PSC Concentrated Inspection Campaign on STCW

OverviewParis and Tokyo MoU will jointly launch a new Concentrated Inspection Campaign (CIC) on STCW compliance from 1st September 2022 to 30th November 2022. The inspection campaign will be additional to the regular PSC inspections. Aim of CICThe purpose of the Inspection Campaign is to determine the level of compliance with the requirements of STCW on board. As per the new revised guidance for PSC, issued by IMO Res. A.1155(32) “Procedures for Port State Control, 2021”, the PSCOs will focus on specific related items of Appendix 11 “Guidelines for Port State Control Officers on certification of seafarers, manning and hours of rest”. This means that PSCOs will not limit inspections only to a typical certification check but they will expand their focus on the evaluation of the Master, officers and crew’s competences when performing duties and during emergency scenarios. 

QuestionnaireThe CIC questionnaire (Appendix A) is a 10-question checklist with some items marked with * leading to detention. It should be noted that questions 6 & 7, related to rest hours and the work schedule, are not marked for possible detention.Actions requiredManagers, manning offices, Officers and crew onboard should be prepared to address the PSC CIC successfully. Appendix 11 of IMO Res. A.1155 (32) includes specific guidance for PSC inspections on Certification Of Seafarers, Manning and Hours of Rest. We provide guidance for preparing the response to questionnaire (Appendix B) and analyzing the possible problematic areas of Appendix 11 and possible deficiency codes related to CiC (Appendix C). 

Appendix A: Inspection Questionnaire

Appendix B: Best Practice Guidance on Inspection Campaign Questionnaire

1. Do the number of the seafarers serving on board conform with the Minimum Safe Manning requirement specified for the vessel?
The number and ranks of the crew on board to be in accordance with Minimum Safe Manning Certificate. In case a deviation is to  take place, this should be supported by Flag Administration dispensation approval, and be for a short period.

2. Do the Master and Officers hold valid certificates of competency as required by the Minimum Safe Manning Document?
Master and Officer to have valid certificates of competency. Crew department and Manning agent are responsible for the validity of the certificates.

3. Do the Master, Officers and Radio Operators hold valid endorsements attesting the recognition of certificates or documentary proof of application?
Valid endorsements to accompany relevant certificates of Master/Officers/Radio Operators.

4. Do seafarers hold relevant certificates of proficiency (COP) or documentary evidences?
Relevant certification of seafarers to be accompanied by required COP, or other supportive documentary evidence. Crew department and manning agent are responsible to check all related COPs or other documents.

5. Do seafarers on board hold valid medical certificates?
A medical certificate issued in accordance with the requirements of STCW shall be accepted, for the purpose of MLC Regulation 1.2. A medical certificate meeting the substance of those requirements, in the case of seafarers not covered by STCW, shall similarly be accepted.Unless a shorter period is required by reason of specific duties to be performed by seafarer concerned or is required under STCW:

1. a medical certificate shall be valid for a maximum period of two years unless seafarer is under age of 18, in which case, maximum period of validity shall be one year;
2. a certification of colour vision shall be valid for a maximum period of six years.

In urgent cases, a person may be employed without holding a currently valid official medical certificate until next port of call where he can obtain a medical certificate from a qualified medical practitioner, provided that:

1. period of such permission does not exceed three months; and
2. seafarer is in possession of a medical certificate which is expired for a period not greater than three (3) months.

6. Do the records for hours of rest indicate compliance with the requirements?
Company acknowledges that normal working hours’ standard for seafarers, shall be based on an eight-hour day with one day of rest per week and rest on public holidays, meaning that each hour exceeding this period shall be considered as overtime. This shall not prevent to implement any Flag procedures which authorize or register a collective agreement which determines seafarers’ normal working hours on a basis no less favorable than the MLC.Limits on hours of work or rest shall be as follows:

• maximum hours of work shall not exceed:
  • 14 hours in any 24-hour period; and
  • 72 hours in any seven-day period; or
• minimum hours of rest shall not be less than:
  • 10 hours in any 24-hour period; and
  • 77 hours in any seven-day period.

Hours of rest may be divided into no more than two periods, one of which shall be at least six hours in length, and interval between consecutive periods of rest shall not exceed 14 hours. When a seafarer is on call, such as when a machinery space is unattended, the seafarer shall have an adequate compensatory rest period if the normal period of rest is disturbed by call-outs to work.Records of seafarers’ daily hours of work or of their daily hours of rest shall be maintained to allow monitoring of compliance with the paragraphs above. The records shall be in a standardized format established by the Flag State taking into account any available guidelines of the International Labour Organization or shall be in any standard format prepared by the Organization.Seafarers shall receive a copy of the records pertaining to them which shall be endorsed by the master, or a person authorized by the master, and by the seafarers

7. Do the watch schedules comply with the provisions of STCW?
A table with the shipboard working arrangements should be posted in an easily accessible place. Table of arrangement shall contain for every position at least:

• the schedule of service at sea and service in port; and
•  the maximum hours of work or the minimum hours of rest required by national laws or regulations or applicable collective agreements.

Table referred above shall be established in a standardized format in the working language or languages of the ship and in English.

8. Are seafarers newly joined the vessel familiar with their specific duties that are relevant to their routine or emergency duties?
Every seafarer boarding vessel should be familiarized immediately with all items of “Essential Instructions to Seafarer” record provided by company and posted in mess rooms with all necessary information and Company policies.All newly joining crew, passengers or other professionals expected to sail with the vessel shall be familiarized to safety and environment protection aspects prior to taking over their duties. All items of that familiarisation should be carried out prior vessel’s sailing but within 24 hours from boarding time. Officers shall be familiarized on Company’s SMS prior vessel’s sailing, within 24 hours from boarding time.A post departure familiarisation shall be carried out prior assigning duties or within a 2-week (15 days) period from boarding, where each seafarer should be familiarized with safety procedures and department specific procedures, equipment and routines.Seafarers newly employed in service aboard the vessel, are provided with reasonable opportunity to become familiar with their duties and with all ship arrangements, installations, shipboard equipment, operating procedures and ship characteristics, relevant to their routine or emergency duties before assignment to those duties. Familiarization process shall be carried out by a delegated officer who shall explain and familiarize joining crew to critical aspects.

9. Can the seafarers on board the vessel communicate effectively with each other in the working language of the vessel?

Company through its Safety Management Systems should establish a standardized working language on board. All documentation related to SMS should be available in working language. Seafarers should be able to communicate on board using the working language defined by Company. Company should check the competency of seafarers on working language through test conducted either during familiarization period or at manning agents premises during recruitment stage.

10. Do the voyage plans cover the whole route from berth to berth?
The voyage plan should be thoroughly checked by navigation officer and then demonstrated to Master. After final Master’s approval the plan should be discussed on a briefing with all OOWs. The plan should cover all voyage from starting berth to ending port’s berth (or anchorage). Some Ship operators use the practice to request the plans to be send to Head Office for verification by a Marine Superintendent or Port Captain (only electronic passage plans exported from ECDIS). The final plan signed by Master should be available for use on primary and secondary navigation systems as they have declared in Ship’s “Record of Equipment”.Available options are:

• Nautical Paper Charts Only (primary method of planning paper charts, no back up plan is required)
• Two ECDIS (No Nautical Paper Charts). The ship is paperless for navigation. The plan should be uploaded on both ECDIS systems.
• ECDIS and Nautical Paper Charts. The ship has installed 1 ECDIS system and use full set of paper charts. The plan should be uploaded on ECDIS and additionally should be available on paper charts also. Both options should include exactly the same planning and parameters.

Appendix C: Inspection Questionnaire

IMO Res. A1155(32) – Appendix 11 Focus PointsAs per Appendix 11, the PSCO will focus on 3 basic issues.

1. Seafarer certification
2. Manning
3. Hours of Rest

Additionally, depending on ship’s overall PSC performance and the existence of clear grounds for more detailed inspection , PSCOs may require the demonstration of competency of each crew member. In that regard, they will check competences of the Master, officers and crew when performing duties and during emergency scenarios. Documentation RequiredThe documentation required for the inspection referred to in these Guidelines consists of:

1. Seafarer certification
   • certificate of competency;
   • certificate of proficiency;
   • endorsement attesting the recognition of a certificate (flag State endorsement);
   • documentary evidence (passenger ships only);
   • medical certificate;
2. Manning
   • minimum safe manning document;
   • muster list;
3. Hours of rest
   • table of ship working arrangements and/or watch schedule; and
   • records of daily hours of rest.

 What a typical PSCO inspection includesA. Seafarer certificates and documentsThe PSCO will request to examine the applicable documents, as per para. ‘Documentation Required’.The inspection will be limited to verification that seafarers serving on board, who are required to be certificated, hold the appropriate CoC, CoP and documentary evidence issued in accordance with chapters II, III, IV, V, VI and VII of STCW 1978, as amended, as well as their relevant flag State endorsement, valid dispensation, or documentary proof that an application for an endorsement has been submitted to the flag State Administration, where applicable. These documents are evidence of having successfully completed all required training and that the required standard of competence has been achieved. During the verification of the seafarers’ certificates and documents, the PSCO will confirm that they are applicable to the ship’s characteristics, operation and their position on board. B. ManningThe PSCO will  examine the applicable documents, as per para. ‘Documentation Required’.The guiding principles for port State control of the manning of a foreign ship should be:

1. verification that the numbers and certificates of the seafarers serving on board are in conformity with the applicable safe manning requirements of the flag State; and
2. verification that the vessel and its personnel conform to the international provisions as laid down in SOLAS 1974 and STCW 1978.

 C. Hours of restAll persons who are assigned duty as officer in charge of a watch or as a rating forming part of a watch and those whose duties involve designated safety, security and environmental protection duties shall be provided with a rest period of not less than:

1. a minimum of 10 hours of rest in any 24-hour period; and
2. 77 hours in any seven-day period.

The hours of rest may be divided into no more than two periods, one of which shall be at least 6 hours in length, and the intervals between consecutive periods of rest shall not exceed 14 hours.The PSCO swill  examine the applicable documents, as per Para. ‘Documentation required’, specifically the watch schedule and the records of daily hours of rest. The PSCO may inspect the seafarer’s personal copy of his or her records pertaining to the hours of rest being held by the seafarer on board in order to verify that the records are accurate. 

Possible DeficienciesThe following list (not limited) includes examples of possible findings during an inspection focusing to STCW.

Deficiency Codes Related to Inspection Campaign

 Detainable DescriptionsDepending on the description (finding), above deficiencies may result to an action code applicable for detention. The below are examples of descriptions that may lead to detention. 

Ship related possible detainable findings

• Minimum Safe Manning Document or equivalent not presented (SOLAS 1974 regulation V/14.2);
• records of daily hours of rest are not on board (STCW Code A-VIII/1.7);

 Seafarers’ documentation possible detainable findings

• not available or serious discrepancy in the CoC (STCW 1978 regulation I/4.2.1);
• absence in watch of a radio operator (general/restricted GMDSS); certificates and endorsement not available (STCW 1978 regulations I/4.2.1,I/4.2.2, I/4.2.3, I/4.2.4 and II/1.2.1);
• documentation for personnel with designated safety, security and marine environmental duties not available (STCW 1978 regulations I/4.2.1, I/4.2.2, I/4.2.3 and I/4.2.4);
• expired certificates (STCW 1978 regulation I/4.2.1), and for medical certificates also refer to STCW 1978 regulations I/9.6 and I/9.7;
• evidence that a certificate has been fraudulently obtained or the holder of a certificate is not the person to whom that certificate was originally issued.