparation of the crew and the ship as a hardware: Numerous deficiencies in the areas where weekly inspections are due (FFA, Safety of Navigation, Propulsion and machinery) are a testimony to that
3. Inadequate follow up to already known deficiencies from previous inspections : The ship marked with repeatedly deficiencies for 3 consecutive inspections in Paris MoU
4. Targeted ship or Manager: The Manager’s performance in port or country and ship’s previous history may lead the PSCO to a stricter inspection leading to detailed checking on practices on board.
5. ISM code 15150 –ISM: This is a “High Risk” code when included in PSC findings, as it creates future PSC actions to next calls in same MoU. If not properly addressed (here it happened 2 times), may lead to an unforeseen detention

Here all above reasons have been observed leading into the obvious result.

7/ POCRA preparation checklist

If the vessel had used the POCRA preparation checklist, the findings may have been resulted differently. The POCRA checklist in Gibraltar for Bulk Carriers in its full extend generates a specific checklist including 44 items analyzed in detailed. This checklist includes all detainable items identified during inspection, and overall,  all the 9 findings during Gibraltar inspection. If the vessel had prepared properly the detention could have been avoided, as all detainable items have been already identified for the ship.

8/Lessons to be Learned

There is a number of lessons to be learned out of this case as follows:

• Ship’s and manager’s PSC history in specific area was problematic and identified from MoU
• The areas that a ship is exposed to a detailed inspection (as most PSC Officers are very competent to check) are Fire safety and Emergency Systems.
• Ship / Manager had not followed up previous findings as required. This cannot go unnoticed from a PSCO boarding the ship.
• As PSC inspections aim to identify safety gaps onboard, having to many technical/procedural issues unattended will possibly lead to detention.
• Be careful how to handle the ISM Code 15150 – ISM. It is highly recommended an additional audit onboard to check SMS implementation (regardless if this is asked by PSCO or not).

9/ Terminology Used

DCS: Deficiency Codes Spread. Number of deficiency codes required to achieve the 100% of the Deficiency Codes in a Post. Alternatively partial indicators may be used such as DCS20, DCS50 or DCS80 te reach 20% 50% or 80% of total deficiencies in Port respectively

Deficiency Profile – Detailed List of all PSC findings with an indication of the Deficiency Code (Detainable or Not)

DER -Detention rate (% of inspections ended with detention)

Detention Profile – – Detailed List of all Detainable PSC findings with an indication of the Deficiency Code

DPI – Deficiencies per Inspection, average

Global Benchmark – The value of the KPI based on the Global statistics for same ship type and age

L12M – Last 12 months period (rolling, at the date of the inspection)

L36M – Last 36 months period (rolling, at the date of the inspection)

POCRA – POrt Call Risk Assessment

SIR – Ship Inspection Ratio – % of unique ships inspected vs unique ships called in port over the last 12 months

UNLOCODE – Standardized UN code for each port/terminal, defined by UN. Please see  UNLOCODE List