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18/03/2011 1 Understanding Oil Company vetting systems, Self- inspections and managing SIRE report comments to reduce inspector observations and deliver continuous improvement. Presenter. David Savage [email protected] Domestic and General Information Domestic Arrangements Emergency fire escape Toilets Smoking Mobil phones Lunch and coffee breaks Materials Assessment Self-introductions

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Vetting course for Superintendent

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Page 1: Sessions 1-6 Handouts

18/03/2011

1

Understanding Oil Company vetting systems, Self- inspections

and managing SIRE report comments to reduce inspector

observations and deliver continuous improvement.

Presenter.

David Savage

[email protected]

Domestic and General Information

� Domestic Arrangements

� Emergency fire escape

� Toilets

� Smoking

� Mobil phones

� Lunch and coffee breaks

� Materials

� Assessment

� Self-introductions

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Objectives and scope of this course

� Why do Oil Companies inspect tankers?� A brief history of why SIRE was introduced.

� Risk Management and spot chartering� How oil companies look at the risks involved with spot chartering

� The self- inspection walk round.� Thinking like an inspector.

� Dealing with inspectors.� How to get the outcome you want

� ABS Guide for IGS for ballast tanks

� OCIMF Annual Report (2010)

� OCIMF 2011 VIQ Rev 0

� OCIMF Paper on Entry into Enclosed Spaces

� OCIMF/LR Study re Emergency Towing Off Pennants

� OCIMF paper Hazards associated with use of additional moorings

� OCIMF SIRE Brochure (2004)

� OCIMF and Industry paper on Oily Water Separators

� BP High Risk Observations List

� ExxonMobil Marine Environment Quality and Safety Criteria Booklet (2010)

� ConocoPhillips Marine Vetting and Audit Criteria

Additional Materials (1)

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� IMO Guidelines on Seafarers’ Working Hours re MLC 2006

� IMO MEPC.1/Circ 736 (Nov 2010) Oil Record Book Guidance

� IMO Current Awareness Bulletin (Nov/Dec 2010 Eds)

� IMO Annual Testing requirements for AIS (MSC Circ 1252)

� Danish Government Mooring accident report

� Draeger Tubes Handbook

� LR MSC88 Report

� IMO Near-Miss reporting

� IOPPC Form B

� OCIMF On-line Crew Matrix Guidance

Additional Materials (2)

• Intertanko Inspector Performance feedback• AMSA Marine Notice on MSDS• On-load release gear video clip• Lifeboat premature release video clip• UKMCA Human Element• Aide Memoire on Paris MOU 2011 Inspection

Regime• UK MAIB Report on CFL Performer Grounding

(“ECDIS assisted grounding”)

Additional Materials (3)

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Remember…

Knowledge is Power!

Documents you

must be familiar

with..

1. Knowing the Rules

• SOLAS

• Fire Safety Systems Code

• Life Saving Appliance Code

• MARPOL

• STCW

• ISGOTT

• The OCIMF SIRE VIQ

How much do YOU know?Let’s find out with a short quiz...

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2. The history of OCIMF, why SIRE was needed, Risk Management and Spot Chartering

A Voice for Safety

Awareness of the threat of massive oil pollution from tankers

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March 1978

Major Oil Spills since 1967

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Liability and Compensation – Applying the ‘Polluter Pays Principle’OPA 90 is based on a polluter pays principle holding the owner/operator strictly liable. It establishes limitations ofliability at higher levels than international conventions and removes limitation protection if the incident was caused by gross negligence, wilful misconduct or violations of Federal safety, construction or operating regulations by the responsible party. In normal circumstances the owner will respond to the spill and his insurance ($1 billion cover forpollution is typical) will fund the response. This framework ensures that the shipowner takes on the major proportionof the liability risk and this structure has been instrumental in discouraging low quality operators from trading in theUS.

The impact of OPA ‘90

The immediate aftermath following the introduction of OPA ‘90

1. Introduction of Oil Co Vetting and Inspection Departments

2. Excessive inspections of the same tanker by different Oil Cos at the same time

3. Inability of individual Oil Cos to inspect ALL tankers of potential interest

4. Inability to maintain inspection intervals within a reasonable time frame

5. Excessive burden on tanker officers and ratings

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1991-1993 Timeline

1991 Full scale Oil Co Inspections commence

1991-2 Severe shortcomings in the “Go it alone” approach recognised at OCIMF

1992 Report sharing concept agreed among OCIMF Members. Development of SIRE commenced

1993 17 Nov. First inspection report submitted to SIRE

SIRE inspections

NOT conducted

Tanker Industry Total: Approx 8,500 vessels

0

2000

3000

4000

5000

6000

7000

8000

SIRE Database

The Demise of The Grey Fleet

2002 2003 2004 2005 2006 2007 2008 2010

1000

2000

3000

4000

5000

6000

7000

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So you think that oil companyvetting superintendents are too demanding. Consider this...

For a Vetting Superintendentevery vetting decision

is a career decision!

For this reason, Oil Company Charterers are extremely careful to ensure that all aspects of potential vessels are

carefully reviewed

Some of the OCIMF Members who Submit SIRE Reports

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The Oil Company Vetting Dept

• Risk Assessment Teams

• Mathematical models

• Automated Computer Systems

What do they look at?

The Three Categories of Shipping Risk

1. Owned Vessels

• Least risk

• Greatest control

2. Time Chartered Vessels

• Better than ‘Spot’ but falls short of owning

3. Voyage ‘Spot’ Chartered Vessels

• Most Voyages

• Greatest risk

• Least knowledge of quality by charterer

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Spot-Chartering and Risk Management• All oil majors have their own quality

assurance schemes

• Schemes vary due to company size, scope & diversity of activities, attitude to marine risk and use of real time information and the quality of analysis. Some use 3rd party vetting.

• All companies input/extract factual ship inspection reports (SIRE) from Oil Companies International Maritime Forum (OCIMF) database

• Determination of vessel utilisation is solely at each company’s discretion.

• Liability concerns dictate how individual companies approach the vetting issue

• Increasing use of auto-vetting. Auto-vetting counts the number of observations, regardless as to how trivial the observation might be.

Considerations by the Vetting Dept

Age

Will it fit?

Name of Operator

TMSA

Can it load nominated

cargo?

Current Class?

Class Changes?

Flag Changes?

Change

of

OperatorStructural Analysis

Inspection History

Operational History

Overall Fleet Profile Voyage Risk

Assessment

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The Function of the Oil Company Charterer

� Charter most cost effective (aka Cheapest) freight where the vessel meets all criteria i.e. vetting, marine assurance, credit, etc.

� The Charterer will:-

� Make freight calls about the forward market (when traders are doing spot deals & in anticipation of system cargoes)

� Provide shipping market intelligence for traders, monitor what competitors are doing

� Provide alternative freighting solutions

� Provide chartering expertise and guidance to other parts of the company

Chartering as the Oil Co Charterer sees it

Traders

Shipbrokers Ship owners

Charterer

Oil SupplyOperations

Oil Co’s own Ship Operations

Vetting Dept

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Typical oil company charterer’s vetting enquiry

to the internal vetting system

� Vetting system requires :

� Vessel’s name / IMO number

� date of loading

� cargo type

� load port

� discharge port

� account / costs centre

Typical Oil Company Spot Charter Process

Input Ship for Vetting :laycan, load port, cargo type, For

whose account is vl to be chartered

Clear for charter

Initiate own SIRE Inspection

No

YES

Resolve Issues with Owners

Maybe

Check for newSIRE

Vetting & Assurance

Dept

Fix for voyage

Voyage PerformanceMonitored

Find other ship

“No Other Ship”

Issues resolved OK?

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Ship Inspection Report (SIRE) Programme

Oil Companies International Marine Forum

3. The OCIMF SIRE Programme

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SIRE Principles

• Reports are submitted to SIRE on a voluntary basis by OCIMF Members

• Payment for the inspections on a “Who asks, pays” policy

• Ship operator can make two sets of comments relating to each report and submit these to SIRE

• Comments become part of the report

The SIRE Principles

• Uniform inspection protocols for all vessels are provided by Vessel Inspection and Barge Questionnaires (VIQs and BIQs)

• The reports are delivered in standard format

• Vessel particulars, certification and on-board inventory details are provided by Vessel Particulars Questionnaires (VPQs) and Barge Particulars Questionnaires (BPQs)

• All SIRE Components are electronic

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SIRE Objectives

•Obtain information of the vessel’s condition and standards of operations to permit an assessment to be made

•Make inspection reports more widely available

•Reduce the duplication of effort by inspecting companies

•Reduce the inspection burden on Operators and crews

The Scope of OCIMF’s Responsibilities

• Provide software to create and submit inspection reports

• Review for compliance, reports submitted by participating Oil Companies

• Facilitate the submission of Operator Comments to SIRE

• Storage of reports and attachment off Operator Comments

• Software to create and submit HVPQs by Operators

• Delivery of SIRE reports to Programme Recipients• Training, Accreditation and Administration of SIRE

Inspectors• OCIMF HAS NO ROLE IN THE SELECTION OF

INSPECTORS

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SIRE Report Recipients

How Reports are Accessed

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The Delivered Report: Inspector Observations, Other Comments and Additional Comments

� Observations provide negative information to the reader. They are printed in red.

� Other Comments are “value added”. They are provided to separate Observations, from positive comments. They re printed in blue.

� Additional Comments at the end of each VIQ Chapter may be used to record Observations that are not covered under any of the questions that are listed in the Chapter.

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The SIRE Report Contents

Sect 1 General Information

Sect 2 All Questions answered Y without comments

Sect 3 All Questions answered N with Observations, or answered Y WITH Other comments

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Section 3 Contains all questions answered

“No” or if

the answer contains “Other Comment”

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Accessing the HVPQ

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Using the SIRE VIQ for Self-inspections

Many Operators use SIRE as a KPI. It is therefore essential to

keep the number of observations to an absolute

minimum.

Conduct regular self inspections using the SIRE VIQ

Allocate responsibilities among department heads and officers

responsible

Ensure that the VIQ is provided to all

controlled vessels

� Instruct Masters to distribute the appropriate VIQ chapters to those officers who are responsible for the operations/roles covered in the various chapters

� Ensure that these officers perform joint REGULAR self-Inspections using the VIQ Chapters – not just before the actual inspections

� Act to fix defects under the your company’s SMS and Defect Management System

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4. SIRE Inspections - Key Issues

� Overall Safety of the inspection

� How the inspection will be conducted

� Duration of the inspection

� What the inspector can and cannot do

� Refer to the Introductory Sections of the VIQ – particularly Sect 4.

� Let’s look at Section 4...

Conduct of the inspection

� Understand the guidance contained in the VIQ introduction, Section 4 and ensure that the inspector follows this

� 4.1 Deals with Dos and Dont’s

� 4.2 deals with Permitted Actions

� 4.3 deals with inspection suggestions.

� Ensure that the inspector does not remain on the vessel longer than is absolutely necessary

� Remember that the intro twice refers to the inspection duration as “8-10 hours”

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The Use of Additional Comments

� The SIRE VIQ cannot ask questions about each and every situation encountered or piece of equipment that might be fitted.

� The Additional Comments feature permits inspectors to make comments relating to any situation, or equipment that is fitted.

� If the inspector makes observations in “Additional Comments” ensure that he points out exactly the IMO or other recognised publication that relates to the observation.

� The good news is that inspectors vary rarely use the Additional Comments feature

Overall Safety

� 1. Ensure full PPE is worn at all times when outside accommodation or in machinery spaces.

� 2. If H2S or Benzene is present in the cargo, make this known to the inspector immediately on boarding.

� 3. Ensure ISGOTT Ch 10 and OCIMF guidance on entering enclosed spaces is followed TO THE LETTER.

� 4. Ensure that if any unusual situation exists, this is fully explained PRIOR to the commencement of the inspection

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The New Officer’s Matrix (VIQ 3.10)

� Inspectors must download the officers matrix prior to boarding.

� This is intended to save time and reduce the overall time on board.

� Ensure, however that the officers certificates and time-served records are kept ready for the inspectors review.

� Ensure that the person responsible to keep the matrix up to date, does so.

Getting ready and staying ready

1. Conduct regular self inspections

2. Correct all shortcomings

3. If shortcomings are noted but not fixed ensure that proof of corrective actions are available

4. Ensure personnel are aware of the inspectors expectations – responsible officers must be able to respond to inspectors’ questions

5. Ensure all documents and equipment that the inspector wants to see, is set out and ready for inspection

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5. The Inspection - First Impressions

What is the inspector looking for?

The problem areas relating to oil spills...

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Mooring

• Sufficient mooring lines?

• Any mixed moorings?

• Condition of the mooring lines?

• Are synthetic tails are properly attached to wires?

• If required, are Emergency Towing Off Pennants (ETOPs) correctly rigged?

Approaching the vessel

Access to the vessel – is it safe?

• What does it comprise?

• Is it safe enough to permit the inspector to

proceed?

• Unless a shore gangway is used, a safety net

should be fitted

• Will the method of using the safety net prevent

injury?

• Are a heaving line, lifebuoy and light available?

• Is the “No Visitors” notice posted where it can be

seen from the shore?

Boarding

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18.2.2

When the inboard end of the gangway or accommodation

ladder rests on or is flush with the top of the bulwark, a

bulwark ladder should be provided.

Any gap between the bulwark ladder and the gangway or

accommodation ladder should be adequately fenced to a

height of at least 1 metre.

18.2.3

Gangways and other access equipment should not be

rigged on ships’ rails unless the rail has been reinforced for

that purpose. They should comply with the guidance in

Annex 18.1.

Code of Safe Working Practices for Merchant Seamen

3.3 LifebuoyA lifebuoy equipped with a self-igniting light and a buoyant lifeline should be available for immediate use in the vicinity of the embarkation and disembarkation arrangement when in use.

MSC.1/Circ.133111 June 2009GUIDELINES FOR CONSTRUCTION, INSTALLATION, MAINTENANCE AND INSPECTION/SURVEY OF MEANS OF EMBARKATION AND DISEMBARKATION

2 CONSTRUCTION2.1 Accommodation ladders and gangways for means of embarkation and disembarkation which are provided on board ships constructed on or after 1 January 2010 should meet applicable international standards such as ISO 5488:1979, Shipbuilding – accommodation ladders, ISO 7061:1993, Shipbuilding – aluminium shore gangways for seagoing vessels and/or national standards and/or other requirements recognized by the Administration. Such accommodation ladders and gangways fitted on ships constructed before 1 January 2010, which are replaced after that date, should, in so far as is reasonable and practicable, comply with these Guidelines.

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VIQ 2011

5.80 Are accommodation ladders, gangways, pilot ladders and pilot hoists, where fitted, in good order?Means of embarkation on and disembarkation from ships. 1. Ships constructed on or after 1 January 2010 shall be provided with means of embarkation on and disembarkation from ships for use in port and in port related operations, such as gangways and accommodation ladders, in accordance with paragraph 2.2 .The means of embarkation and disembarkation required in paragraph 1 shall be constructed and installed based on the guidelines developed by the Organization (MSC.1/Circ 1196) (SOLAS II-1/3-9)MarkingEach accommodation ladder or gangway should be clearly marked at each end with a plate showing the restrictions on the safe operation and loading, including the maximum and minimum permitted design angles of inclination, design load, maximum load on bottom end plate, etc. Where the maximum operational load is less than the design load, it should also be shown on the marking plate. (MSC.1/Circ.1331/3.5)

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Boarding by Pilot Ladder?

The self igniting light must be intrinsically safe if deployed in a

gas hazardous area

Security

• Is the gangway manned?

• Is the gangway watchman provided with a walkie-talkie?

• Does the gangway watchman challenge the inspector?

• Does he:-

• Ask for SIRE ID?

• Ask the inspector to sign a Visitor’s Book

• Provide the inspector with an Emergency Stations Card

• Ask to see inside the inspector’s bag

• Ask to check mobile phone is switched off

Critical moments - Coming on board

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ACCREDITED SHIP INSPECTOR

PHOTO

Michael D Billet

is accredited to inspect

Oil/Chemical/Gas

Vessels

Inspector No. 1003

Expires: 20/09/2003 AUDITOR

SHIP INSPECTION REPORT (SIRE) PROGRAMME

Critical moments – Meeting the Inspector

• Are all dipping/sampling points closed?

• Is small spill clean-up equipment provided near

manifold?

• Are fire hoses rigged in vicinity of manifold?

• Are bolts inserted into all the manifold flanges?

• Are all unused manifolds blanked/fully bolted?

• Are pressure gauges fitted outboard of the manifold

valves?

• Are all scupper plugs in place and tight?

• Are scuppers free of rain water?

• Are portable pumps rigged for immediate use at aft end

of main deck?

First Impressions - The walk to the accommodation

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• The inspector has been on board for only a few minutes

• He has not yet met the Master, but…

• ...what he has already seen is important

and...

• ...the initial and very important impression has been gained

...first impressions

• Are all accommodation doors shut?

• Is the watertight door seal packing sound?

• Is the accommodation under positive pressure (Can you feel a draft in your face?)

Entering the Accommodation

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ISGOTT

5th Edition

Chapter 4.1

Air pressure inside the accommodation block

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ISGOTT24.2 Central Air Conditioning and Ventilation Systems

On ships with central air conditioning units, it is essential that the accommodation is kept under positive pressure to prevent the entry of hydrocarbon vapours. Intakes for air conditioning units are usually positioned in a safe area and vapours will not be drawn into the accommodation under normal conditions. A positive pressure will bemaintained only if the air conditioning system is operating with its air intakes open and if all access doors are kept closed, except for momentary entry or exit. The system should not be operated with the intakes fully closed, that is in 100% recirculation mode, because the operation of extraction fans in galley and sanitary spaces will reduce the atmospheric pressure in the accommodation to less than that of the ambient pressure outside.

• Are the alleyways brightly lit, free of clutter and clean?

• Are the posted fire and safety signs clearly legible?

• Are the Station Bills (Boat Lists) up to date?

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Why it is useful if the C/E and the C/O are present at

the opening meeting.

Topics for discussion

1. The order of the inspection.

2. What equipment the inspector wants to see operating.

3. Confirmation that the access hatches to the ballast

tanks to be sighted from the deck are ready to open

4. Any unusual conditions on board that need to be

pointed out

5. Any defects that exist and which will be seen by the

inspector

6. The timing of the inspection will be 8-10 hours

7. The inspector must be considerate of the work

demands on ship’s staff

The pre-inspection meeting

Certificates and Documentation

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VIQ 2.1Are all the statutory certificates listed below, where applicable, valid and have theannual and intermediate surveys been carried out within the required range dates?

Set out certificates in exactly

the same as in 2.1 of the VIQ

2.1.1 Certificate of Registry

2.1.2 Continuous Synopsis Record

2.1.3 Document of Compliance (DoC)

2.1.4 Safety Management Certificate (SMC)

2.1.5 Safety Equipment Certificate, supplemented by Form E

2.1.6 Safety Radio Certificate, supplemented by Form R

2.1.7 Safety Construction Certificate

2.1.8 IOPP Certificate, supplemented by Form A or B

Statement of Compliance supplement

2.1.9 What is the vessel’s designation as recorded in the IOPP Certificate, Form

B, Question 1.11?

2.1.10 Minimum Safe Manning Document

2.1.11 Certificate of Fitness for the Carriage of Chemicals or Gas

2.1.12 Noxious Liquid Substances (NLS) Certificate

2.1.13 Civil Liability Convention (1992) Certificate

2.1.14 Name of P and I Club:

• General information for Chapter 1 of the VIQ

• Operator’s Operating Procedures Manuals

• Class Condition Survey files

• Enhanced Survey Programme (ESP)

• Condition Assessment Scheme (CAP)

• IOPPC with Part B

• Oil Record Books (both Pt 1 and Pt 2 together)

• Hours of Rest records

• Garbage Management Books

Certification and documentation (1)

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• Publications

• Crew management

• Crew licences and records of sea service

• Drug and alcohol policy

• Safety management

• Minutes of meetings,

• Records of drills, training and familiarisation

• Record of Visits by Operator’s Superintendent

• (Do Not Provide Superintendent’s Audits)

Certification and documentation (2)

• Ship security

• Enclosed space, and pump room entry procedures

• Hot work procedures and certificates. Remember – the

more Hot Work Certificates there are, the more

concerned the inspector will be

• Life-saving equipment from the LSC and Form E

Certification and Documentation (3)

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• Shipboard oil and marine pollution

emergency plans

• Ballast water management plans

• Garbage management plans and logs

• Crane and Cargo lifting equipment records

• Ship to ship transfer operations

• VOC Plan

• Mooring equipment records

Certification and Documentation (4)

Hours of Rest – Be very careful

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Watchkeeping Schedules

STCW Code Section A-VIII/1.5 of the STCW requires watch schedules to be posted in an ‘easily accessible’ location on the ship.

These schedules should relate to the ‘actual’ watch keeping arrangement at sea and in port.

The actual Manning level aboard and trading pattern of the vessel is key

� Accuracy in the completion of the hours of Rest Log

� Documents that may be reviewed to check the accuracy of the Hrs of Rest Log:

� Oil Record Book ( Deck & Engine)

� Enclosed Space Permits & Entry Logs

� Tanks Washing – details of wash times

� Purging, Gas freeing and re-inerting

� Records of Drills – if outside normal work hours, are they logged?

STCW Hours of rest –Compliance is either difficult or impossible

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� Manning Levels

� Two or Three deck officers will arouse suspicion

� Manning is at, or close to, the minimum as stated in the Minimum Manning Document

� Vessels Operating under UMS

� Work Schedules in port

� Both deck and engineering officers are subject to non-compliance

� Chief Officer and Chief Engineer are key candidates

Hours of rest compliance (2)

� Is the Hours of Rest Log completed in accordance with Company instructions?

� Does the SMS have clear instructions to prevent fatigue?

� Is the Comments section completed?

� Are the total daily and weekly hours recorded?

� Will inconsistencies between the recorded hours of rest versus actual evidence be uncovered?

Hours of rest compliance (3)

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� Oil Record Books

� Part 2

� Cargo loading or discharging

� COW operations

� Tank Washing

� Slop tank decanting

� Part 1

� Bunkering

� OWS operations

� Transfer of residues to slop tanks

� Incineration of waste

Hours of Rest – Practical checks (1)

� Enclosed Space Permits & Enclosed Space Entry Logs

� Dates and Times when permits were opened and closed

� Who was in the spaces

� Comparisons between purging and gas freeing times

Hours of Rest – Practical checks (2)

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Some examples of inspector observations seen in SIRE Reports

� The vessel maintained work rest logs as required.

However, when the current month’s log (May ‘08) was checked in the computer it was noted that the entire month for both deck and engine departments had already been filled out.

The inspection was conducted 11 of May.

Some examples of inspector observations seen in SIRE Reports

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� The engine oil record book showed that the vessel conducted bunkering operations on 2 of Jan between 0100 and 1000.

The Chief Engineer and 2nd Engineer’s Hours of Rest logs were reviewed and both were shown to have been working a normal day ( 0800-1700) on 2 Jan. The vessel operated UMS at sea and manned in port.

Some examples of inspector observations seen in SIRE Reports

If the Inspector is wrong, do not accept an

Observation

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Signatures in the ORB Part 1

� Signatures to be

by the officers in

charge of the

operation

� If the C/E signs the

ORB Part 1 it is a

simple matter to

cross check with

the Hours of Rest

Records

Some examples of inspector observations seen in SIRE Reports

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General PSC Findings

� Hours of rest not being complied with in port resulting in watch keepers on duty for departures and first sea watches not being adequately rested;

� Records of hours of work/rest are not being maintained;

� Records of hours of work/rest do not reflect the actual working arrangements; and

� The Safety Management System of the ship is deficient in ensuring compliance.

� Logs are being completed by a single person – not by the individuals concerned

� Logs are not completed on a daily basis “without delay” – Marpol Annex I 36.5

� Many people assume a 00-24hr day is used – this is not the case. STCW uses the term, “In any 24 hour period”

� Most entries are simply fictitious!!!!!

Hours of Rest - conclusions

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Major concerns for Oil Cos, but ballast tank entry during cargo transfer is not encouraged.

A review of the ESP Report File is essential.

Cargo and ballast tank conditions

A planned inspection programme must be in place

Important:

Review the Condition Evaluation

Report/Executive Summary

The bad words…

• Substantial corrosion

• cracks

• Serious incidents

Review of the ESP File

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IMO Resolution A.744(18): Annex B: ‘Guidelines on the

enhanced programme of inspection during surveys of oil

tankers’.

Enforced by:

MARPOL 73/78 Resolution A744(18)

IACS Unified Requirements, IACS UR Z10.1 (Hull Surveys

of Oil Tankers) specifies the minimum overall and close-up

surveys for:

•plate thickness measurements

•tank testing

•survey planning and reporting

ESP Requirements

Overall Survey: A survey intended to report on the overall condition of the hull structure and determine the extent of additional Close-up Surveys.

Close-up Survey: A survey where the details of structuralcomponents are within the close visual inspection range ofthe surveyor, i.e.. Normally within reach of hand.

Suspect areas: Locations showing substantial corrosionand/or are considered by the surveyor to be prone to rapidwastage.

Substantial corrosion: An extent of corrosion such thatassessment of corrosion pattern indicate a wastage in excessof 75% of allowable margins, but within acceptable limits.

ESP Requirements – Important Definitions

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To include:

• item and location of where measurements taken;

• measured thickness and original (and minimum) thickness;

• date when carried out;

• type of measurement equipment;

• name of the Operator and whether Class approved;

• Class surveyor’s verification and countersignature.

(The inspector will check details in the ConditionEvaluation Report)

Thickness measurement reports

• General – The bigger the file, the more concerned the inspector will be.

• ISGOTT Guidance must be followed.

• Consideration of alternatives,(such as cold work).

• Planning.

• Execution.

• What is the notification and agreement process between vessel and shore management?

Hot work certificates

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ISGOTT 4th Edition

Hot Work – the ISGOTT 5 position

ISGOTT 4th Edition had box requiring consultation with

office

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This assumes that the SMS insists on notification and agreement by shore management to ALL hot work within gas-hazardous areas

The OCIMF Guidelines relating to SMS and Hot work

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OCIMF GUIDELINES ON SAFETY MANAGEMENT SYSTEMS FOR HOT WORK AND ENTRY INTO ENCLOSED SPACES . Sep 2008

The SMS should ensure that: -

(i) Any Hot Work to be carried out is necessary for:-

(a) the safety, and / or,

(b) the immediate operation of the ship, and that all viable alternatives have been considered and reasons for rejection are documented.

(ii) Full consideration has been given to performing the Hot Work in a designated space such as the engine room workshop where conditions are deemed safe.

(iii) Full consideration has been given to all hazards associated with the Hot Work process, as identified within a formalised Risk assessment.

Principles for an Effective Safety Management System for the Control of Hot Work. 2.1 General:

2.2 Pre – agreement: The requirement for Hot Work outside the designated space should be agreed between the Shipboard Management Team and the Company (office). The discussion may include: evaluation of alternatives (including Cold Work), duration of job, scheduling, ship’s staff and/or contractors, materials and logistics, stability and stress and weather forecasts.

OCIMF GUIDELINES ON SAFETY MANAGEMENT SYSTEMS FOR HOT WORK AND ENTRY INTO ENCLOSED SPACES . Sep 2008

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Restricting the issue of approvals, such as entry permits, so that all cargo tanks which are safe to enter are shown on one document, may be found to simplify the paper administration,avoid overlapping and reduce the possibility of confusion as to which approval applies to which tank. However, if such a system is used, there must be rigorous control to ensure cancellation of existing permits, and that the atmospheres of all named tanks are correctly tested at the time of issue so that an effective extension of a period of validity does not occur by default. It will be particularly important to ensure that the permit process is supplemented by the marking of tank lids with notices indicating which tanks are safe to enter.

The ISGOTT position relating to entry into enclosed spaces

10.4-Control of entry into enclosed spaces

The OCIMF Position Relating to SMS and Enclosed Space Entry

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3.2 List of principles for Entry into Enclosed Spaces: The SMS should consider the following:-

(i) That best practice examples consistently show the benefit of Single Permit use for individual spaces. However, in certain limited cases it might be appropriate to utilise a single permit covering multiple enclosed spaces.

OCIMF GUIDELINES ON SAFETY MANAGEMENT SYSTEMS FOR HOT WORK AND ENTRY INTO ENCLOSED SPACES . Sep 2008

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Garbage Management

• Certificates folder is disorganised

• Ship’s management manuals not updated

• Ship’s manuals not signed by personnel

• SOPEP manual not revised

• Mooring records not maintained

• Personnel unfamiliar with SOPEP contents

• Unsatisfactory winch testing records

• Certificates for mooring lines do not indicate the winch

on which they are stored

• Inadequate Hot Work and Enclosed Space Entry

Permits

• Physical evidence not in conformity with records

• Fire plans do not reflect actual equipment

• Unfamiliarity with contents of management manuals

• Hours of Rest Records

Common documentation Observations

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6. Oil Record Book Exercise

Please review the excerpts from the Oil Record Books from the vessel “Caledonia”

Please look for irregularities in these and record your findings

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4 Each operation described in paragraph 2 of this regulation shall be

fully recorded without delay in the Oil Record Book Part I, so that all

entries in the book appropriate to that operation are completed. Each

completed operation shall be signed by the officer or officers in charge of

the operations concerned and each completed page shall be signed by

the master of ship. The entries in the Oil Record Book Part I, for ships

holding an International Oil Pollution Prevention Certificate, shall be at

least in English, French or Spanish. Where entries in an official national

language of the State whose flag the ship is entitled to fly are also used,

this shall prevail in case of a dispute or discrepancy.

Annex I Reg 17

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ORB Part I

4 Apr 1999C12 10t should be m3C12.1 No receipt issuedH27.2 1230 – no start or finish time

recorded

6 Apr 1999D13 Tonnes recorded and not M3D15.4 Tonnes recorded and not M3

� C 11.1 Sludge tank – Its actual ID is not mentioned

3 t should be M3

� C12.1 No record of the receiver of the sludge – no receipt issued

2.5t in a 20 day voyage is too little

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� 23 Apr 1999

� Code D No mention as to whether an automatic stopping device is fitted. (Special Area)

28 Apr 1999

H27.3 Individual quantities loaded to Foredeep tanks is not recorded

No entry is made in the ORB Part 1for bunker spill – but it is recorded in Part II

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� Part II

� 4 Apr ’99

� A3 3C Tank overloaded 5190m3/5155

� 6 Apr 99

� Transfer from ER 3t to Slop Tank not recorded

� 24.4.99

� D16 Use of Eductor suction gauges to measure tank is empty is not a satisfactory method

E18 Ballasted 3C but this tank was not COW’d

G31.2 1140M3 washing water (plus 60mt from slop tank ROB) = 1200m3, but total recorded = 1387m3 (discrepancy 137m3)

26 Apr 99

H32 De-ballasted 3C in special area

� I42 Settling time records 26 hours within one day?

� I 47/48 Bulk rate is lower than the final rate of discharge.