PSC inspections during COVID-19: Key considerations and developments

Remote surveys and inspections mean that surveyors do not have to be physically present on board a vessel, which is especially important during these challenging times caused by COVID-19. Remote technology seems to have many benefits; above all, it has made our work and lives easier since the pandemic broke out. For example, not having to travel to the vessel’s location ensured safety, reducing at the same time the carbon footprint.

Namely, the COVID-19 pandemic accelerated the adoption of remote surveys which, according to RINA, are perceived as equivalent in terms of accuracy as the traditional surveys. ‘’Remote technology for surveys has shown its full reliability. Wider adoption and involvement of different players in the industry are now essential to move towards a widely accepted and regulated solution’’ RINA said.

Recent developments

Due to COVID-19 safety constraints and travel restrictions and with the increase of new information and communication technologies, remote inspections became at once part of industry’s activities. For example:

• MOL and Autonomous Control Systems Laboratory Ltd. announced in June 2021 the success of a demonstration test using a made-in-Japan flying drone to inspect the hold of an MOL-operated coal carrier.
• In February 2021, Mitsui O.S.K. Lines, Ltd and its car carrier Orca Ace, gained ClassNK’s Remote Survey (RMSV) notation, which recognizes the vessel’s preparedness for implementing remote surveys.
• In the beginning of 2021, Bureau Veritas (BV) successfully completed an underwater remote survey using the Seasam technology eco-system from Notilo Plus onboard a Corsica linea ship.
• In October 2020, DNV GL and Aker BP jointly conducted a pilot project concerning remote inspections on three of their offshore cranes on the Norwegian Continental Shelf.
• In June 2020, a survey by Bureau Veritas marked the first time ever a Singaporean-flagged harbour tug has undergone a fully accredited annual survey conducted remotely, without a surveyor physically present onboard.

Guidance on remote inspections

In October 2020, OCIMF issued a document providing guidance on commissioning and conducting a Remote Inspection under OCIMF Programmes. In February 2021, ClassNK released “Guidelines for Remote Surveys Ver. 2.0”, including a class notation requirement for the ship with advance preparation for remote surveys. Paris MoU was one of the first MoU to release guidelines concerning the outbreak’s impacts and how the pandemic affects PSC Inspections while other MoUs followed.

For example, Tokyo MOU adopted interim guidance relating to COVID-19 circumstances, in order to protect PSCOs and prevent spread of COVID-19 and for facilitating port State Authorities to apply pragmatic flexibility amid pandemic. Black Sea MoU issued an overview of COVID-19 measures applying to PSC officers in its six member countries: Bulgaria, Georgia, Romania, Russia, Turkey, and Ukraine.

Moving forward

With new technologies and increased digitization, the maritime world is on the edge of a significant transformation. In this regard, the concept of remote surveys must be further developed and put into practice as a tool for securing the future of ship surveys. In this context, OCIMF recommends the following factors to be considered:

• The risk of transmission of COVID-19 due to conducting a physical inspection.
• The existence of cases or symptoms of COVID-19 onboard particularly within 14 days leading up to the date of the proposed inspection.
• An assessment of the vessel’s location and past schedule.
• Travel restrictions to and from the intended inspection location.
• The possibility that a physical inspection of the vessel can be conducted at another port on a future date which will meet the Submitting Company’s assurance needs.
• The possibility that the vessel may already have Inspection Reports available in the relevant Programme
• Database which could allow an assessment of the vessel to satisfy the Submitting Company’s assurance needs.

Factors affecting PSC inspections

In relation to the COVID-19 situation, it may occur that a ship cannot fulfill the requirements of the relevant Instruments or the follow-up on inspection results as would normally be required. As such, Tokyo MoU explains that in case a ship has not complied with the requirements of the surveys, inspections and audits contained in the relevant convention requirements (e.g. SOLAS Chapter I Regulation 7-10 and 14, etc.), the ship must provide evidence to the Port State that the flag State has agreed to an exceptional delay specific to COVID-19.

What is more, in view of the large number of seafarers long overdue for repatriation, Port States are urged to apply an enhanced focus on MLC issues and in particular SEAs, irrelevant of the inspection type. If possible deviations are found, in particular regarding repatriation and/or crew rotations for any crew, Port State Control response will take into account the following general principles, according to Tokyo MoU guidance:

1. Where contract extensions are necessary and fall within the eleven-month default maximum, they should be undertaken in accordance with the national law of the flag State.
2. Contract extensions beyond the eleven-month default maximum should be avoided unless circumstances beyond the control of the ship owner or operator prevent repatriation. In such cases, the ship owner or operators should maintain evidence of actions taken to avoid extending the contracts and details of planned measures to repatriate the seafarers. This documentation should include evidence that the flag State has been advised of the repatriation plan.
3. Port State Control Authorities should be aware of restrictions within their own jurisdiction that may prevent crew changes, and take this into account when considering port State control action.
4. Port State Control Authorities should pay particular attention to situations where the eleven-month default maximum period of service has been or is likely to be exceeded. A pragmatic approach to port State control should be taken.