Marine: Types of Safety Deficiencies Leading To Detentions

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SQEMARINE SAFETY | QUALITY | ENVIRONMENT

Circular 2017-05: USCG PSC Annual Report 2016

General

The US Coast Guard has published its 2016 Annual Report on Port State Control. This annual report
details the statistics related to enforcement of the international requirements with regard to foreign
flagged vessels trading in U.S. ports.

Facts for 2016

In 2016, a total of 9,859 individual vessels, from 83 different flag administrations, made 81,877 port
calls to the United States.
As reported by the statistics derived from USCG Port State Control examinations, the most common
types of safety deficiencies leading to detentions are shown in the table below:

Types of Safety Deficiencies Leading to Detentions


6% 4% 2%
6%
7% 27%
16%
9% 15%
9%
Fire Fighting Appliances ISM Related Deficiencies
Life Saving Appliances All Other
Safety in General MARPOL Annex I
Propulsion and Auxiliary Machinery SOLAS Operational Deficiencies
Load Lines Crew

By different ship type, the detention percentage reached the rates as shown:

Detentions by Ship Type


Chemical Tanker 0,42%
Container Ship 0,85%
Oil tanker 0,89%
Bulk Carrier 1,20%
General Dry… 2,30%
0,00% 0,50% 1,00% 1,50% 2,00% 2,50%

According to the Flag Administration Security Compliance Performance Statistics, in 2016 the security
deficiencies reported, concern the Access Control, Ship Security Plan and Ship Security Officer. The
same source reveals the rates of major control actions by vessels taken in 2016, leading Bulk Carriers
and following other type vessels such as Containerships, Ro-Ro Cargo Ships, Oil Tankers and other.

Regarding the detention appeals, in 2016, Cost Guard Headquarters received a total of 13 detention
appeals. Four (4) appeals were submitted challenging the overall merits of the detention. All four were
denied. For those parties appealing their association with a detention, nine (9) total, all nine were
granted.

SQE MARINE Circular 2017-05 USCG PSC Annual Report 2016 Date: April 17 Page 1

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SQEMARINE SAFETY | QUALITY | ENVIRONMENT
Circular 2017-05: USCG PSC Annual Report 2016

2016 PSC Report vs 2015 PSC Report

In 2016, witnessed a substantial decrease in the number of detentions. The total number of ships
detained for environmental protection and safety related deficiencies decreased from 202 to 103 as
the total number of ships detained in 2016 for security related deficiencies slightly decreased from 11
to 8. According to its performance statistics, flag administration safety performance for 2016
increased, with in total 9,390 safety inspections conducted, 103 safety detentions and with the overall
annual detention rate dropping to 1.09%. Flag administration security performance for 2016 increased
as well, with 8,818 security inspections conducted, 8 security major control actions taken and the
annual Control Action Ratio (CAR) decreased in 0.09%.

Year Safety Security Safety Security Safety Detention Security Detention


Inspections Inspections Detentions Detentions Rate Rate
2015 9,265 8,655 202 11 2.18% 0.13%
2016 9,390 8,818 103 8 1.09% 0.09%

The detention ratio of flag administration receiving 7 points in Column II of the PSC Safety Targeting
Matrix has mostly decreased during 2016. Detention ratio of Flag Administration receiving 2 points in
Column II of the PSC Safety Targeting Matrix has increased a little. Also, Flag Administrations removed
from last year’s Targeted List had a lower detention ratio than those removed in 2015.
Even though the number of detentions decreased in 2016 compared to the previous year, some
common themes repeated this year during PSC examinations, such as:
 Fire Fighting and Protection Systems. PSCO discovered fire safety issues as the most
common area for detainable deficiencies.
 Safety Management Systems (SMS). Several SMS related detentions noted that the vessel
and company were not following shipboard and SMS procedures for the upkeep of critical
lifesaving equipment, including the maintenance of lifeboat engines and expired SART
batteries.
 Lifesaving Equipment. Inoperable steering systems on lifeboats, frozen winches for
launching lifesaving appliances, incorrectly installed hydrostatic releases and painters on float-
free life rafts.
 MARPOL Annex I. Inoperable oily water separating (OWS) equipment remains the most
common detention deficiencies under this category.
 Safety in General. This topic concerns almost any area throughout a ship and if not
addressed immediately can lead to serious injury or loss of life.
There was a decrease in the number of Flag Administrations Receiving 7 and 2 points in Column II of
the ISPS/MTSA Targeting Matrix and in 2016, three Flag Administrations Removed from Last Year’s
Targeted List, while in 2015 no Flag Administration removed. There was an improvement in the
number of Security Deficiencies per Category and in the rate of Major Control Actions taken by
different Vessel types.

Actions required

In accordance with the statistics as presented by USCG in 2016, the PSC activity increased by 125
safety exams, leading to a detention total decrease from 202 to 103. However, it is essential that Ship
Managers emphasize in items that have to do with firefighting and protection systems, lifesaving
SQE MARINE Circular 2017-05 USCG PSC Annual Report 2016 Date: April 17 Page 2

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SQEMARINE SAFETY | QUALITY | ENVIRONMENT
Circular 2017-05: USCG PSC Annual Report 2016

equipment maintenance which is mandatory to be included in SMS procedures and, also, issues
concerning the oily water separating (OWS) equipment. These are common themes repeated this year
in detainable deficiencies found during PSC examinations and have to be eliminate for better future
results.
Additionally, Ship Managers should implement safeguards in order to be proactive and focus on items
already known to be checked in specific ports.

Further information

 USCG Annual PSC Report 2016: USCG’s PSC 2016 Annual Report shows drop in
detentions
 Port Reports and Inspections: RISK4SEA

Annex 1: Port State Control Safety and Environmental Protection Compliance Targeting Matrix
Annex 2: ISPS/MTSA Security Compliance Targeting Matrix

SQE MARINE Circular 2017-05 USCG PSC Annual Report 2016 Date: April 17 Page 3

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SQEMARINE SAFETY | QUALITY | ENVIRONMENT
Circular 2017-05: USCG PSC Annual Report 2016

Annex 1: Port State Control Safety and Environmental Protection Compliance Targeting Matrix

Priority (P)I Vessel


17 or more points on the Matrix; ships involved in a marine casualty that may have affected seaworthiness;
USCG Captain of the Port (COTP) determines a vessel to be a potential hazard to the port or the
environment; ships whose Recognized Organization (Classification society) has a detention ratio equal to or
greater than 2%. Port entry may be restricted until the Coast Guard examines the vessel.
Priority (P)II Vessel
7 to 16 points on the Matrix; outstanding requirements from a previous examination in this or another U.S.
port that require clearing; the vessel has not been examined within the past 12 months per column IV.
Cargo operations or passenger embarkation/debarkation may only be restricted if the Sector
Commander/COTP determines that the vessel poses a safety or environmental risk to the port.
Non-Priority Vessel (NPV)
6 or fewer points on the Matrix. Vessel poses a low safety and environmental risk. The Coast Guard may
select and examine vessel using the Port State control random selection process.

Downgrade Clause: If a vessel has scored either a PI or PII and has had a USCG PSC examination within
the past 6 months with no serious deficiencies, the Sector Commander may downgrade the vessel to NPV.
If the Sector Commander downgrades a vessel, it will be added to the pool of random examinations.

SQE MARINE Circular 2017-05 USCG PSC Annual Report 2016 Date: April 17 Page 4

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SQEMARINE SAFETY | QUALITY | ENVIRONMENT
Circular 2017-05: USCG PSC Annual Report 2016

Annex 2: ISPS/MTSA Security Compliance Targeting Matrix

(1) Pertains solely to Flag Administrations with more than one major control action in a 12 month
period.
(2) Includes vessels from non-SOLAS signatory countries and non-SOLAS vessels from signatory
countries.
(3) COTP or OCMI may downgrade a vessel’s priority from ISPS I to ISPS II, or ISPS II to ISPS III
depending upon circumstances surrounding a denial of entry. If denial of entry is solely from
failure to provide a Notice of Arrival prior to entry into the U.S., assign 2 points.
(4) Includes vessel delays, restriction of operations, and restriction of movement related to vessel
security deficiencies. Does not include routine examination of the ship or lesser administrative
actions.
(5) After July 1, 2014 the Coast Guard no longer targeted vessels for ISPS exams based on their
port call history. This column will be removed in future PSC annual reports.

SQE MARINE Circular 2017-05 USCG PSC Annual Report 2016 Date: April 17 Page 5

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