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).
No. | Description | Yes | No | Detention |
1. | Do the number of the seafarers serving on board conform with the Minimum Safe Manning requirement specified for the vessel? | |||
2. | Do the master and officers hold valid certificates of competency as required by the Minimum Safe Manning Document? | |||
3. | Do the master, officers and radio operators hold valid endorsements attesting the recognition of certificates or documentary proof of application? | |||
4. | Do seafarers hold relevant certificates of proficiency (COP) or documentary evidences? | |||
5. | Do seafarers on board hold valid medical certificates? | |||
6. | Do the records for hours of rest indicate compliance with the requirements? | |||
7. | Do the watch schedules comply with the provisions of STCW? | |||
8. | Are seafarers newly joined the vessel familiar with their specific duties that are relevant to their routine or emergency duties? | |||
9. | Can the seafarers on board the vessel communicate effectively with each other in the working language of the vessel? | |||
10. | Do the voyage plans cover the whole route from berth to berth? |
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:
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:
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:
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:
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:
IMO Res. A1155(32) – Appendix 11 Focus PointsAs per Appendix 11, the PSCO will focus on 3 basic issues.
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:
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:
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:
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
Finding | Deficiency Area | Related PSC codes |
No CoC, CoP, flag State endorsements or proof that an application for an endorsement has been submitted (STCW 1978 regulations I/4.2.1 and I/10) | Certificate & Documentation | 01201 – Certificates for master and officers 01214 – Endorsement by flag State 01215 – Application for Endorsement by Flag State |
Special training requirements: mandatory basic or advanced training or endorsement not presented; | Certificate & Documentation | 01201 – Certificates for master and officers 01202 – Certificate for rating for watchkeeping 01203 – Certificates for radio personnel 01204 – Certificate for personnel on tankers 01205 – Certificate for personnel on fast rescue boats 01206 – Certificate for advanced fire-fighting 01208 – Doc evidence for personnel on ro-ro passenger ship 01210 – Certificate for medical first aid 01211 – Cert for personnel on survival craft & rescue boat 01212 – Certificate for medical care 01213 – Evidence of Basic Training 01216 – Cert for personnel on ships subject to the IGF Code 01217 – Ship Security Officer Certificate 01218 – Medical certificate |
No evidence of basic training, or other certificate of proficiency, if not included in a qualification certificate held (STCW 1978 regulations VI/1, VI/1.2, VI/3, VI/4 and VI/6); | Certificate & Documentation | 01201 – Certificates for master and officers 01202 – Certificate for rating for watchkeeping 01203 – Certificates for radio personnel 01210 – Certificate for medical first aid 01212 – Certificate for medical care 01213 – Evidence of Basic Training |
Information or evidence that the master or crew is not familiar with essential shipboard operations relating to the safety of ships or the prevention of pollution, or that such operations have not been carried out; | Certificate & Documentation | 01201 – Certificates for master and officers 01202 – Certificate for rating for watchkeeping 01299 – Other (STCW) |
No Minimum Safe Manning Document or the manning (number or qualification) not in accordance with the MSMD (SOLAS 1974 regulation V/14 and STCW 1978 regulation I/4.2.2); | Certificate & Documentation | 01113 – Minimum Safe Manning Document 01209 – Manning specified by the minimum safe manning doc |
Unqualified person on duty (STCW 1978 regulation I/4.2.4); | Certificate & Documentation | 01201 – Certificates for master and officers 01202 – Certificate for rating for watchkeeping 01219 – Training and qualification MLC – Personal safety training |
Watch schedule not posted or not being followed (STCW 1978 regulations I/4.2.3 and I/4.2.5 and STCW Code A-VIII/1.5); | Certificate & Documentation | 01306 – Shipboard working arrangements |
MLC | 18202 – Legal documentation on work and rest hours | |
The absence of a table of shipboard working arrangements or of records of rest of seafarers (STCW Code A-VIII/1.7); | Certificate & Documentation | 01306 – Shipboard working arrangements |
The records of hours of rest are inaccurate or incomplete (STCW Code A-VIII/1.7); | Certificate & Documentation | 01306 – Shipboard working arrangements 01307 – Maximum hours of work or minimum hours of rest 01308 – Records of seafarers’ daily hours of work or rest |
MLC | 18201 – Work and rest hours | |
The watchkeeper is receiving less than 10 hours rest in any 24-hour period (i.e. working in excess of 14 hours) or 77 hours rest in any seven-day period (STCW Code A-VIII/1). | Certificate & Documentation | 01308 – Records of seafarers’ daily hours of work or rest |
MLC | 18201 – Work and rest hours |
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
Seafarers’ documentation possible detainable findings