PSC Case Study : Bulk carrier Detention in Rotterdam

1/ Ship background & PSCI Eligibility

The 12 years old ship (YoB 2012, Built in China) was assessed with a PSC Inspection Window (IWOD) Open given the Risk Profile of the ship and the Manager in the MoU area. The ship was eligible for inspection, as she had an inspection window opened for inspection in Paris MoU since 06/04/2021.

The ship’s Manager (DOC holder) manages a fleet of 5 Bulk Carriers (1 Panamax, 2 Handymax & 2 Handysize ) ships.

The ship’s PSC history during Last 36 Months included 4 inspections as below (all of them out of Paris MoU):

The ship had been inspected in Paris MoU for the last time in Klaipeda, Lithuania back in 2020 with zero deficiencies As mentioned above the Inspection Window was opened for inspection and Managing Company should have been prepared for expanded inspection on the ship.

2/ Manager Background

Manager’s PSC record the Last 5 years (2018-2022) included 74 inspections resulting in 162 deficiencies and 3 detentions. The inspections were mostly distributed to Tokyo, Paris, Vina Del Mar,Med MoU followed by Black Sea MoU ,USCG. Manager’s Deficiency per inspection (DPI) is 2.19 (while the Global Benchmark for similar aged and type ships is 1.98) and the detention ratio (DER) is 4.05% (while the Global Benchmark for similar fleet is 2.57%).

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 Rotterdam (Port UNLOCODE NLRTM )  for the period of the last 36 months, (prior this inspection) there were 497 inspections on Bulk Carriers resulted 10 detentions. Port’s detention Rate (DER) is 2.01% which is higher than the Global Average for ports inspecting Bulk Carriers (1.71%).

Port’s Deficiency per Inspection (DPI) the last 36M is 2.89, 2 times higher than  Global Average for ports inspecting Bulk Carriers (1.21).

Above statistics show that Rotterdam, Netherlands is a challenging port for Bulk Carriers, however the Port KPIs are not extreme higher than the Global Average.

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 Australia was within 6 months, so the ships was not Eligible for inspection. However as  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 9/6/2023.

The ship inspection ratio (SIR) for the unique ships called/inspected the last 12M in Rotterdam Port was 24%, meaning that 3 out of 10 unique Bulk Carriers called in Rotterdam 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 Rotterdam and PSCO boarded for inspection and to check the ship’s safety status and condition. The result of the PSC inspection was 35 deficiencies (8 detainable). As it is expected in such situations the code 15150- ISM  was marked to engage Manager to verification of ISM Implementation on board through ISM Audit.

The breakdown of the Deficiency Areas 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 indication that any ship may be detained if 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. Targeted ship or Manager: The Manager’s performance in MoU and ship’s previous history may lead the PSCO to a stricter inspection leading to detailed checking on practices on board.

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 Rotterdam for Bulk Carriers in its full extent generates a specific checklist including 72 items analyzed in detail. This checklist includes all detainable items identified during inspection, and overall, 24 out of 35 findings during 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:

1. Ship’s and manager’s PSC history in specific area was problematic and identified from MoU
2. The areas that a ship is exposed to a detailed inspection (as most PSC Officers are very competent to check in North-Northwest Europe PSC area) are Fire safety, Safety of Navigation, Pollution Prevention, LSA, MLC and Propulsion & Machinery.
3. As PSC inspections aim to identify safety gaps onboard, having too many technical/procedural issues unattended will possibly lead to detention.
4. Extreme Caution should be exercised on the handling of the ISM Codes It is highly recommended that an additional audit onboard the ship is carried out to verify 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

Appendix 1

List of deficiencies in Rotterdam Inspection