Marine Operations Note: 03/2018 - Advance Notice of Arrival Requirements for vessels calling on ports in Australia, China, Europe and the USA

March 2018

Marine Operations Note: 03/2018

(This Note supersedes and replaces Marine Operations Notes:

04-2009, 01-2011, 01-2012 and Marine Safety Advisories: 03-2015 and 04-2015)

SUBJECT: Advance Notice of Arrival Requirements for vessels calling on ports in Australia, China, Europe and the USA

Dear Ship Owner Operator and Designated Person Ashore:

We are experiencing an increase in Port State Control inspections; however, we have also experienced a decrease in PSC detentions.

Our requirement to receive ANOA and Pre arrival Check Lists are helping to ensure compliance and report defects. In nearly every case, where a vessel is detained for an existing deficiency, the Administration was not provided with an Advance Notice of Arrival (ANOA) or a completed Pre Arrival Checklist. We have been meeting with PSC authorities to establish better communications and understanding of the flag Administration’s Compliance Assistance (CAP) Program. The Administration frequently updates its prearrival checklists to identify the most common detainable deficiencies to provide value to the CAP. We have found that when PSC inspectors are made aware that the Administration was informed of inoperative equipment or other deficiencies, and that appropriate corrective action was initiated, the PSC is more likely to let the Administration continue to address compliance.

It is very unfortunate that in the majority of cases the PSC detention was preventable. For example, recently a vessel was detained because of a lack of fire safety equipment. The Master sent all of the portable fire extinguishers ashore for servicing and the vessel was engaged in bunkering operations during which time the USCG boarded to conduct the Port State Control Inspection. Other examples include closing the water supply valve to the high pressure Water Mist System and leaving the automatic fuel shut off valves inoperable due to blocks of wood or nuts preventing the system from shutting off the fuel supply. Recently we are seeing more detentions for MLC issue related to wage payment, seafarers on board with expired SEAs, noncompliance with the hours of rest, and a Master’s and Chief Mates direction to the seafarers not to use the complaint procedure established by the company.

Other detainable deficiencies are due to existing conditions where there is no evidence of corrective action or action initiated to mitigate the impact of defective equipment required by the applicable international conventions. Detainable deficiencies primarily concern:

• defective firefighting equipment - defective navigation equipment

• Defective fire dampers - lack of appropriate updated charts,
• defective OWS - inadequate maintenance, and
• defective emergency generators - an ineffective SMS (which relates back to lack of maintenance and defective equipment.

Recently we are also receiving more MLC related detentions:

• insufficient hours of rest - SEAs expired, and
• seafarers wages not paid monthly - complaint procedures not implemented onboard

It would be helpful to receive ANOAs in time to request a Pre Arrival Checklist and so we may provide assistance to ensure compliance. Receiving an ANOA in a timely manner would assist in minimizing any potential delays due to detention and noncompliance with the international conventions.

To better assist the vessel operator, the Master and the crew on board Liberian ships, the Administration will require Master’s and/or DPA’s to provide an ANOA to

NOA@liscr.com at least 4 work days (96 hours) prior their vessel arrives at its first port of call for Australia, China, Europe, or the USA. Where possible a copy of an ANOA provided to the Coastal State will suffice with a report of any defective equipment and actions taken to mitigate same. Where this is not possible, we request that the Master send an email to NOA@liscr.com with the following information:

Vessel Name:

IMO Number:

Pot of Arrival:

Date of Arrival:

Contact information for the local agent:

Defective Equipment:

Vessel's Previous Port:

Date of departure:

DPAs and Master’s should ensure their crews and vessels are prepared for Port State Control inspections and drills. The Liberian Administration provides a Pre-Arrival Checklist (RLM258) that outlines the most detainable deficiencies. It is also available on the LISCR web site:

http://www.liscr.com/sites/default/files/online_library/RLM-258_PreArrivalChecklist.pdf

At least every other month and more frequently if requested by the Administration a completed checklist identifying any defective equipment, or possible noncompliance and corrective action should be included with the ANOA. This will assist in minimizing potential problems with PSC.

If you have questions please contact us by email at safety@liscr.com or by telephone to +1-703-790-3434 and ask for the Safety Department.

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