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Sunday, March 17, 2013

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INTERCARGO Inspection Reporting Form
Industry Issues

These are the leading issues in our industry:
Bulk Carrier design and safety
Port State Control
Mississippi Towage
The safety of terminal loading and discharging operations
Flag issues
Environmental protesters
Education and training
Security and the dry bulk industry

Bulk Carrier design and safety

Concern for the lives of seafarers and the safety of ships means that safety is very much at the forefront of the activities of Intercargo. Indeed, Intercargo runs a Technical Committee, known as CASTEC, which meets twice a year alternating between venues in Asia and Europe, to discuss technical matters. It also runs technical seminars on a wide range of subject matters.
Bulk carrier design and safety has been a major work item of both the IMO and IACS in recent years. Following a period in the late 1980's / early 1990's when a large number of bulk carriers and their crews were lost, a major work programme was initiated. This culminated in 1997 with significant changes to both SOLAS regulations and IACS rules with the introduction of new hull structural strength and damage survivability provisions. In response to further concerns about the safety of bulk carriers, IMO then instigated a number of Formal Safety Assessment (FSA) studies. In December 2002, and after all these studies had reported their findings, a series of recommendations for rule-making were agreed by the IMO. SOLAS amendments were approved at the IMO MSC meeting 78 in May 2004. That meeting also voted to maintain optional as opposed to mandatory, Double Skin Bulk Carriers - an issue widely supported by Intercargo and other industry participants pending wider operational experience of DSS Bulk Carriers.
Intercargo also continues to work closely with IACS to develop safe, efficient, environmentally friendly and operationally streamlined bulk carriers. Intercargo and IACS hold regular technical and policy meetings, concentrating on important issues such as the Joint Bulker Project Common Rules. The ultimate aim of the JBP project is to reduce the interpretive differences between individual classification societies - the importance of which cannot be understated.
Intercargo also continues to monitor bulk carrier losses. It has been compiling statistics since 1990, and produces an annual Bulk Carrier Casualty Report that lists the losses each year and analyses the previous 10-year period. The trends indicate that the number of ships, lives and amount of deadweight tonnage lost continues to fall, while the average age of the bulk carriers that sink is rising.

Port State Control

The international conventions like SOLAS, STCW and MARPOL form the framework of the safety, security, training and pollution prevention regulations with which ships should comply. The primary task of enforcing compliance and the issuing of certificates falls on the flag State. Under control provisions that date back to the 1929 SOLAS convention, port States also have certain rights to exercise authority over foreign ships that enter its ports. Checking that a ship complies with convention standards, is one of those rights. A ship found to have deficiencies and considered unsafe to proceed to sea is likely to be detained.
Port State control (PSC) activity has developed along regional lines. In 1982 the Paris Memorandum of Understanding on Port State Control, now simply referred to as the Paris MOU, was signed between north European States, Canada and the Russian Federation. Agreements in South America and Asia quickly followed. The United States, however, chose to remain outside of any regional grouping and operate its own programme.
Intercargo actively supports the PSC inspection regime as an effective method of eliminating substandard shipping. It has written a guide for ships involved in the dry bulk trades and it encourages members and non-members alike to complete an Inspection Reporting Form to comment on inspection experiences that have caused concern. That guide has also been reproduced and published jointly with the North of England P&I Association and it features in its series of loss prevention guides. One other aspect which now falls under the remit of the PSC regime is security with Inspectors charged with ensuring that vessels are compliant with the International Ship and Port Facility Security Code (ISPS). Intercargo monitors PSC data and encourages members to lodge appeals to the small minority of inspections / detentions which are deemed grossly unfair.
Intercargo continues to monitor the detentions of bulk carriers reported by the Paris and Tokyo MOU's and the US Coast Guard. Preliminary evidence shows that the ships entered with Intercargo accounted for around 8% of these detentions.
Intercargo releases to the EQUASIS database, the names of the ships it has entered for membership. Checking this publicly accessible database enables interested parties to see the PSC deficiency and detention record of all internationally trading ships, and not just those entered with Intercargo.

Mississippi Towage

Intercargo has devoted a considerable amount of time attempting to galvanise support against what it perceives as erosion of free market principles on the Mississippi River. Intercargo believes that the differential charges levied between the tug company and the Marine Terminal Operator (MTO), and the MTO and the ship operator, raise costs and limit the right of shipowners to select a tug company of its choice.
The US Federal Maritime Commission (FMC) and its Bureau of Enforcement are currently investigating this practice under the overview of a US Administrative Law Judge. A decision from the FMC is expected during 2005.

The safety of terminal loading and discharging operations

The loading and unloading of bulk cargo at terminals has important implications in terms of ship safety. In 1997, the IMO developed the BLU Code - the Code of Practice for the Safe Loading and Unloading of Bulk Carriers - to promote and encourage the use of good practice at the ship-shore interface.
Intercargo is also in regular dialogue with the Dry Bulk Terminals Contact Group (DBTG) recognising that terminal and bulk carrier operators are strongly interdependent and share many areas of mutual concern. The DBTG, established to represent the interests of terminal operators around the world, has Observer status at the IMO under the name International Bulk Terminals Association (IBTA). Intercargo is participating in a consultation exercise on a proposed Manual for Dry Bulk Terminal Representatives.
Intercargo has issued a Bulk Carrier Terminal Reporting Form and encourages its members to use the form to report their experiences, good and bad, at terminals.

Flag issues

A primary responsibility of a flag State is the enforcement of convention standards on the ships that it has registered. In choosing a flag shipowners, as well considering such factors as administrative and diplomatic support, port and cargo preference schemes and fiscal matters, need also to consider the port State control record of the flag in question. Port States typically use 'flag' as a factor for targeting ships for inspection and MOU's maintain ship detention records and publish 'black lists' of the worst performing flags based upon three-year rolling average statistics.
Intercargo's bulk carrier database lists the most frequently used flags as Panama (29%), Malta and Cyprus (9%), Liberia (8%) and China and Greece (6%). The flags most frequently used by Intercargo members are Panama (31%), Liberia (11%), Hong Kong (9%), China (7%) and Greece (6%).

Environmental protesters

Intercargo is publicly committed, through its Direction paper, to recognising public concern over environmental issues, and welcomes informed and open debate as a means of initiating progress.
What is seldom appreciated is the fact that responsible shipowners share such concerns. Through the work of the IMO and other similar bodies, a great deal of progress in balancing the need for environmental change with a rising demand for seaborne trade. It is unfortunate when the shipping industry often finds itself in the middle of 'activists' demonstrations that place the lives of seafarers and demonstrators alike in jeopardy and raise serious questions about security and safety. There have been over 40 separate protests since 2000, involving dry cargo ships carrying lawful, albeit deemed environmentally sensitive cargoes such as rain forest timber and GM grain products. Intercargo calls on those responsible for organising demonstrations to demonstrate if they must, but to agree that the illegal boarding of ships, the causing of criminal damage and the chaining to anchor chains and the like, will eventually lead to loss of life and/or a serious maritime casualty.
Another campaign area is linked to shipbreaking, or as it now referred to, ship recycling. A recent action saw Greenpeace attempt to get the highest court in The Netherlands to classify a ship as toxic waste, presumably with a view to preventing its movement from The Netherlands to a State that scraps ships. There is a concern that the case may set a precedent for the future recycling of ships. All owners contemplating the recycling of their ships are urged to consult the Industry Code of Practice on Ship Recycling, guidelines published in 2001 by the industry Associations and endorsed by Intercargo.

Education and training

Intercargo would like to take the opportunity to draw your attention to the following website:
Please note that INTERCARGO is unable to offer any training or employment opportunities unless advertised.

Security and the dry bulk industry

The issue of maritime security has received a considerable amount of coverage since the terrorist attacks in the United States in September 2001. At the IMO, the matter has been extensively debated. In December 2002, it adopted a series of detailed maritime security provisions for both port facilities and ships over 500 GT which entered into force on 1 July 2004. The regulations are contained in a new SOLAS chapter XI-2 and are backed-up by the International Ship and Port Facility (ISPS) Code. This Code has been written in two parts: a mandatory Part A and recommendatory guidance notes in Part B. Under this new international security regime, ships will be required to undertake a security assessment and develop a security plan. A Company and a Ship Security Officer will need to be appointed, and ships will have to fit a Ship Security Alert System and carry a Continuous Synopsis Record to list all its ownership, flag and classification details.
Intercargo members may access the member's area of the Intercargo website for more information on such issues.

INTERCARGO has developed this form for ships to report their experiences of port State control inspections where the performance / practice of the Port State Control Officer (PSCO) has caused concern to the ship. Confidentiality is assured, unless INTERCARGO is requested to investigate. (Privacy Statement)
Please fill the form below ensuring that all the items marked in red are completed, and submit by pressing the "Submit" button at the end. Alternatively, print off the form and fax back to INTERCARGO on +44 (0)20 7977 7031 or post to the address at the bottom of the form
1. General Details (as recorded on "Report Form A" by the PSCO)
Reporting authority of
1
Name of ship:
2
Place of inspection
11
IMO number
6
Date of final report
10
Gross tonnage
7
2. Inspection Practice / Performance
Interval between inspections:
Less than six months since last "clean" inspection (no recorded deficiencies)
Timing of the inspection during scheduled port stay:
Did the PSCO attend the ship at an unreasonable / unnecessarily inconvenient time?
i.e. within hours of the ship's scheduled departure time
Charging policy imposed:

·  Excessive level of charge

·  Unfair application of charges
Unreasonable attitude of the PSCO:

·  The PSCO proceeded with a "more detailed inspection" despite the lack of clear grounds
·  The PSCO required corrective actions not called for by class or convention regulation
·  The PSCO imposed undue demands on the routine operation of the ship
·  The actions of the PSCO unnecessarily delayed the ship
Identification of deficiencies:

·  The PSCO showed poor professional judgement
·  The PSCO exaggerated the severity of the deficiencies
·  The nature of the deficiencies identified and the corrective actions needed to clear the deficiencies were not clearly explained
Detention order:

·  The opportunity to consult owner, class or flag State was not provided
·  The detention was unfair / unreasonable
·  The PSCO gave no information on the right to appeal his decision
3. Reasons
Please give experiences not listed, or expand on any of the points raised above
Master:
Company:
INTERNATIONAL ASSOCIATION OF DRY CARGO SHIPOWNERS
9th Floor, St Clare House, 30-33 Minories, London EC3N 1DD
Telephone : +44 20 7977-7030, Fax : +44 20 7977-7031






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