Maritime Questions › Certificates Surveys
A PSC inspector asks to see the Oil Record Book (ORB). You hand it over. The inspector immediately focuses on two types of entries. What might they be looking for and what are the consequences of falsified entries?
A. Falsified ORB entries result only in civil penalties. Individual officers cannot face criminal charges for company-level decisions about bilge water disposal.
B. PSC inspectors only check that the ORB has an entry for every day of the voyage. The content of individual entries is not verified during a routine PSC inspection.
C. The ORB is only inspected by MCA surveyors during the IOPP annual survey. PSC inspectors do not have authority to examine machinery space operational records.
D. OIL RECORD BOOK (ORB) inspection focus: (1) BILGE WATER DISCHARGES: PSC inspectors focus on Part 1 (machinery space operations) entries for overboard discharges. MARPOL Annex I requires that machinery space bilge water be processed through the Oily Water Separator (OWS) and can only be discharged overboard if: outside 12nm from land; oil content less than 15 ppm (monitored by ORB monitor); vessel is not in a Special Area; OCM (Oil Content Monitor) is operational. Inspectors check: (a) frequency of OWS operations vs expected bilge water generation; (b) whether discharge volumes are plausible given the voyage track and bilge holding tank capacity; (c) whether the 15 ppm monitor calibration records are current; (2) SLUDGE DISPOSAL: Part 1 code H — disposal of oil residues (sludge). Inspectors compare the volume disposed against sludge generation calculations (should be approximately 1-2% of fuel consumed); if sludge is not being disposed at a reasonable rate, it may indicate it is being disposed overboard (illegal); (3) FALSIFICATION: known as "magic pipe" operations — bypassing the OWS. Consequences: criminal prosecution; MARPOL fine; loss of CoC for the officer signing false ORB entries; P&I Club investigation. In the US, the Vessel Pollution Act (33 USC 1908) provides for imprisonment of up to 6 years for the signing officer.
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A. The SMC is not required on board — only the Document of Compliance (DOC) held by the company is mandatory. PSC cannot detain the vessel on this basis alone.
B. An expired SMC can be sailed on for 3 months while awaiting a new survey, provided the master informs the flag state. There is no PSC ground for detention during this grace period.
C. SAFETY MANAGEMENT CERTIFICATE (SMC): issued under SOLAS IX / ISM Code. VALIDITY: maximum 5 years, subject to intermediate verification (audit) at intervals between 2.5 and 3.5 years after initial or renewal audit. Renewal process: the SMC must be renewed before expiry by a flag state or Recognised Organisation (RO) verification audit; IF EXPIRED: an expired SMC means the vessel is operating WITHOUT a valid ISM certification — this is a fundamental SOLAS breach. PSC consequences: (1) IMMEDIATE DETENTION: PSC will detain the vessel — an expired SMC is a ground for detention under SOLAS IX; (2) FLAG STATE NOTIFICATION: PSC notifies the flag state Administration; (3) CRIMINAL LIABILITY: operating a SOLAS vessel without valid certificates is an offence under the Merchant Shipping Act (UK flag state); (4) WHAT SHOULD HAVE HAPPENED: the ISM audit should have been arranged before expiry; the master and DPA are both responsible for monitoring certificate validity; a diary system tracking all certificate expiry dates is an ISM requirement. ROOT CAUSE: failure of the company's certificate management system — itself an ISM non-conformity.
D. The SMC is automatically renewed when the DOC is renewed. An expired SMC therefore simply means the paperwork has not been updated — the underlying certification remains valid.
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A. The CSSEC is only issued to general cargo ships. Tankers, bulk carriers, and container ships hold separate vessel-type specific certificates with different survey requirements.
B. The CSSEC covers only the hull structure and stability. Safety equipment (lifeboats, firefighting) is covered by a separate Cargo Ship Safety Construction Certificate.
C. No annual survey is required for the CSSEC — it is issued for 5 years and renewed at the 5-year anniversary. Only the load line certificate requires annual surveys.
D. CARGO SHIP SAFETY EQUIPMENT CERTIFICATE (CSSEC): issued under SOLAS I/12 for cargo ships of 500 GT and above. COVERS: (1) Life-saving appliances (LSA) — lifeboats, rescue boats, liferafts, immersion suits, lifejackets, line-throwing appliances, pyrotechnics; (2) Fire detection, fire extinguishing systems, and portable fire equipment; (3) Navigational equipment as required by SOLAS Chapter V (charts, echo sounder, gyro compass, magnetic compass, AIS, ARPA, etc.); (4) GMDSS radio equipment (though also covered by the Safety Radio Certificate); (5) Day signals (shapes). SURVEYS: (a) Initial survey before first issue; (b) ANNUAL survey (within 3 months each side of the anniversary date) to maintain validity; (c) PERIODIC survey (full survey) at intervals not exceeding 5 years; (d) ADDITIONAL surveys as required after significant repairs or modification. Annual survey focus: LSA equipment — lifejackets, immersion suits inspected, hydrostatic releases checked, EPIRB registration/battery expiry checked, pyrotechnics within date, lifeboat engine tested, falls and release gear tested.
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