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If the PSC does not require the re-inspection of the close out of the deficiencies, it is a good idea to send an email to the port state through agent informing that the deficiencies have been rectified.
Code 17 deficiencies require quick action. The deficiencies need to be closed before departure from the port. But that is not the case with other deficiencies such as code 15 to be rectified before departure from next port or code 18 to be rectified within 3 months.
While the time period for getting the deficiency rectified is different in each of these deficiencies, the process is same. For example, for code 15 deficiency master must send the confirmation of close out of deficiency before departure from next port.
Or if it is required for the PSC inspector to verify the close out of deficiency, his presence must be requested through the agent in ample time.
Detainable deficiencies are serious and hence the process of close out of detainable deficiencies is also different from that for other deficiencies.
Well, the line that separates the code 17 deficiency from a detainable deficiency is thin but not too difficult for the port state officer to identify.
The procedure to use to identify a detainable deficiency is provided to the port state officers in PSC handbook of the MOU.
Paris MOU handbook for PSC inspectors further gives the deficiency areas that can be considered to be the ground for detention. For example, following are the deficiencies under SOLAS that can be considered to be the ground for detention.
These are just the guidelines. A deficiency in any of these areas does not mean that the ship will be detained. But what if none of the lights are working.
Then there is something serious about the deficiency and in most certainity, the vessel will be detained. The PSCO will also send the notice of detention to the flag of the vessel and to the classification society of the vessel.
Different PSCs would have different appeal procedures which can be either found on their website or can be received through the port agent.
Contrary to common belief, it is not too uncommon for the flag or shipowner to appeal against the detention of the vessel.
If the vessel is detained, it affects ship operation as no one wants to hire a ship that has recently been detained by port state control.
Even if the ship gets a hire, it will be on low freight rate as the shipper would have the bargaining power because of recent detention of the vessel.
The database of the very low performing ships and companies is publically posted on the website of most of the PSC MOUs. The appeal does not necessarily be for not agreeing to the deficiency.
The appeal can also be made if the owners or flag is of the opinion that the deficiency should have been the code 17 deficiency and not the detainable deficiency.
For example here is the case where the flag state disagreed with the detention of the vessel. Once the notifications have been done, it is time to work on closing the detention deficiencies as soon as possible to keep the delays to the minimum.
And the first thing we have to do is to understand the deficiency correctly. We cannot afford to misunderstand the deficiency and put our efforts towards areas which would not be required to close out the deficiency.
For example, if the deficiency is related to MARPOL, we need to know if the deficiency is related to a defective equipment or an observation related to the certification or documentation.
PSC deficiency codes help in that. Let us say that deficiency is related to the enhanced survey programme and PSC has provided the deficiency code as As we can see that code is related to the certificates and documentation only.
So our efforts need to be only towards getting the missing document or getting any pointed error corrected by flag state or classification society as applicable.
It is sometimes wrongly assumed that ISM related deficiency would mean deficiency related to the paperwork or documentation. Let us take an example of a deficiency related to in-operational fire detectors in accommodation.
One fire detector not working will be a code 17 deficiency. The deficiency will be under code and this needs to be corrected before departure. As the vessel will be detained, the PSCO will board the vessel to verify that the fire detectors have been rectified.
Once the PSCO is satisfied, the detention order will be lifted and the ship will be allowed to sail. Now let us consider this final situation where say, 10 or more fire detectors are found not working.
Needless to say that this will be a detainable deficiency under deficiency code But this also gives an impression to the port state inspector that the ISM code is not effectively implemented on board.
Because had it been effective, the defective fire detectors would have been identified during last weekly tests.
So many defective fire detectors point to the fact that the weekly routines are not being carried as required by the SMS.
The ISM code is not effectively implemented as apparently no weekly checks on the fire detectors are being carried out. And as I earlier mentioned, non-ISM related deficiencies need to be closed by rectifying the noted observation or defect.
But, the ISM-related deficiencies would only be closed after a successful external ISM audit which will be done by the flag or by classification society on behalf of the flag.
Over the years the port stay of the ships have reduced drastically which gives lesser time to the ship staff to deal with PSC deficiencies identified during PSC inspections.
But if we know exactly how to deal with the PSC deficiencies, we can save a lot of time and possible delays in close out of the deficiencies.
Rajeev Jassal has sailed for over 19 years mainly on crude oil, product and chemical tankers. He has done extensive research on quantitatively measuring Safety culture onboard and safety climate ashore which he believes is the most important element for safer shipping.
Dear Capt Rajeev. Please keep up the good work. Very nice and kind of you to do that. Capt jitender Sanyal.
Dear Capt. Jassal, Thanks for your clearly explanations of some words of the confusion in Colreg I am fully respect of you observation and intelligence.
Just coming 3rd june 18 , my mate oral examination in Myanmar. I hope well explains about the colreg 72 for my examiners.
Rajeev , very informative yet simple explanation of the various codes of the PSC codes. However , one pertinent thing is , whether psc inspections can be contested?
Nice share.. Thank you sir for the very informative article. I have a query on appealing against detention. What should be the immediate action on detention.
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These detailed and well researched articles provides value reading for all ranks. Ask or answer a question on this forum. Knowledge dies if it remains in our head.
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