The US Coast Guard (USCG) QUALSHIP 21 program, a program the RMI uses as a measure of the quality of its fleet, has revealed an increased level of detentions in the past two years. Although the detention rate has dropped from 2015 to 2016, it is still significantly higher than previous years.
RMI notes that all vessels calling in any port, including US ports, must comply fully with and demonstrate compliance with all national and international standards for safety, security, environmental protection and the welfare of seafarers as required by MI-108 §2.11.3.
Prior to Arrival at a US Port
In accordance with RMI Marine Notice 2-011-20, all vessels entering US ports are required to submit a copy of the Notice of Arrival (NOA) to the Administrator at NOA@register-iri.com when submitting the NOA to the USCG 96 HOURS PRIOR TO ENTERING U.S. WATERS. 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).
- 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 or safety reprimand to the Master and/or Chief Engineer. Repeated failures to report non-operational equipment or systems on the NOA may result in suspension of the Master’s and Chief Engineer’s RMI seafarer documents and/or an additional audit of the vessel or Company SMS.
- Prior to arrival in a US port, the Master and Chief Engineer shall complete, sign, and submit the Critical Items Checklist (RMI Form MSD 340). The MSD 340 shall be emailed to NOA@register-iri.com in conjunction with the eNOA which is submitted 96 hours prior to arrival. The latest version of the form may be downloaded from the website at www.register-iri.com. Failure to complete the Critical Items Checklist (MSD 340) may be cause for suspension of the Master’s and Chief Engineer’s RMI seafarer documents and/or an additional audit of the vessel or Company SMS. In the event of consecutive US port calls, the Critical Items Checklist (MSD 340) need only be submitted prior to the first US port. An updated Critical Items Checklist (MSD 340) must be submitted if the condition of the vessel changes during these consecutive port calls or after the vessel calls a port outside the US.
Detentions in US Ports
Any vessel that is detained in a US port is subject to:
- an immediate Special Inspection by the Administrator prior to sailing 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 because of the detention may be charged to the shipowner or operator);
- 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
- 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 is subject to the:
- 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,
- 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.
Owners are advised that ROs are required to notify the RMI immediately, regardless of whether or not the vessel is detained, when they are requested to clear PSC deficiency codes 30, 17, and/or 60 as a result of a PSC examination.
Explore more in the official marine notice: