PSC Enforcement

Question 1

When to Expand Exam

Answer 1

When clear grounds exist, expand the examination. Reference (b), MSM II, D1, defines clear grounds, which is related to the term nonconforming ship, as evidence that the ship, its equipment or crew are in nonconformance with regulatory requirements. Expanded exams need to focus on areas where clear grounds have been established, and not delve into other systems or processes unless the PSCO’s observations or impressions clearly lead there

Question 2

Conditions of Class

Answer 2

Generally, if the ship brings a current, outstanding condition of class to the PSCO’s attention, a deficiency is not issued, because the ship’s certificate issuing authority is already aware of the issue, and has determined a pathway to compliance.

Question 3

Deficiency Writing Requirement

Answer 3

Reference (b), MSM II, D1, provides policy for deficiency writing. PSCOs must document deficiencies on the U.S. Coast Guard Port State Control Report of Inspection, Form CG-5437B, providing a description of the deficiency in a direct, succinct statement that contains two elements:

• The regulatory standard the ship does not meet.
• Why the ship does not meet the regulatory standard.

List deficiencies on the Form B in order of severity, with the most severe first.

Question 4

Rescue Boat Deficiency Write-up example

Answer 4

Rescue boat shall be stowed in a state of continuous readiness for launching in not more than five minutes. The davit used for launching the rescue boat and davit launched inflatable liferaft was not operating properly. The davit continuously lost hydraulic pressure within approximately one to two seconds when the slewing control was activated; Total slewing time of six minutes from stowed to launch position. The slewing time from the stowed resuce boat position to the davit launched liferaft stowed position was approximately eight minutes. The intermittent operation of the davit hydraulics delays the launching of the rescue boat and inflatable liferaft beyond the time allowed. Cite: Reference (e), SOLAS (14) III/14.1. (17ac)

Question 5

ECA Fuel Write-up example

Answer 5

While ships are operating within an emission control area, the sulphur content of the fuel oil used onboard ships does not exceed 0.10 percent m/m (mass of sulphur dioxide per total mass of the emission) after 01 January 2015. Bunker delivery notes showed for a period of over two years, from 02 March 2016 to 11 July 2018, the range of sulphur content from 0.30 % m/m to 0.318 % m/m. This fuel oil was being used within the United States Caribbean Sea Emission Control Areas. A sample tested by a third party fuel supplier confirmed that last product bunkered was above the permissible limit. Cite: Reference (h), MARPOL VI/14.4.3 (30ac).