Recently, an RMI-flagged ship proceeded into a US port with a disconnected Quick Closing Valve (QCV) which created a dangerous and unsafe condition. The ship was inspected by the US Coast Guard and detained for this unsafe condition. Prior to port entry, the Master and Chief Engineer certified to the RMI Administrator on the MSD 340 that the QCVs were properly set and not blocked or disconnected.
The MSD 340 and the requirements for its use are to ensure that Masters, Chief Engineers, and all persons-in-charge verify critical items on board their ship prior to entry into a US port. Additionally, it is to ensure the vessel is in compliance with critical safety, security, and environmental protection standards and is safe to proceed into port. RMI Marine Notice 5-034-5, Measures to Improve Compliance of RMI-Flagged Vessels in US Ports, states:
"Prior to arrival in a US port, the Master and Chief Engineer shall complete, sign, and submit the Critical Items Checklist (MSD 340). Failure to complete the MSD 340 may be cause for suspension of the officers’ RMI seafarer documents and/or an additional audit of the vessel or Company SMS."
The Administrator underscores that QCVs are to be maintained, connected, and free of intentional blocking devices at all times. The proper use and maintenance of these valves is critical to ensuring that fuel sources are secured in the event of machinery space fires. Both the Administrator and the USCG place a great deal of importance and scrutiny on these devices as part of their routine flag and port State control examinations.
Owners, Operators, Masters, Officers, and crew members must take note of the specific requirement for the completion and certification of the MSD 340. Accurate verification of all items set forth on the MSD 340 is extremely important to avoid unsafe conditions onboard RMI vessels and to avoid adverse actions by port State control authorities.
Further details may be found herebelow: