In nearly every case, where a vessel is detained for an existing deficiency, the Administration was not provided with an Advance Notice of Arrival (ANOA) or a completed Pre Arrival Checklist, Liberia commented. Therefore, they have been meeting with PSC authorities to establish better communications and understanding of the flag Administration’s Compliance Assistance (CAP) Program. The Administration frequently updates its prearrival checklists to identify the most common detainable deficiencies to provide value to the CAP.
When PSC inspectors are made aware that the Administration was informed of inoperative equipment or other deficiencies, and that appropriate corrective action was initiated, the PSC is more likely to let the Administration continue to address compliance.
''It is very unfortunate that in the majority of cases the PSC detention was preventable. For example, recently a vessel was detained because of a lack of fire safety equipment.'' Liberia Maritime Administation said in a relevant marine notice.
In that case, the Master sent all of the portable fire extinguishers ashore for servicing and the vessel was engaged in bunkering operations during which time the USCG boarded to conduct the Port State Control Inspection. Other examples include closing the water supply valve to the high pressure Water Mist System and leaving the automatic fuel shut off valves inoperable due to blocks of wood or nuts preventing the system from shutting off the fuel supply.
''Recently we are seeing more detentions for MLC issue related to wage payment, seafarers on board with expired SEAs, noncompliance with the hours of rest, and a Master’s and Chief Mates direction to the seafarers not to use the complaint procedure established by the company.'' Liberia explained.
Other detainable deficiencies are due to existing conditions where there is no evidence of corrective action or action initiated to mitigate the impact of defective equipment required by the applicable international conventions.
Detainable deficiencies primarily concern:
- Defective firefighting equipment;
- Defective navigation equipment;
- Defective fire dampers;
- Defective OWS;
- Defective emergency generators;
- Lack of appropriate updated charts;
- Inadequate maintenance;
- Ineffective SMS;
MLC related detentions are the following:
- Insufficient hours of rest;
- Seafarers wages not paid monthly;
- SEAs expired;
- Complaint procedures not implemented onboard;
Sending an ANOA in time can reduce any delays than can be caused by detention and noncompliance with the international conventions.
For this reason Masters and/or DPA’s are advised to provide an ANOA at least 4 work days prior their arrival at the first port of call for Australia, China, Europe, or the USA. In addition, if possible a copy of an ANOA provided to the Coastal State will be enough with a report of any defective equipment and actions taken to mitigate same. The ANOA must contain the following information:
- Vessel Name
- IMO Number
- Pot of Arrival
- Date of Arrival
- Contact information for the local agent
- Defective Equipment
- Vessel's Previous Port
- Date of departure
DPAs and Master’s should be prepared for Port State Control inspections and drills. At least every other month and more frequently even, a completed checklist regarding defective equipment, or possible noncompliance and corrective action should be included with the ANOA. This will help in eliminating possible problems with PSC.