The key to successfully reducing the number of deficiencies during a PSC inspection, and to avoiding a detention, is regular maintenance on board.
•Top 4 detainable deficiencies are:
1) Safety Management Systems (SMS)- SMS deficiencies evidenced by multiple uncorrected material and/or operational deficiencies are often the most cited. The most common SMS deficiency is where the crew failed to implement the SMS as it relates to the maintenance of the ship and equipment. SMS related detentions usually resulted from the failure of the master and or crew to report non-conformities to the company.
2) Fire Safety– The prevention of fires on board ships remains an area of particular concern for our PSC program. Deficiencies related to oil soaked lagging coupled with excessive fuel leaks were the most common cause of detentions in areas under fire safety.
During one exam, the PSCO noted all five of the vessel water mist system discharge valves in the closed position. Although the system was in automatic mode, in the event of a fire, the closed valves would not have supplied fire-fighting water as designed. On another ship, rags were found stuffed into all of the sprinkler heads of the fixed water sprinkling firefighting system in a paint locker.
3) MARPOL Annex I- There were several detainable deficiencies related to MARPOL Annex I. In addition to the usual deficiencies related to oily water separating equipment, two ships were discovered illegally discharging oily waste.
In the second case, the crewmember demonstrated how the bilge piping arrangement was modified, including the hand wheel on the bilge isolation valve. The modifications allowed the valve to open without breaking the tamper seal. Officers on both ships were subject to criminal investigations for illegally discharging oil waste.
4) Lifesaving Appliances– Overall, detainable deficiencies related to lifesaving systems have remained steady over the years accounting for less than 10% of the total. Deficiencies related to rescue boats and lifeboats generally lead this category most due to them not being ready for immediate use.
During one exam, the PSCO observed six to eight inch long cracks along the bow, center, and stern sections of the upper rails due to contact with the davits in both port and starboard life-boats. On another ship, 30 of the ship’s 31 immersion suits were taken out of service due to their poor condition.
The Coast Guard stresses that if any ship’s system required by international conventions is not in working condition, the master and crew should take necessary actions to remedy the situation in accordance with their SMS before the ship enters port and report any unresolved issues on their advance notice of arrival.