During October of 2023 an MR1/MR2 Tanker , inspected in Zhuhai, China (Port UNLOCODE CNZUH) resulting in a detention with 25 Deficiencies. Given the high number of deficiencies recorded, the scope of the case study is to illuminate the case, causes and lessons to be learned.
1/ Ship background & PSCI Eligibility
The 18 years old ship (YoB 2025, Built in South Korea) 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 Tokyo MoU since 29/07/2021.
The ship’s Manager (DOC holder) manages a fleet of 13 Tankers (MR1/MR2, LR1/LR2, Suezmax).
The ship’s PSC history during Last 36 Months included 4 inspections as below:
|5/9/2023||Novorossiisk||RUNVS||Russia||Black Sea MoU||Yes||No||3|
|16/3/2022||Port of Dakar||SNDKR||Senegal||Abuja MoU||Yes||No||0|
|3/2/2021||Novorossiisk||RUNVS||Russia||Black Sea MoU||Yes||No||0|
The ship had been inspected in Tokyo MoU for the last time in Manila, Philippines back in 2021 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 (prior the detention)
Manager’s PSC record the Last 36M (Oct 20-Sept. 23) included 14 inspections resulting in 58 deficiencies and 0 detentions. The inspections were mostly conducted to Black Sea MoU (11). Manager’s Deficiency per inspection (DPI) was 4.14 (while the Global Benchmark for similar aged and type ships is 1.47) and the detention ratio (DER) was 0% (while the Global Benchmark for similar fleet is 2.23%).
Manager’s Risk Profile in Tokyo MoU was calculated to be Medium based on Last 36M PSC History in MoU.
3/ Port Background
In Zhuhai (Port UNLOCODE CNZUH) for the period of the last 36 months, (prior this inspection) there were 35 inspections on Tankers resulted 3 detentions. Port’s detention Rate (DER) is 8.47% which is almost 8 times higher than the Global Average for ports inspecting Tankers (1.73%).
Port’s Deficiency per Inspection (DPI) the last 36M is 2.50, almost 2 times higher than Global Average for ports inspecting Tankers (1.20).
Above statistics show that Zhuhai, China is a challenging port for Tankers, as the Port KPIs are 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 Tokyo MoU was back in 2021, so the ship was Eligible for inspection. The ship was rated SRS and the Manager’s performance in MoU was marked as medium, the Inspection window opened date was opened for inspection, since 29/12/2021.
The ship inspection ratio (SIR) for the unique ships called/inspected the last 12M in Zhuhai Port was 10%, meaning that 1 out of 10 unique Tankers called in Zhuhai 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 marked some risks (red flag) as below:
- Ship Deficiency Per Inspection – L12M > from Global average
- Ship Age Risk (>15 years old)
Manager PSC history within MoU was assessed as medium risked. Some parameters were red flag, specifically,
- Manager Inspection In Regime (0 inspections meaning that the manager had no experience in MoU )
- Manager DPI in Port
- Manager Deficiency Profile vs Port Top 20 Deficiency Codes
The most dangerous set of parameters was the Port related factors which 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
Additionally the Concentrated Inspection Campaign on Fire Safety was in progress during ship’s PSC inspection.
Overall POCRA Assessment
Taking into consideration the above Inspection Probability and Inspection Severity the overall POCRA assessment was that the call risk was High.
This should be an alert factor for preparation.
5/ PSC Inspection Result
Ship called Zhuhai am and PSCO boarded for inspection and to check the ship’s safety status and condition. The result of the PSC inspection was 25 deficiencies (7 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:
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:
a) Inadequate identification that the ship will be inspected : It is evident in this case by the end result
b) 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
c) Inadequate Concentrated Inspection Campaign Preparation: ( 9 deficiencies, 3 of them detainable were CiC related)
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 Zhusan for Tankers in its full extent generates a specific checklist including 33 items analyzed in detail. This checklist includes all detainable items identified during inspection, and overall, 20 out of 25 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:
- Ship’s CiC (Fire Safety) preparation and implementation on board was of a low level.
- Nine (9) deficiencies on Fire safety and three (3) on LSA are to many, as the SOLAS weekly inspections are covering such issues.
- The 3 detainable deficiencies on Fire Safety indicate that there was no CiC awareness or preparation
- As PSC inspections aim to identify safety gaps onboard, having too many technical/procedural issues unattended will possibly lead to detention.
- Extreme Caution should be exercised on the handling of the ISM Codes 15xxx. 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
10/ About RISK4SEA Port Call Risk Assessment
Port Call Risk Assessment (POCRA) is an automated Risk Assessment of Ship, Manager and Port Specific Risk Factors to identify PSC Inspection, Probability, Severity and overall assessment and generate a Detailed Focus PSC Inspection Checklist in order to prepare for a PSC inspection. Learn more at https://risk4sea.com/pocra/
RISK4SEA (www.risk4sea.com) is a SaaS PSC Intelligence platform, illuminating PSC performance to Prepare/Assess PSC inspections, Benchmark against competition and Automate PSC functions & alerts to eliminate detentions and minimize OPEX.
List of deficiencies in Zhuhai Inspection
|Deficiency||#||Detainable||Included in POCRA checklist|
|01201 – Certificates for master and officers||1||No||Yes|
|02127 – Safe access to tanker bows||1||Yes||Yes|
|03102 – Freeboard marks||1||Yes||Yes|
|03105 – Covers (hatchway-, portable-, tarpaulins, etc.)||1||No||No|
|04103 – Emergency, lighting, batteries, and switches||1||No||Yes|
|07101 – Fire prevention structural integrity||1||Yes||Yes|
|07105 – Fire doors/openings in fire-resisting divisions||2||No||Yes|
|07109 – Fixed fire extinguishing installation||1||No||Yes|
|07109 – Fixed fire extinguishing installation||2||Yes||Yes|
|07111 – Personal equipment for fire safety||1||No||Yes|
|07116 – Ventilation||1||No||Yes|
|07199 – Other (fire safety)||1||No||Yes|
|08103 – Fire alarm||1||No||Yes|
|10101 – Pilot ladders and hoist/pilot transfer arrangements||1||No||No|
|10109 – Lights, shapes, sound-signals||1||Yes||Yes|
|10113 – Automatic identification system (AIS)||1||No||No|
|11101 – Lifeboats||1||No||Yes|
|11113 – Launching arrangements for rescue boats||1||No||No|
|11135 – Maintenance of Life Saving Appliances||1||No||Yes|
|13102 – Auxiliary engine||1||No||No|
|13103 – Gauges, thermometers, etc.||1||No||No|
|15150 – ISM||1||Yes||Yes|
|99102 – Other (SOLAS operational)||1||No||Yes|