The following guidelines and explanations are to address some of the issues being observed by me.
A) AUDITS & NON CONFORMITY
During conducting audits on board few of our vessels, we have come across several deficiencies pertaining to vessels not using the SUNCE current forms and checklists, and the awareness about the company’s QMS manual & Emergency Procedures Manual is negligible. It becomes glaring, when even senior officers are unable to answer simple questions on the systems.
This has further caused non-implementation of the systems and thus deficiencies and Non conformities are galore.
One of the simple questions that most are unable to answer is what is a Non Conformity.
The explanation is here under with Example:
Non-conformity: Means an observed situation where objective evidence indicates the non-fulfilment of a specified requirement
Major Non-Conformity: Means an identifiable deviation that poses a serious threat to the safety of personnel or the ship or a serious risk to the environment that requires immediate corrective action and includes the lack of effective and systematic implementation of a requirement of the ISM Code
Example: Let’s assume, on board a vessel, after discharging cargo, the Master advises Chief Officer to carry out tank cleaning and thereafter decant water from slops and discharge into sea through ODME.
The chief officer does the tank cleaning, and when goes about to start the ODME, he is unable to start the ODMCS.
Example: The ODME has developed a fault, and needs to be repaired prior to use.
As much as most of the people would say that this is a Non-conformity, please note this is not a Non Conformity. A Equipment can malfunction.
But let’s further assume that the Chief Officer does not know how to use it, and he has further never tried out the ODMCS as required by Company procedures every month for the past three months. Thus there is no evidence that adequate checks and inspections were carried out as required.
Here the Non-Conformity Develops. The Objective Evidence – no print-outs can be shown, no ORB entries can be shown to justify that the Chief Officer ever tried it out. The specified Requirement is that ODME must be tried out monthly, which was not fulfilled.
This leads to a Glaring non-Conformity. The gravity of the Non-conformity is set by the evaluation of the threat. If it causes serious risk to Safety, Health or Environment, it will be called a Major non-conformity.
(As in the above case, the Master takes over from Chief Officer and with non working ODME on auto mode, bypasses the Automatic settings, and decants the water manually, it will turn to a Major Non-conformity).
The key word are
“OBJECTIVE EVIDENCE” – REQUIRES DOCUMENTATION.
“SPECIFIED REQUIREMENT” – COMPLIANCE WITH COMPANY’S SMS & PROCEDURES, ALWAYS IN LINE WITH REGULATIONS.
“NON-FULFILLMENT” – EVIDENCE MISSING THAT THE SHIP & ITS PERSONNEL COMPLY WITH THE SYSTEMS & REQUIREMENTS.
The non-fulfillment can be further tracked down to two reasons:
1) The documentation has been done accurately, but while auditing, the auditor find out that the personnel doing it have no idea of what they are doing. They are doing only “tickology”. That is they are not familiar with the requirements, but because someone told them to follow something / a pre-existing system has been continued without use of actual analytical abilities which stand-out to display the competence of the person doing it.
2) No documentation or carrying on with an out-dated system / pre-existing system. This goes to show that the personnel are not aware of the latest. Not a healthy sign, because apart from analytical abilities it shows the characteristics of observance and awareness levels in the person.
Therefore, it is important for you to familiarize actually with the system and use the company forms and checklists, where available to maintain documentation / evidence or make your own documented evidence if no standard form or checklist is provided from the company. This should also be brought to attention of the company in a Master’s Management Review.
B) LOG BOOK ENTRIES
The CCR / Cargo / Port Record book or log book and the Bell Book complement the entries in the Deck log book. Please note, that these two log books are the equivalent of Rough note books, where except for erasing / cutting data or writing with pencil, everything is permissible. It is like a scrape note book, where, if you feel that you should write about the most insignificant event, you should write.
These entries in Cargo log book should include (not limited to) entries pertaining to
timings of visitors on board, personnel going ashore, change of cargo tanks, during loading & discharging, Change of Cargo pumps Deck and pumproom rounds and the result of the rounds. Ballasting / deballasting commencement, change-over of ballast tanks & completion Matters relating to change in parameters of pumping any time and manifold pressures Any other abnormal occurrence if suspected. Specific communication with terminals / port on VHF or Radio Instructions from terminal during loading / discharging Stoppages & resumption. Ship shore meeting timings and other timings considered important Timings related to small barges, provision boats etc. alongside, entry / exit of surveyors or inspectors Testing / inspection of cargo gear, pre-arrival checks, loadicator tests. Timings and procedure of tank cleaning Records related to ballast handling. Etc. Similarly every item of smallest detail should be entered in the Bell Book, when in use on bridge.
The items that seems important in the above should be further also noted down in the Deck log Book (Also refer to the inside cover page of Deck / Engine log book), including;
Important timings Training events (the record of this can be kept in the Bell book also), including drills. Reference to SUNCE forms and checklists, which are applicable, having been completed and complied. Reference to vessel position & activity (during cargo operation “ loading Gas Oil alongside Ulsan, XYZ Terminal, Jetty # 2 & during navigation, GPS or Radar position) at least once every watch Maintenance / Inspection Record of any equipment, which is related to Safety, Environmental Protection etc. Record of Master’s weekly rounds in the accommodation, to check for hygiene and cleanliness (Must be at least once every week). Cargo quantity loaded / discharged, departure / arrival drafts and/or freeboard. Crew sign on / sign off Result of Stress & Stability Checks prior departure Ballasting / Deballasting Use of ODME etc.
C) TRAINING
Onboard training should not only be limited to Drills. It must also include and be documented adequately for training of junior ranks to the next rank, trainings and familiarization with shipboard specific equipment, safety or otherwise.
Evidence of training should be kept for each person on board.
D) REPORTING / CLOSING OUT INTERNAL / EXTERNAL AUDIT OBSERVATIONS, NON CONFORMITIES, DEFICIENCIES REPORTED BY SUPERINTENDENT OR VESSEL PERSONNEL, VETTING OBSERVATIONS ETC.
Whenever the vessel gets / finds such an observation or report of deficiencies from own observation or from third party observations, such as PSC, Flag state, Vettings etc., they should within the shortest possible time send to office, siting the observations, source of observations, root cause as identified by Master / Vessel Management and the corrective action required with Preventive Action towards closing the same permanently.
Proper Root Cause must be analysed and submitted for each observation or NC.
The observations will be followed up from office by the superintendents with their remarks and as and when the observations are closed, they should be reported to office with physical evidence, such as scanned documentary evidence, photographs etc. as applicable. Sending a requisition does not close the observation, until it is received on board and put to use to close the observation.
Once the office sites the evidence, the superintendent would close the same and advice the vessel in the same form. This must be done within 14 days of a vetting inspection as that is the lead time in most cases to reply to a vetting observation to the oil majors.
G) VETTING INSPECTIONS & AUDITS
Vetting Inspection is carried out as follows:
1) The Inspector boards the vessel and starts making his first opinion of the vessel basis the presentation of the visitor card on gangway, ISPS Checks and the way the accommodation ladder is kept to the general condition of the deck and the housekeeping in and out of the accommodation.
2) The inspector should be escorted straight to the Master. Normal salutations like Good Morning etc., make an objective impression on the Inspector about the satisfaction level of the people on board.
3) The Inspector would normally call an opening meeting with senior officers to brief them how he would want to carry out the inspection. The Master can and should care for the rest hours of his officers and accordingly advice the Inspector, if he wants him to call for eg. 2nd officer later or earlier in order to provide him adequate rest. This shows that Master Cares for the rest of his people. Another good impression.
4) The Inspector would now want to check documentation and ships certificates with Master. He should be provided with a list of certificates with date of expiry & issuance (SUNCE.MA.02 Vessel Certificates Status.xls) to facilitate him with the inspection. The orderliness of the certificates and the ease of finding them would make the inspector happy.
5) Further, the inspector should be provided with a copy of the Crewlist, a copy of the HVPQ, key dates regarding maintenance, inspection & launching of lifeboats, drills etc., a copy of the officer’s Matrix updated, ship’s particulars, a copy of any Condition of class, a declaration of last three cargoes with the ROB after discharge stated and the Minimum Manning certificate copy.
6) All officers and crew certificates, national and flag.
7) Keep the certified copies of Intact & Damage Stability manuals, IGS manual, ODME Manual, P&A Manual, loadicator manual etc. ready for inspection.
8) Ensure you provide the maximum attention to the comfort of the Inspector and arrange tea/coffee or snacks for him, and keep checking if he wants more.
9) Oil Record books and garbage log book.
10) Once completed with Master, the inspector would like to go on Bridge. He’ll call for 2nd Mate. Please ensure the guidelines in the QMS Chapter 9 are observed.
Ensure Master’s standing orders are posted Updated magnetic compass deviation card, matching with the current compass error log, which must have latest error observations GMDSS log with entries related to maintenance / inspections, and all distress / urgency / safety communication received, even if not responded owing to outside the vessel’s reach, or if within vessel’s area, should have the entry, why vessel did not proceed for help. Echo Sounder log, GPS Log & Anchoring records updated Current passage plan, which must include references to all charts and publications that have been referred or can be referred to make the plan. For example in Singapore reference should also be made of BA Chart 5502. These publications and charts should be kept out and easily accessible to all, neatly arranged and securedly kept. The markings on the charts for the previous plans should not be erased until it has been inspected by the Inspector. Ensure that the voyage charts have been checked that all Notices are corrected, marked on the chart and in the chart correction log, including the references of all Temporary & Preliminary notices applicable and marked on chart. All Navtex / EGC print-out must be read & signed by all watchkeepers including Master. Watchkeeping Schedule should be posted. All other log books must be properly completed. 2nd officer should be aware of the UKC policy of the company. All bridge checklists including Master pilot information and pilot card are properly filled & filed. Alcohol test equipment available & evidence of Master having carried out the same regularly. Company policies displayed on bridge. So it should be also in the ECR & other alley ways. The Drug & Alcohol policy should be in all alleyways and common rooms. The record of LSA, FFA & Training & Drills should accessible and to be presented to him immediately. Bridge equipment maintenance record should be present. Ensure there are no alarms on bridge. Not too much paper printed out on any printer – Sat-C or Navtex / Weather Fax. Emergency contact list should be available in SOPEP & on bridge and in CCR. 11) The Inspector thereafter may want to take a round on deck, starting from accommodation. While he is with Master, the chief officer and Chief Engineer should get the deck and engine room and all other areas re-verified that everything is in order.
12) Ensure the Garbage area is properly maintained and kept clean.
13) ensure all stenciling is done, more is acceptable less is not. Every sounding pipe or vent on deck should be stenciled properly.
14) Ensure Rescue boat and Lifeboat is properly kept, ready & clean, tried out. Liferafts are properly connected with the HRU.
15) The inspector may request the operation of the following equipment:
Emergency Fire Pump Emergency Generator Lifeboat / Resuce boat engine Emergency Steering ODME 16) No lighters should be used. Only match boxes. Ashtrays should be of closed type and only visible in the approved smoking areas, door of which should be kept closed.
17) Proper PPE is in use.
18) No evidence of any leakage.
19) Manifold pressure gauges working on both sides. All unused manifolds shut (comply with Ship shore safety checklist)
20) Samples are properly kept in sample locker.
21) Ensure deck air is on, and wilden pumps have been tested.
22) Paint stores, chemical stores, sample locker etc. must have MSDS & PPE.
Then he would like to go to Engine Room
23) Ensure no leakages.
24) All MARPOL seals are in place and record is maintained
25) Ensure emergency & Fire fighting equipment are inspected and in readiness.
26) Ensure emergency air compressor is fully charged and ready.
27) Ensure no earth alarms are present. All such equipment must be traced and switched off if required & possible during inspection, if time does not permit to mitigate.
28) Insulation mats present at switch boards.
29) Must be able to calibrate the OWS.
30) Chemical MSDS & PPE is placed at Chemical store.
Then comes Chief officer
31) Must be aware of pressure settings of IG / PV Valves & Pressure alarms
32) Must be able to calibrate the gas measuring equipment
33) Should have the full cargo loading / discharging plan ready. See Cargo Module A – Sunce forms CT.04 A/B/ C/D as applicable.
34) Hourly log of loading & discharge should be in use & maintained. (SUNCE.CT.10 Hourly log of cargo discharge.xls)
35) Ship shore safety checklist should be complied with, with repeated checks for Items marked R.
36) MSDS is available in Mess room, CCr, Bridge & ECR.
37) Record of Cargo samples has been kept.
38) Chief officer must be aware of the dangers if the IG is not used.
Finally remember, should you feel that the inspector may give some deficiency that he has observed, please try to rectify them before he leaves the vessel.
0-6 OBSERVATIONS (UNLESS HIGH RISK) 100% OIL MAJOR ACCEPTANCE
6-10 OBSERVATIONS (UNLESS HIGH RISK) 80% OIL MAJOR ACCEPTANCE
10 – 15 OBSERVATIONS (UNLESS HIGH RISK) 60% OIL MAJOR ACCEPTANCE
16 – 20 OBSERVATIONS (UNLESS HIGH RISK) 40% OIL MAJOR ACCEPTANCE
ABOVE 20: VERY LESS CHANCES ALMOST NIL.
The charterers or Oil Majors are looking for the reason why the business should come to you and they are looking for reasons whether the display by ship staff during inspection is temporary or will it be continued. Will there cargo be safe even in future with them?
Below is a list of common deficiencies observed:
| Common Vetting Deficiencies |
| |
| A | Safety |
| 1 | Non - conformities of internal audit not closed out. |
| 2 | Safety signs such as emergency escape route signs posted too high. |
| 3 | Launching of lifeboats and rescue boats as per statutary requirements overdue. |
| 4 | Self igniting lights for lifebuoys not approved for use in hazardous area i.e. not intrinsically safe. |
| 5 | Imo symbols not posted at various places. |
| 6 | Safety officer has not done safety officer course. |
| 7 | Enclosed space entry permits not followed and / or entries wrongly filled. |
| 8 | SCBA air quality test overdue. |
| |
| B | Deck & Cargo |
| 1 | MSDS not available for the cargo being loaded. |
| 2 | Gangway net not rigged properly.Net found secured around stanchions. |
| 3 | Oil spill gear in poor condition. |
| 4 | Eye wash / emergency shower not working / damaged. |
| 5 | Poor housekeeping on deck and in stores. |
| 6 | Sea chest integrity test gauge is not compound type.No records of integrity tests. |
| 7 | Mooring rollers , bollards , fairleads , chokes not marked with SWL. |
| 8 | Mooring pedestal rollers found frozen. |
| 9 | No spares on board for single exhaust fan for pump room. |
| 10 | Scuppers loosely fitted. |
| 11 | Containment system (Save alls) plugs missing. |
| 12 | Fire wires not rigged properly. |
| 13 | More than one layer of mooring rope on split drums. |
| 14 | Proper PPE not worn by ship staff. |
| 15 | Pressure vacuum alarm settings in CCR were wrongly set / Not familiar with procedure to change settings. |
| 16 | No terminal regulations available while loading / discharging. |
| 17 | Ballast pumps seals found leaking. |
| |
| C | Navigation |
| 1 | Charts and publications not corrected upto date. |
| 2 | Navtex , Navarea , T & P notices not filed properly and not plotted on trading charts. |
| 3 | Only one mean of position fixing i.e. GPS used during passage. |
| 4 | Navigating officers not attended BTM / BRM , ECDIS courses. |
| 5 | Passage plan not made from berth to berth. |
| 6 | UKC for passage and ports not calculated as per company requirements. |
| 7 | Speed input in radar for anti-collision was not through the water. |
| |
| D | Engine room |
| 1 | Calibration checks of portable thermometers not done. |
| 2 | Calibration checks of pressure guages not done. |
| 3 | No warning signs and / or no seals on emergency bilge suctions. |
| 4 | Poor house keeping. |
| 5 | Earth fault observed on main switch board. |
| 6 | No approved insulation mat present in front of electrical switchboards. |
| 7 | Leaks noticed from various machineries. |
| |
| E | Accommodation |
| 1 | Accommodation under negative pressure (vacuum). |
| 2 | Galley exhaust dirty with cooking fat. |
| 3 | Light fittings around accommodation containing water. |
| 4 | Garbage bins and drums without noncombustible lid.Garbage bins and drums not made of non-combustible material. |
| 5 | Expired or No medical chest certificate. |
| 6 | First aid boxes missing from place or containing expired medicines. |
| 7 | Poor house keeping , provision freeze room frozen food not on gratings ,lying on floor. |
| |
| F | Documentation |
| 1 | Annual inspection of lifting gears not recorded in lifting gear register. |
| 2 | Survival crafts and launching appliances weekly and monthly inspections not logged in log book. |
| 3 | Oil record book part 1 not filled up correctly. |
| 4 | Fire wire certificates not on board. |
| 5 | Work hour - rest hour records not complying with actual work hours / rest hours. |
| 6 | Senior officers not done ship handling course. |
| 7 | LSA and FFA maintenance register not maintained and inadequate information |
Please note the above is some of the major things we would really appreciate that you and your staff considers and follows. Only acknowledging receipt is not sufficient. During audits it has been seen that most of the vessels are not using the checklists / forms, no one knows the systems, but all Masters have acknowledged having received them. Probably some of you are doing it also, but we’d rather wish that you’re sure then sorry later.
Sent to Sunce Vessels / 12Jun10 - Rajesh Baran
