The Republic of the Marshall Islands has issued a Marine Safety Advisory to explain the correct method for completing, verifying, and submitting the form ‘Critical Items Checklist’ (MSD 340) to ensure that it accurately reflects the status of the critical items, particularly the Quick Closing Valves (QCVs) and other items that may lead to an unsafe condition onboard an RMI-flagged ship.
Recently an RMI-flagged ship proceeded into a United States (US) port with a blocked QCV which created a dangerous and unsafe condition for the ship, its crew, and the port. The ship was inspected by the US Coast Guard (USCG) and detained for this unsafe condition. Prior to port entry, the Master and Chief Engineer certified to the RMI Maritime Administrator on the MSD 340 that the QCVs were properly set and not blocked.
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 Republic of the Marshall Islands Flagged Vessels in United States 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), which may be found in Appendix 1 of this Notice. 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 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.
The unsafe condition and subsequent detention referred to above was directly attributed to the failure to report or ascertain the status of critical equipment when filling out the MSD 340. The QCV in question was installed in the fuel piping to the main and auxiliary engines. The QCV was physically blocked open and discovered by the port State control officers which led to an immediate port State detention. Senior shipboard personnel erroneously verified that the items on the checklist were completed and submitted the checklist to the Administrator. This unsafe condition and detention of the vessel was avoidable had appropriate action been taken by the Master, Chief Engineer, or the 2nd Assistant Engineer. This case is currently under review by the Administrator.
Other recent misrepresentations made on the MSD 340 that have led to unsafe conditions and adverse port State control actions include:
- inflatable liferafts with hydrostatic release units not properly attached;
- rescue boat engines failing to start;
- hyper-mist systems set to manual mode or in the off position;
- covered smoke detectors;
- Oil Record Book anomalies; and
- poor performance on fire, abandon ship, and confined space entry and rescue drills.
Recommendations
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 in the Marine Safety Notice below
Source: RMI
