How to Avoid Port State Control Deficiencies

“PORT STATE CONTROLS ARE NOT RANDOM…AND THE LONGER A VESSEL GOES WITHOUT BEING CONTROLLED,
THE HIGHER UP THE PRIORITY LIST IT GOES!” – Franc Jansen

INTERNATIONAL SAFETY MANAGEMENT - ISM

This is a very generic “one size fits all” category for Port State Control Officers.

Anything related to lack of maintenance, quality seamanship, adherence to procedures and good record keeping can result in a conclusion of poor Safety Management. And if too many ‘little’ non-detainable deficiencies are uncovered by PSC they can be grouped together to form one major overall detainable deficiency.

Clearly, the only way to prevent this is to properly manage safety on board. Your ISM provider should always ensure you have a practical SMS specific to your yacht, one that is practical and efficient and does not overly burden the crew with administration. As I mentioned earlier, the starting point is not just to do the minimum required for compliance, it is to do what is necessary for quality seamanship. Compliance will always follow good seamanship.

On board, the SMS starts with a commitment from the Captain and the Chief Officer to adhere to and implement the SMS. Quality senior officers make the SMS their own and take ownership of it. If a procedure or check-list is not right, they adapt it for the better.

When senior officers believe in the system they are operating, a culture of safety is created amongst the whole crew. Yachts that are efficiently run with a smart SMS and a crew with a positive attitude to high safety standards, spend no energy worrying about the risks of a Port State Control Inspection because frankly, there rarely are any!

SAFETY RADIO (incl EXCEPTION)

The Radio Certificate is not one simple certificate – it is a series of certificates and records including the Record Epirp registration and annual testing, radio license, LRIT and IAS amongst others. All certificates must be valid, up-to-date and ready for inspection. Completing the GMDSS log may be a boring and repetitive task, but it is an important requirement, so it needs to be done. Captains should always ensure there are enough qualified persons on board who can operate the radio installation, two on-board crew should hold the required licenses.

MEANS OF ESCAPE

It might seem obvious, but often on a busy yacht, it is the simple and the obvious that gets missed and the fact this is the 8th most common deficiency proves that. Emergency escapes need to be kept free and accessible at all times. While storage is always a problem on yachts, using an emergency escape as storage should never be an option. Equally, and this is another common fault, the emergency escape hatch should never be closed so tightly that only the biggest engineer or deckhand can open it. Emergency escapes should be checked regularly on periodic safety rounds.

ENDORSEMENT BY FLAG STATE

All Officers and Crew must hold valid qualifications endorsed by the Flag of the yacht. It is not enough, for example, to have a UK MCA certificate on a Malta flagged yacht. The Flag of the yacht must have specifically endorsed the Certificate of Competence. An Officer without an endorsement cannot function as an Officer – that is a situation that can lead to the yacht failing on the required minimum Safe Manning document and being detained. It is a classic example of why Crew Certification on-board needs to be controlled and followed, with records kept of all Crew Certification and their expiry dates. Equally, every time a crew member arrives on board, it is important that the responsible Officer on board checks that all the original certificates for that Crew member are actually on the yacht.

VOYAGE & PASSAGE PLANS

Obviously voyage planning is required for all yachts going to sea and it is the Master’s duty to ensure a plan is drawn up detailing all the relevant factors and ensuring the requirements and procedures of the Flag State of SMS are being followed (SOLAS Chapter V, with Annex 24 and 25 list all the regulations for voyage and passage plans).

For longer voyages this is usually not an issue as they are known well in advance and come with plenty of time to prepare, but we all know how difficult it can be, mid-season, to make detailed voyage plans that take into account the ever-changing whims of our esteemed guests. In Annex 24, small vessels and pleasure craft are recognised and as such are required to make a voyage plan, and whilst the plan doesn’t actually need to be written down, the better your planning the safer you and your guests will be. And, in the unlikely event of a situation, the records you keep and are therefore able to show can go a very long way to ensuring any blame doesn’t fall unnecessarily on your shoulders.

FREEBOARD MARKS

It is always prudent to remember that the Freeboard Marks on the hull need to be in accordance with the Load Line Certificate of your yacht. The Freeboard Marks (or Plimsoll Marks) are usually a line indicating the Main Deck and a circle with a line with the initial of Class on the yacht indicating the maximum Load Line. I don’t want to state the blindingly obvious, but removing these marks on aesthetic grounds or having so much fuel, water or ballast on board so that the bottom line is underwater is a big NO-NO that will land you in deep trouble with PSC.

CONTINUOUS SYNOPSIS RECORDS

All commercial yachts over 500GT need to maintain a Continuous Synopsis Record (CSR). The CSR contains a list of records for the yacht. Each time a record in the CSR is changed, a new CSR should be issued. The purpose of the CSR is to keep a record of the history of the yacht. So, unlike other certification where obsolete certificates should be removed as soon as a new one is issued, the yacht needs to maintain a full set of CSRs on board. It is also important to check that the current CSR is accurate and importantly, that a full set is ALWAYS ON BOARD. CSRs are numbered so this can be checked easily. If any are missing or the records are not up-to-date, then you should contact your Flag immediately.

GARBAGE MANAGEMENT PLAN

Each yacht of 100GT or more and which carries more than 15 persons, needs to have a Garbage Management Plan. Yachts over 400GT also need to keep a Garbage Record. Placards detailing the garbage disposal need to be posted and a designated Garbage Management Person must be appointed, usually the Chief Officer, who delegates to the Chef and other crew. The persons involved need to be able to tell the PSC inspector what is in the GMP, so reminders to the crew every now and then, especially during safety meetings, can go a long way to being prepared for PSC. The Garbage Record Book needs to be maintained correctly and receipts should always be kept. In the situation where, for example, a marina does not automatically give out a receipt, the yacht can generate its own receipt and ask the marina to sign and stamp before leaving port.

CHARTS

The issue with charts for intended voyages is that they need to be updated. It has to be said that, even if we see it less and less on yachts, sending your paper chart folio to a chart correction company once a year whilst relying on an uncertified electronic chart system, is not the way to go about it. If you get a PSC inspection and you don’t have the correct charts on board or they have not been updated, you will be in trouble. Correcting charts is a tedious but necessary task and there are plenty of providers with systems available that can be a big help in easing the burden.

More and more yachts are fitted with ECDIS, which almost eliminates the issue. However, ECDIS has its own set of specific requirements as well. Paris, Tokyo and the Black Sea MOU recently carried out a Concentrated Inspection Campaign (CIC) specifically on ECDIS.

NAUTICAL PUBLICATIONS

And so we get to the N°1 deficiency in yachting in 2017 and, frankly, for most years. Each yacht must carry up-to-date nautical publications. The IMO lists the requirements for the publications each vessel has to carry. In addition, Flag may have some of its own requirements and other specific guidelines. You can find the requirement of both the IMO and your Flag state on their respective websites.

Of course, any reputable and experienced Yacht Management provider will not only be able to guide you on what your yacht’s requirements are, they will also have systems in place to ensure those publications are on-board and up-to-date, relieving you of at least one set of worries and responsibilities.

If you have any queries on any of the issues mentioned in this guide or if you would like
some help ensuring your yacht is fully PSC compliant, contact one of our team for a Port State Control
Audit or to find out more about our own personalised ISM System.

Email: hello@jmsyachting.com
Tel: Monaco +377 97 70 01 73
Site: www.jmsyachting.com

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