Marine Advisory: 01/2019 - Flag State Preemptive Boardings of Liberian Vessels calling on US Ports

25 January, 2019

Marine Advisory: 01/2019

Subject: Flag State Preemptive Boardings of Liberian Vessels calling on US Ports

Dear Owners/Operators/DPAs/Masters:

Purpose: This Advisory is to inform Liberian Vessel Operators of our intent to continue to attend all Liberian flag vessels calling on US Ports to assist all Liberian vessels operators with the USCG.

Background: The USCG has increased its emphasis on compliance with the International Safety Management Code (ISM Code) during foreign vessel inspections. The Administration has noted that the USCG is boarding vessels more frequently than a vessels normal 12-month inspection interval, and as frequently as 3 months, regardless of vessel type.

We continue to see USCG detentions of vessels with very good international PSC records, including deficiency rates less than 1 and no detentions within five years. The first vessel was detained in Port Manatee, Florida, on 9 January 2019, the second was detained in Los Angeles, California on 17 January 2019. Both were detained for SMS failures. We had a third vessel detained by the USCG on 22 January 2019 also in Los Angles when a quick closing valve was found blocked by the USCG inspector.

The reasons for recent USCG detentions include failure to initiate action to correct existing deficiencies:

• Quick closing valve blocked with a piece of metal/wood.
• Engine room oil leaks/unapproved soft patch repairs on fuel lines and salt water lines.
• Emergency generator/missing means of primary or secondary starting/automatic start and/or does not engage.
• Fire fighting equipment/systems are not functional / leaking /water mist system not in auto mode.
• Failure of the crew to follow enclosed space entry requirements included in the SMS.
• Failing to replace the seal on the sample drain valve for the OWS.
• Failing to report defective equipment, and
• Defects reported to the company, but the company failed to take corrective action in a timely manner.

We recommend Owners, Operators, DPAs encourage their Master’s and Chief Engineers to thoroughly check to ensure their SMS procedures are properly implemented, for example:

• Deficiencies or defects affecting compliance the vessels SMS or International Conventions concerning Safety, Security and Environmental are reported and corrective action initiated.

• If a block or other obstruction is used during a test of a quick closing valve, ensure it is removed immediately after the test to restore the values safety feature.
• If using the OWS sample valve, replace the seal in accordance with the SMS.
• If entering an enclosed space, ensure the correct procedures are followed and documented.

To avoid SMS detentions Masters and Chief Engineers are to document non-conformities and initiate corrective action in accordance with the ships SMS and inform the Administration and the DPA at least 96 hours prior to arrival in ports in Australia, China, Europe or the USA. These reports will assist in demonstrating compliance with SMS.

US ANOA Procedure: All vessels scheduled to arrive at a port in the USA, shall provide the vessels ETA along with agent information to this Administration 96 hours prior to arrival. All vessels scheduled for inspection by the USCG are also required to provide us with the USCG point of contact. All vessels, regardless of the previous inspection, shall continue to follow the instructions in Marine Operations Note 03/2018 regarding Advance Notices of Arrival and Pre-Arrival Checklists.

The Administration will conduct an early flag state inspection on all US arrivals if the vessel is within 4 months of the annual flag State safety inspection date. If not within 4 months of the safety inspection date, we will schedule for a preemptive inspection whenever possible. We may not always be able to provide an inspector, and will prioritize based on the inspection history of the vessel and the concerns of the vessel operators.

In the case of a preemptive inspection, all effort will be made to minimize the cost and burden on vessels and operators. Master’s, DPA’s, operators, that report deficiencies/non-conformities to the Administration prior to the ships arrival and no additional deficiencies or observations are found during the inspection will have the preemptive inspection fee waived.

We sincerely appreciate your support.

If you have any questions, please contact our Safety Department at Telephone: +1-703-790-3434 or by email to safety@liscr.com.

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