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Overview

Paris and Tokyo MoU will jointly launch a new Concentrated Inspection Campaign (CIC) on STCW compliance from 1st September 2022 to 30th November 2022. The inspection campaign will be additional to the regular PSC inspections.

 

Aim of CIC

The purpose of the Inspection Campaign is to determine the level of compliance with the requirements of STCW on board. As per the new revised guidance for PSC, issued by IMO Res. A.1155(32) “Procedures for Port State Control, 2021”, the PSCOs will focus on specific related items of Appendix 11 “Guidelines for Port State Control Officers on certification of seafarers, manning and hours of rest”. This means that PSCOs will not limit inspections only to a typical certification check but they will expand their focus on the evaluation of the Master, officers and crew’s competences when performing duties and during emergency scenarios.

 

Questionnaire

The CIC questionnaire will be finalized and released within August in order to provide early guidance and preparation period for the inspection.

 

Actions required

Managers, manning offices, Officers and crew onboard should be prepared to address the PSC CIC successfully. Appendix 11 of IMO Res. A.1155 (32) includes specific guidance for PSC inspections on Certification Of Seafarers, Manning and Hours of Rest.

 

How we may help

SQEMARINE can provide guidance for analyzing all challenging areas of Appendix 11 and possible deficiency codes related to CIC. Additional guidance will be provided for the upcoming CIC questionnaire (upon release).

 


 


Appendix A: Inspection Questionnaire

IMO Res. A1155(32) – Appendix 11 Focus Points

As per Appendix 11, the PSCO will focus on 3 basic issues.

  1. Seafarer certification
  2. Manning
  3. Hours of Rest

Additionally, depending on ship’s overall PSC performance and the existence of clear grounds for more detailed inspection , PSCOs may require the demonstration of competency of each crew member. In that regard, they will check competences of the Master, officers and crew when performing duties and during emergency scenarios.

 

Documentation Required

The documentation required for the inspection referred to in these Guidelines consists of:

  1. Seafarer certification
    • certificate of competency;
    • certificate of proficiency;
    • endorsement attesting the recognition of a certificate (flag State endorsement);
    • documentary evidence (passenger ships only);
    • medical certificate;
  2. Manning
    • minimum safe manning document;
    • muster list;
  3. Hours of rest
    • table of ship working arrangements and/or watch schedule; and
    • records of daily hours of rest.

 

What a typical PSCO inspection includes

A. Seafarer certificates and documents

The PSCO will request to examine the applicable documents, as per para. ‘Documentation Required’.

The inspection will be limited to verification that seafarers serving on board, who are required to be certificated, hold the appropriate CoC, CoP and documentary evidence issued in accordance with chapters II, III, IV, V, VI and VII of STCW 1978, as amended, as well as their relevant flag State endorsement, valid dispensation, or documentary proof that an application for an endorsement has been submitted to the flag State Administration, where applicable. These documents are evidence of having successfully completed all required training and that the required standard of competence has been achieved. During the verification of the seafarers’ certificates and documents, the PSCO will confirm that they are applicable to the ship’s characteristics, operation and their position on board.

 

B. Manning

The PSCO will  examine the applicable documents, as per para. ‘Documentation Required’.

The guiding principles for port State control of the manning of a foreign ship should be:

  1. verification that the numbers and certificates of the seafarers serving on board are in conformity with the applicable safe manning requirements of the flag State; and
  2. verification that the vessel and its personnel conform to the international provisions as laid down in SOLAS 1974 and STCW 1978.

 

C. Hours of rest

All persons who are assigned duty as officer in charge of a watch or as a rating forming part of a watch and those whose duties involve designated safety, security and environmental protection duties shall be provided with a rest period of not less than:

  1. a minimum of 10 hours of rest in any 24-hour period; and
  2. 77 hours in any seven-day period.

The hours of rest may be divided into no more than two periods, one of which shall be at least 6 hours in length, and the intervals between consecutive periods of rest shall not exceed 14 hours.

The PSCO swill  examine the applicable documents, as per Para. ‘Documentation required’, specifically the watch schedule and the records of daily hours of rest. The PSCO may inspect the seafarer’s personal copy of his or her records pertaining to the hours of rest being held by the seafarer on board in order to verify that the records are accurate.

 

Possible Deficiencies

The following list (not limited) includes examples of possible findings during an inspection focusing to STCW.

Deficiency Codes Related to Inspection Campaign

Finding Deficiency Area Related PSC codes
No CoC, CoP, flag State endorsements or proof that an application for an endorsement has been submitted (STCW 1978 regulations I/4.2.1 and I/10) Certificate & Documentation 01201 – Certificates for master and officers
01214 – Endorsement by flag State
01215 – Application for Endorsement by Flag State
Special training requirements: mandatory basic or advanced training or endorsement not presented; Certificate & Documentation 01201 – Certificates for master and officers
01202 – Certificate for rating for watchkeeping
01203 – Certificates for radio personnel
01204 – Certificate for personnel on tankers
01205 – Certificate for personnel on fast rescue boats
01206 – Certificate for advanced fire-fighting
01208 – Doc evidence for personnel on ro-ro passenger ship
01210 – Certificate for medical first aid
01211 – Cert for personnel on survival craft & rescue boat
01212 – Certificate for medical care
01213 – Evidence of Basic Training
01216 – Cert for personnel on ships subject to the IGF Code
01217 – Ship Security Officer Certificate
01218 – Medical certificate
No evidence of basic training, or other certificate of proficiency, if not included in a qualification certificate held (STCW 1978 regulations VI/1, VI/1.2, VI/3, VI/4 and VI/6); Certificate & Documentation 01201 – Certificates for master and officers
01202 – Certificate for rating for watchkeeping
01203 – Certificates for radio personnel
01210 – Certificate for medical first aid
01212 – Certificate for medical care
01213 – Evidence of Basic Training
Information or evidence that the master or crew is not familiar with essential shipboard operations relating to the safety of ships or the prevention of pollution, or that such operations have not been carried out; Certificate & Documentation 01201 – Certificates for master and officers
01202 – Certificate for rating for watchkeeping
01299 – Other (STCW)
No Minimum Safe Manning Document or the manning (number or qualification) not in accordance with the MSMD (SOLAS 1974 regulation V/14 and STCW 1978 regulation I/4.2.2); Certificate & Documentation 01113 – Minimum Safe Manning Document
01209 – Manning specified by the minimum safe manning doc
Unqualified person on duty (STCW 1978 regulation I/4.2.4); Certificate & Documentation 01201 – Certificates for master and officers
01202 – Certificate for rating for watchkeeping
01219 – Training and qualification MLC – Personal safety training
Watch schedule not posted or not being followed (STCW 1978 regulations I/4.2.3 and I/4.2.5 and STCW Code A-VIII/1.5); Certificate & Documentation 01306 – Shipboard working arrangements
MLC 18202 – Legal documentation on work and rest hours
The absence of a table of shipboard working arrangements or of records of rest of seafarers (STCW Code A-VIII/1.7); Certificate & Documentation 01306 – Shipboard working arrangements
The records of hours of rest are inaccurate or incomplete (STCW Code A-VIII/1.7); Certificate & Documentation 01306 – Shipboard working arrangements
01307 – Maximum hours of work or minimum hours of rest
01308 – Records of seafarers’ daily hours of work or rest
MLC 18201 – Work and rest hours
The watchkeeper is receiving less than 10 hours rest in any 24-hour period (i.e. working in excess of 14 hours) or 77 hours rest in any seven-day period (STCW Code A-VIII/1). Certificate & Documentation 01308 – Records of seafarers’ daily hours of work or rest
MLC 18201 – Work and rest hours

 

Detainable Descriptions

Depending on the description (finding), above deficiencies may result to an action code applicable for detention. The below are examples of descriptions that may lead to detention.

 

Ship related possible detainable findings

  • Minimum Safe Manning Document or equivalent not presented (SOLAS 1974 regulation V/14.2);
  • records of daily hours of rest are not on board (STCW Code A-VIII/1.7);

 

Seafarers’ documentation possible detainable findings

  • not available or serious discrepancy in the CoC (STCW 1978 regulation I/4.2.1);
  • absence in watch of a radio operator (general/restricted GMDSS); certificates and endorsement not available (STCW 1978 regulations I/4.2.1,I/4.2.2, I/4.2.3, I/4.2.4 and II/1.2.1);
  • documentation for personnel with designated safety, security and marine environmental duties not available (STCW 1978 regulations I/4.2.1, I/4.2.2, I/4.2.3 and I/4.2.4);
  • expired certificates (STCW 1978 regulation I/4.2.1), and for medical certificates also refer to STCW 1978 regulations I/9.6 and I/9.7;
  • evidence that a certificate has been fraudulently obtained or the holder of a certificate is not the person to whom that certificate was originally issued.