Measures to improve compliance of RMI vessels in US ports

The detention rate of RMI flagged vessels in US ports has increased

The Republic of the Marshall Inslands issued notice to inform and raise the awareness of shipowners, operators, Masters, and officers and Recognized Organizations (ROs) of the recent increase in detentions of vessels, including Republic of the Marshall Islands (RMI) flagged vessels, calling in United States (US) ports and to reinforce performance and compliance measures as provided for in the RMI Maritime Act (MI-107) and RMI Regulations (MI-108). These performance and compliance measures are for the benefit of the entire RMI registered fleet and are not intended to penalize a ship, its crew, shipowners, or operators.

All vessels calling at any port, including US ports are required to comply fully with national and international standards for safety, security, environmental protection and the welfare of seafarers.

The RMI Maritime Administrator has noted a marked increase in the number of ships being detained due to a single substandard condition. Although the Administrator frequently publishes Marine Notices (MNs), Marine Safety Advisories (MSAs) and other guidance regarding prevention methods, substandard conditions are still being found during port State control (PSC) examinations and other boardings.

Such conditions include: a blocked or tied open quick closing fuel oil valve; the hypermist fire extinguishing system not ready for use, not lined up in automatic mode or with the water supply valve shut rather than open; inoperable oily water separator (OWS) or oil content meter (OCM) or not being able to demonstrate proper operation of the OWS and OCM; failure of the crew to adequately carry out a fire or abandon ship drill; items such as smoke detectors rendered inoperable by actions of the crew; substandard cleanliness or condition of the engine room; and/or failure to report inoperable equipment, such as: fire dampers or other fire protection and extinguishing systems; and/or emergency fire pumps not fully operational or not able to take suction in ballast condition

In the first two quarters of the 2015 calendar year, the detention rate of RMI flagged vessels in US ports has increased to a level more than double the previous year.

The increase in PSC detentions appears to be due to a number of factors including: non-reporting of inoperable equipment or systems; an overall lack of maintenance of critical shipboard systems; a lack of preparedness for a PSC examination including a lack of knowledge of the crew to successfully demonstrate normal shipboard equipment and procedures; and an increased scrutiny of vessel compliance and crew performance by PSC officials.

At this current rate and without the attention of all parties involved in the operation of a ship, it is likely that the RMI will not be able to sustain its US Coast Guard (USCG) QUALSHIP 21 status.

The Administrator has noted that well operated ships are being detained for a single substandard condition. Therefore, the Administrator urges all shipowners, operators, Masters, and officers, and ROs to assess their applicable procedures and operations, the capability of crewmembers, and the effectiveness of safety management systems.

Applicability

In order to maintain the high quality of the RMI registered fleet, this Notice applies to all RMI flagged vessels calling at US ports. The Administrator will apply the performance and compliance measures found herein to the degree necessary on a case-by-case basis.

Requirements

Prior to Arrival at a US Port

1. All vessels entering US ports are required to submit a copy of the Notice of Arrival (NOA) to the Administrator at [email protected] when submitting the NOA to the USCG. Repeated failure to submit a copy of the NOA to the Administrator may result in actions by the Administrator such as an additional audit of the vessel or the Company’s Safety Management System (SMS).
2. All vessels arriving at US ports are required to list any non-operational equipment or systems on their NOA. Proactively listing inoperative equipment on the NOA and notifying the Administrator can often prevent adverse PSC actions. Therefore, vessel operators that fail to list non-operational equipment or systems on the NOA may be subject to an immediate International Safety Management (ISM) Code audit and/or a letter of warning to the Master. Repeated failures to report non-operational equipment or systems on the NOA may result in suspension of the Master’s RMI seafarer documents and/or an additional audit of the vessel or Company SMS.
3. Prior to arrival in a US port, the Master and Chief Engineer shall complete, sign, and submit the Critical Items Checklist found in Appendix 1 of this Notice. Failure to complete the Critical Items Checklist may be cause for suspension of the officers’ RMI seafarer documents and/or an additional audit of the vessel or Company SMS.

Detentions in US Ports

Any vessel that is detained in a US port will be subject to:

1. an immediate Special Inspection by the Administrator prior to sailing in order to determine the root cause of the detention (all costs resulting from the detention including the cost of the Special Inspection and any administrative actions made necessary as a result of the detention may be charged to the shipowner or operator);
2. an additional survey by the RO for any and all statutory certificates that were the subject of the deficiency(ies) causing the vessel to be detained; and
3. where an ISM deficiency resulted in the detention, an ISM audit of the SMS onboard the vessel will be required prior to sailing, the scope of which shall be as stipulated by the Administrator.

Any ISM Company for a vessel detained in a US port will be subject to the:

1. submission of a corrective action plan by the Company to address the underlying root cause of the substandard condition or conditions which resulted in the detention of the vessel; and
2. at the discretion of the Administrator, an immediate audit of the Company’s Document of Compliance (DOC), the scope of which shall be as stipulated by the Administrator.

Please click below to view RMI Notice

Source: The Republic of the Marshall Islands