Question 1

During a PSC inspection, the PSCO asks an AB to demonstrate how to don an immersion suit. The AB takes 12 minutes and is unable to close the zipper. What is the PSC consequence and what corrective action do you take?

Accepted Answer

STCW COMPETENCY FAILURE — PSC RESPONSE: SOLAS III requires that crew can don an immersion suit within 2 minutes without assistance (SOLAS III/32.3). An AB taking 12 minutes and unable to close the zipper demonstrates: (a) inadequate immersion suit training; (b) potentially an unsuitable immersion suit (wrong size or defective); (c) insufficient drills. PSC CONSEQUENCE: The PSCO can issue a deficiency notice for: "Crew unable to perform essential safety duties — immersion suit donning." This may result in DETENTION (a fundamental safety deficiency — crew cannot protect themselves in an emergency). IMMEDIATE CORRECTIVE ACTION: (1) IMMEDIATE DRILL: conduct an immersion suit donning drill with ALL crew. Document with date, time, crew list, and result; (2) CHECK SUITS: inspect all immersion suits — are they the correct size for the assigned crew member? Are zippers operational and lubricated? Are the suits within their service life?; (3) RECTIFY DEFECTIVE SUIT: a suit with a seized zipper must be repaired or replaced immediately; (4) TRAINING: brief the crew on the 2-minute standard. Practice regularly — not just during drills; (5) RECORDS: update the drill records; (6) INFORM PSCO: demonstrate the corrective action taken. Re-test the AB in front of the PSCO to demonstrate rectification; (7) SYSTEMIC REVIEW: why was this AB not trained? Review all crew training records against STCW requirements. SOLAS III/32.3: "Every person on board shall be instructed in the use of the ship's immersion suits. In addition, every crew member shall be instructed in and required to practice donning an immersion suit and any accessories within 2 minutes without assistance." This is explicit and applies to ALL crew members — officers and ratings alike. PSC testing authority (option D): the Paris MOU and SOLAS explicitly provide PSC with the authority to test crew competency. The PSCO can ask crew to: don an immersion suit; demonstrate use of a fire extinguisher; show liferaft launching procedure; demonstrate GMDSS equipment operation. If crew fail these demonstrations, the PSCO has clear grounds for deficiency notices and potentially detention. The 2-minute standard: 2 minutes without assistance. The purpose is that in a vessel sinking rapidly in cold water, a crew member must be able to protect themselves against cold water immersion before they are underwater. Beyond 2 minutes in cold water (North Sea, winter): survival time without immersion suit is typically 30 minutes to 1 hour. The suit extends this to hours. Medical exemption (option C): a medical condition affecting dexterity is a genuine consideration — but it would need to be documented and the company would need to provide alternative arrangements. This is not an excuse for a fleet-wide training failure. Zipper maintenance: immersion suit zippers require periodic lubrication (manufacturer's specification). Seized zippers are a maintenance failure. The CM should include zipper inspection in the immersion suit maintenance schedule.

Question 2

A Paris MOU Port State Control Officer (PSCO) boards your vessel in Rotterdam. As Chief Mate, what does the initial inspection involve and what is your role?

Accepted Answer

PSC INITIAL INSPECTION — CM ROLE: The Paris MOU provides the framework for PSC inspections in European waters. INITIAL INSPECTION — THE PSCO CHECKS: (1) CERTIFICATES: validity of all relevant certificates: (a) Safety Management Certificate (SMC) and Document of Compliance (DOC); (b) SOLAS Safety Equipment Certificate; (c) SOLAS Safety Construction Certificate; (d) SOLAS Safety Radio Certificate; (e) Load Line Certificate (LL); (f) IOPP Certificate (MARPOL Annex I); (g) ISPS (International Ship and Port Facility Security Code) Certificate; (h) MLC Maritime Labour Certificate; (i) Classification Certificates; (j) Minimum Safe Manning Document; (k) Officer's Certificates of Competency; (2) CREW WELFARE: PSCO may interview crew privately about rest hours, wages, food, and access to complaint procedure (MLC inspection); (3) GENERAL CONDITION: visual inspection for obvious deficiencies — corrosion, unsafe equipment, damaged fire equipment, dirty accommodation; (4) ISM: request evidence of ISM implementation — drill records, internal audits, non-conformity reports. CM ROLE: (a) Accompany the PSCO on request; (b) Produce documents immediately — delay suggests non-compliance; (c) Answer questions truthfully and professionally; (d) Notify master of PSCO's findings as the inspection proceeds; (e) Do NOT coach crew on what to say — crew must speak freely to the PSCO. Paris MOU targeting system: uses a risk-based targeting system (Concentrated Inspection Campaigns and the Targeting Factor) to select which vessels to inspect. High-risk ships (older vessels, flags with poor performance records, companies with poor track records) are inspected more frequently. PSC authority: based on UNCLOS, SOLAS, and the MOU framework. Port state has the right to inspect foreign vessels in their ports to verify compliance with international conventions. The inspection right does NOT require cause — any commercial vessel in a Paris MOU port can be selected. The MLC private interview: PSCO may interview crew without the master or CM present. MLC Standard A5.2.1 specifically provides for this. If the CM were present, crew might be reluctant to report MLC violations. The CM must not interfere with MLC crew interviews. Certificate validity vs actual condition (option B): if certificates are valid but conditions are hazardous (fire system not functioning, crew not properly trained), the PSCO can issue deficiency notices and potentially detain the vessel for "clear grounds" — hazardous conditions regardless of paper compliance. Detention criteria: not just paper failures. A vessel CAN be detained for: overriding alarm silenced; inadequate fire drill records; crew unable to demonstrate use of fire equipment; structural deficiencies; significant rest hour violations.

Question 3

After inspection, the PSCO states she has found deficiencies that may lead to detention. What categories of deficiency are "detainable" under Paris MOU?

Accepted Answer

DETAINABLE DEFICIENCIES — PARIS MOU: The Paris MOU defines a "detainable deficiency" as one that poses a CLEAR AND IMMINENT DANGER to safety, health, or the environment. Categories include: (1) ISM CODE: no ISM Certificate; ISM certificate expired; evidence that the ISM is not implemented — no drill records, no non-conformity reports, no audit records; (2) FIRE SAFETY: fire detection system inoperative; automatic fire dampers inoperative; fire main inoperative; CO2 system expired; lifeboat release mechanism seized; (3) NAVIGATION: primary navigation equipment inoperative (radar); no charts or grossly outdated charts; GMDSS equipment inoperative; (4) STRUCTURAL: vessel unseaworthy — hull damage, excessive corrosion compromising watertight integrity; (5) LIFESAVING APPLIANCES: insufficient lifeboats or lifejackets; lifeboat falls overdue; EPIRB expired or inoperative; immersion suits not available or defective; (6) MARPOL: IOPP certificate expired; no Oil Record Book or incomplete ORB; oil-water separator inoperative; (7) MLC: serious MLC violations — crew not paid, inadequate food/water, inadequate rest, serious accommodation deficiencies; (8) CERTIFICATION: officer certificates not valid for the role or expired; vessel undermanned below Safe Manning Document; (9) STCW: unable to demonstrate STCW competencies — crew cannot operate fire equipment, donning drills inadequate. NOTE: a single deficiency can cause detention if it is dangerous. Multiple minor deficiencies together may cumulatively justify detention. Paris MOU detention statistics: approximately 2-3% of vessels inspected are detained. Common deficiency categories include: fire safety/fire fighting equipment; safety in general; life-saving appliances; ISM. The CM's role before inspection: the best PSC preparation is a well-maintained vessel with proper documentation. The CM can reduce detention risk by: maintaining drill records; ensuring equipment is operational and tested; keeping certificates up to date; maintaining accurate ORBs; enforcing rest hours. CM role during inspection: the CM should accompany the PSCO on a walk-through and immediately address minor deficiencies that can be rectified during the inspection. If a fire extinguisher pin is missing — replace it during the inspection. This shows proactive compliance culture and may prevent a deficiency notice for the minor item. Master signing (option D): the master is asked to sign the inspection report to acknowledge RECEIPT of the inspection findings — not to "accept" the detention. Refusing to sign is noted on the report but does NOT void the detention. The PSCO has authority to detain under the port state's national law giving effect to the Paris MOU. Flag state reporting: deficiencies are reported to the flag state. Vessels with repeated deficiencies or detentions are targeted for more frequent inspection. The Paris MOU "black list" and "grey list" identify flag states with poor PSC performance records.