CONTENTS

1 Introduction
1.1 Training other crew members
1.2 Port states and their organisation

2 The rules and regulations

2.1 IMO Conventions
2.2 ILO Conventions – MLC 2006
2.3 National laws
2.4 PSCO Guidelines

3 Ship selection
3.1 Inspection criteria
3.2 Expanded inspections

4 An initial inspection
4.1 Preparation
4.2 First impressions
4.3 Certificates and documents.
4.4 The walk-round
4.5 The report

5 More detailed inspections

5.1 Clear grounds
5.2 Overriding factors

6 Detention and banning

6.1 Detention
6.2 Banning

7 Frequently asked questions

8 Further resources

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 1. INTRODUCTION

The Port State control regimes around the world are a key component in helping to
maintain safety at sea, minimise the risks of pollution, and ensure that all ships
compete for business on equal terms. Knowing what will happen during a port State
control inspection and how to make sure your ship passes it is an essential skill on a
well-managed ship.

In the video you will see two real-life initial inspections, and this Reference provides
further background details, brief reference material, short case studies, and pointers
to more information. You will need to use both in order to obtain a good overview
and an understanding of the main principles of port State control.

You can use the package with other crew members to explain why ships are
inspected, what sort of questions they might be asked, and to spot problems which
should be brought to an officer's attention. With everyone properly informed, you will
be better prepared for your next inspection.

1.1. Training other crew members

If you are responsible for training others, then you should aim to follow the
instructions in this section as closely as possible. It will help you to learn how to run
effective training sessions with the crew.

Preparation
Think about the group
How familiar are your trainees with Port State control? What do they need to
know? What kind of questions might they ask you? What do you want this
session to achieve?

Watch the video

It's important to familiarise yourself with the video in advance, so that you can
anticipate possible questions from the group and research your answers.

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 Read this Reference
This Reference contains the key points made in the video and expands on them
where appropriate.

Tips for running an effective training session

Begin with an overview
Tell the group what the objectives of the session are, what you're going to cover,
what they will know by the end of the session, and how long it will take.

Ask questions throughout

It's a good idea to ask your trainees questions from the start, and to encourage
them to take an active part in the session. You can use the questions and
discussion points in this Reference to test understanding and relate the learning
to the equipment on board their ship.

Start discussions
Encouraging discussions in a small group will help each individual to make a
contribution to the session. But remember that some people are reluctant to
speak up.

Sum up what the session has achieved

At the end, briefly bring together everything you've covered. Make sure that
you've asked for any other questions and answered them. Ask the group what
they found most useful about the session.

Afterwards
When the session is over, spend a few minutes thinking about how it went, and
how you might want to change it next time.

1.2. Port states and their organisation

Port states generally work together in regional groupings to try and ensure that
the rules and the procedures are harmonized and enforced in a consistent
manner. The regulatory net is widening as more countries agree to take part and
implement the procedures using a Memorandum of Understanding (MoU) which
ensures that port State control inspections are conducted effectively and in
accordance with established IMO and ILO Conventions

The first memorandum of understanding on port State control was signed in Paris
in 1982 by 14 European states, and the Paris MoU was formed. At present there
are nine MoUs around the world.

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 MoU contact details
MoU Contact
Paris www.parismou.org
Acuerdo de Vina del Mar www.acuerdolatino.int.ar
Tokyo www.tokyo-mou.org
Caribbean www.caribbeanmou.org
Mediterranean www.medmou.org
Indian Ocean www.iomou.org
West & Central African / Abuja www.abujamou.org
Black Sea www.bsmou.org
Riyadh www.riyadhmou.org

US Coast Guard
The US Coast Guard conducts its own port State control. Details are at the
Homeport website of the US Department of Homeland Security, which gives
details of how ships are selected for inspection. It includes the USCG Safety
Targeting Matrix, and information about which flags are most likely to be
inspected. The direct link to the USCG's port State control information is:

http://homeport.uscg.miI/mycg/portal/ep/browse.do?channel ld=-18371

2. THE RULES AND REGULATIONS

The origins of port State control can be traced back to the SOLAS Convention of
1929. Today the International Maritime Organization, the IMO, deals with safety
at sea and the training of seafarers, while its sister organisation the International
Labour Organisation, the ILO, deals with working and living conditions at sea.
The IMO and the ILO are both part of the United Nations.

2.1. IMO Conventions

The rules on port State control are based on SOLAS Chapter I Regulation 19,
and IMO resolution A.787(19) 'Procedures for port State control.' The resolution
was adopted in 1995 and amended in 1999 by resolution A.882(21). Further
amendments are expected. Go to www.imo.org if you need more details.

The IMO procedures give basic guidance on how inspections should be done,
and how inspectors should look for 'deficiencies', or faults, in a ship, in its
equipment, and its crew. As an international organisation, the IMO wants the
procedures, as far as possible, to be the same in every port in the world.
However, the procedures are only guidelines, and they are used in different ways
in different ports. Each member State of the IMO is responsible for enforcing the
international conventions on the ships which fly its flag.

The key IMO Conventions, Codes and relevant protocols include SOLAS,
MARPOL, STCW, Tonnage Measurement, Load Line, Colregs, Bunker and Anti-
fouling. If an IMO member State ratifies a Convention, it means that the content
of the Convention has been integrated within the National legislation of that
member State and becomes mandator

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 Documents to be provided
The list of documents which port State authorities can ask for is reviewed frequently.
Check the latest news from the IMO's Facilitation Committee, FAL, at:

http://www.imo.org/OurWork/Facilitation/FALCommittee/Pages/default.aspx

Supporting these are Classification rules which govern the structure of the ship, the
materials used, and the engineering systems. For more details, see the website of
the International Association of Classification Societies. www.iacs.org.uk

A port State can only apply Conventions which it has implemented for its own ships.
So port State control in Rotterdam can only apply regulations which are in force in
The Netherlands. However, all ships which enter the port of Rotterdam would have
Dutch regulations applied to them, regardless of which flag they flew.

As well as port States, coastal States have the right to enforce some regulations on
ships in their waters.

2.2. ILO Conventions

Previously, the ILO had many different Conventions that related to the working
conditions of seafarers, 130, 138, 147 etc., but in 2006 the principles and
requirements of these were all combined into a new Maritime Labour Convention,
known as MLC 2006. This came into force on 20 August 2013 and its compliance is
subject to enforcement by Port State Control Officers. Not all countries had ratified
the Convention at the time it came into force. However, it is important to note that the
previous ILO Conventions still apply until the State has ratified the Convention, so
working and living conditions, for example, could still be checked under ILO 147.
Now there may be more focus on the galley and accommodation areas, with checks
being made on hygiene, galley cleaning and food safety procedures, conditions in
freezer rooms and storage areas, as well confirming that the food provided is
"adequate, varied and nutritious", as the MLC 2006 Convention requires.

In addition, port states that have ratified the Convention can inspect visiting ships
under MLC 2006 from states that have not ratified, under the principle of no more
favourable treatment which prevents states from trying to avoid compliance with
international regulation.

The MLC 2006 does bring certain new areas within the scope of Port State Control,
particularly those covered by Title 2 - Conditions of Employment. In a more detailed
inspection this may include examination of the Seafarer's Employment Agreement,
SEA, checking the leave entitlement, and examining the records of hours of work
and rest. There should also be an effective complaints procedure on board and the
PSCO may want to check that this is working to the satisfaction of the seafarers.
Masters should note that under this new regime, PSCOs may want to talk to ratings
and junior officers about their employment without a senior officer being present.

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 2.3. National laws

National laws and regulations apply first, above all the international conventions and
regulations

So when a PSCO is making an inspection in Japan, they first apply Japanese law,
before they apply any other regulations. And when a PSCO is inspecting a ship in
Australia, the first thing they apply is Australian law. National law comes first.

An example of this is the United States Oil Pollution Act 1990 (OPA 90), which
applies to foreign ships in US ports, and which must be complied with, before any
international regulations are considered. Compliance with VGP (Vessel General
Permit) requirements will also be checked.

2.4. PSCO Guidelines

All inspectors must follow a Code of Good Practice. An inspector will maintain the
highest standards of professionalism and integrity. Their decisions will be open and
transparent. They will act within the law, within the rules of their Government, and be
fair, impartial, and consistent.
• Professionalism means they will apply acceptable professional standards of
conduct and technical knowledge. Inspectors should update their knowledge
regularly.
• Integrity means they are honest and free from corrupting influences and
motives.
• Transparency means they are open and accountable for their actions.

In their actions and behaviour, PSCOs should not be prejudiced by the race, gender,
religion or nationality of the crew when making decisions. They should respect and
take account of cultural differences.

During inspections they will comply with all health and safety requirements including
wearing personal protective clothing.

The PSCO will apply the procedures and requirements consistently, and in a
practical way rather than strictly to the letter. If a disagreement cannot be settled, the
PSCO will inform the Master that there are several complaint procedures in place

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 3. SHIP SELECTION

It is not practical to inspect every ship, every time it enters port. So port State
control authorities aim to inspect a percentage of the ships that enter their port in
any given period. The percentage will vary from one MoU to another. Several
MoUs and the US Coast guard select ships based on a risk analysis. The higher
the risk profile of a ship, as detailed below, the more frequently it will be selected
for inspection.

Authorities may also run a Concentrated Inspection Campaign, CIC, for a set
period of time, when they concentrate on a particular theme. They might decide
to inspect every ship's living and working conditions, or every ship's oil record
books. Campaigns will last for a set number of weeks or months.

3.1. Inspection criteria

Some Port State authorities use points systems to decide which ships to select
for an initial inspection. The more points a ship scores, the more likely it is to be
given an initial inspection.

Points are given for a range of factors which experience has shown are very
good indicators of how well a ship is operated, and of its condition.

Flag
Ships of certain flags are given points against them because those countries
have a worse record than average, or that country has not signed the main
international conventions. For a list of which flag states are affected, go to
www.parismou.org

Classification society
Ships are given points if they are classed with a Recognised Organisation that
has a worse than average record, or one that is not a member of the
International Association of Classification Societies, the IACS. See
www.iacs.org for a list of societies.

History
Ships are given points if they are visiting a region for the first time, or have a
deficiency/detention history which is worse than average.

Type
Generally, more points are given to oil tankers, gas carriers, chemical tankers,
bulk carriers, and passenger ships.

Age
Ships more than 10 years old may be given points, depending on their type.

Company
Some MoUs are now taking into account the record of the company with regard
to detentions and deficiencies.

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 Different MoUs use slightly different scoring systems. For full information, see the
website of the MoU you are interested in. There is a list of links in Section 1. If the
total number of points scored by the ship is high enough, port State control will
make an initial inspection

Within the Paris MoU, the risk profile of the ship gives rise to two priorities for
inspection:
PRIORITY 1: must be inspected because either the time window has closed
or there is an overriding factor
PRIORITY 2: may be inspected because they are within the time window or
the port State considers an unexpected factor warrants an inspection.

Information about ships is gathered by MoUs from regional and international

industry databases, like the public database Equasis, at www.equasis.org , and
also from port arrival listings, shipping schedules, and ship position reports.

If a ship has a poor inspection history, it may be given a more detailed

inspection.

3.2. Expanded inspections

Under the Paris MoU, ships with high risk factors such as bulk carriers,
passenger ships, oil tankers and gas and chemical carriers over 12 years of age
will be subjected to an expanded inspection. Their reporting obligations mean
that the ship is obliged to inform the next port in advance if it believes that it is
due for a mandatory expanded inspection. The Paris MoU website lists the types
of ship for which this is required and details of the reporting obligations. You can
also check with the local agent. Expanded inspections can take six to eight hours
and the PSCOs will have a mandatory list of items to check according to the ship
type. These may include witnessing a drill.

Other MoUs may also undertake expanded inspections and you should check
their websites for more information about the criteria they use.

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 4. AN INITIAL INSPECTION

4.1. Preparation
As soon as a ship is scheduled to arrive, port State control consult their
information systems and assess it for an initial inspection using the risk factors
and criteria defined in Section 3.1. In the EU, this procedure automatically lists
the ships to inspect.

The PSCO will prepare for the inspection by consulting several databases.
The age, type, flag, Class, Company, inspection history, outstanding
deficiencies etc., are studied. Port security levels and terminal restrictions are
taken into account and PPE is checked.

If the ship is put on the selection list, the PSCO will arrive at the ship without
warning.

The initial inspection is in four main sections:

• First impressions
• Certificates and documents
• A walk-round
• The report and discussion

The overall aim is to make sure the ship is operated to international

standards. For an overview of which standards are applied, see Section 2.

4.2. First impressions

When the PSCO arrives, they will look at the external condition of the hull,
freeboard marks, accommodation ladder, and mooring arrangements.

The PSCO will also want to see that there is a gangway watch, and an
accurate record of visitors. As the PSCO is escorted to see the Master, they
will already be looking at the state of the ship, and any cargo operations.
They will notice whether accommodation is clean and well maintained,
whether corridors are cluttered, and whether light bulbs are working.

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 First impressions are of vital importance to PSCOs in any inspection.

4.3. Certificates and documents:

The PSCO will do a certificate check, usually in the Master's cabin or

dayroom. The PSCO will look for missing or expired certificates or
documents, and ones which are not translated or posted up as required.

Documents which are undated, unsigned, or uncertified by recognised

organisations or the Flag State, will be a cause for concern. So will record
books which show gaps, or that are inconsistent.

The PSCO will check that manning levels comply with the regulations, and
that minimum rest periods are applied.

The PSCO will check that crew members are familiar with the Company
'Safety and Environmental Protection Policy', and that the 'Safety
Management System' documentation is readily available. The PSCO will look
at the status of interim certificates, and that the ship type is covered in the
Document of Compliance (DOC). They may want to check the records of
drills. Under MLC 2006 they may want to see the certificates for the ship's
cook and the catering staff.

Problems with a ship's certificates and documents are very often the first sign
of problems with the ship itself. The PSCO may take at least an hour to check
all of the paperwork.

In terms of pollution prevention, the Oil Record Book and, for tankers, the
ORB part II will be inspected. For chemical tankers it will be the cargo record
book and any shore discharge receipts for slops. The Garbage Record Book
is another key document that must be carefully maintained and crew
members with garbage duties may be asked about their tasks. The records of
garbage discharged ashore must be available and match the details in the
record book.

4.4. The walk-round:

Next the PSCO will walk round the ship. It is vital that they are accompanied
by one or more officers when they do this. The inspection will normally
include the deck, bridge, engine room and crew accommodation. Depending
on the PSCO's background, they may start the walk-round in different places.
For example, a PSCO who is an ex- engineering officer might want to start in
the engine room.

Sometimes the inspection will be done by more than one PSCO. One PSCO
might examine the deck and another examine the engine room.

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 The PSCO needs to check the general condition of each area of the ship:

Exposed decks
• deck plating, bulwark and stays, guard rail, hatch coamings and covers,
piping and vents
• improper temporary repairs, recent welding / hot work, or liquid seepages

Cargo handling gear

• including additional equipment and securing devices

Navigation and radio-communication equipment

• navigational and radio equipment, reserve radio batteries, fire detection
and alarm systems
• record of operation and maintenance
• record of emergency steering gear tests and drills
• detailed berth to berth voyage planning
• management of voyage charts and publications
• hand-over procedures for watch and control of ship
• bridge visibility

Lifesaving appliances
• lifeboats, rescue boats and life-rafts
• launching arrangements
• personal lifesaving appliances
• record of periodic inspections, testing and drills
• management of emergency plans and instructions
• consistency of mustering practice with the plan
• service and inspection of all appliances and pyrotechnics

Fire fighting arrangements

• fire doors and means of escape
• fire pumps, fire main, hydrants and hoses, fire extinguishers
• record of periodic inspections, testing and drills
• management of fire control plan and instructions

Machinery spaces
• main and auxiliary engines
• piping, pumps and valves
• electrical generators
• cables, terminations and joint arrangements
• lighting
• cleanliness
• emergency escape routes

Pollution prevention arrangements

• oily-water separator
• ODME on tankers
• Shipboard Oil Pollution Emergency Plan (SOPEP)
• SMPEP and other Vessel Response Plans
• garbage arrangements

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 Living and working conditions
• records of rest and working hours
• availability of personal protective equipment
• record of accommodation inspections
• condition and quantity of food and drinking water
• arrangement and cleanliness of food stores, galley, pantries,
refrigeration, and mess rooms
• sanitary arrangements, including doors, flooring and drainage
• ventilation, lighting, heating and water supply
• medical facilities, equipment, and medicines

When they inspect any of these areas, the PSCO must also follow the Guidelines
for Inspectors.

4.5. The report

If the PSCO is satisfied they will issue a Form "A" Report, and the inspection is
finished.

If deficiencies are found, the inspector will issue a Form "A" report and a Form
"B" report showing the deficiencies, and the time allowed to correct them.

If the deficiencies relate to the MLC, then the ship must also produce a
Rectification Action Plan (RAP) which must be approved and signed by the
PSCO with a time period defined for the action the be completed.

The inspection report goes to the Master and the port State only. Since the
Master represents the owner they must copy the report to the onshore ISM
operator. The reports are also put into online databases which can be searched
by ship's name and IMO number. Summaries of reports are available to the
public.

Sometimes ships which are extremely sub-standard are highlighted in documents

publicly available on MoU websites.

Inspection reports must be kept on board the ship for two years.

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 5. MORE DETAILED INSPECTIONS

5.1. Clear grounds

In certain circumstances, ships may be subject to more detailed inspections. This
may occur because, during the initial inspection, the PSCO has found "clear
grounds" that justify a more detailed inspection.

What are "clear grounds"?

"Clear grounds" arise when either:
■ the ship, its equipment, or its crew do not appear to correspond substantially
with the requirements of the relevant Conventions
or:
■ the Master or crew members are not familiar with the essential shipboard
operational procedures that relate to the safety of the ship or pollution
prevention

The PSCO may find "clear grounds" for a more detailed inspection when he is looking
at the certificates and documents, or he may find evidence of "clear grounds" during
his walk-round. In either case the definition is the same.

If there are deficiencies, this may be "clear grounds" for the PSCO to conduct a more
detailed inspection, and the PSCO will inform the ship's Master.

If there are "clear grounds" for a more detailed inspection, the inspector must tell
the Master immediately. The Master can contact the Administration, or if it is
appropriate, the organisation responsible for issuing the certificate, and can invite
them on board.

The inspector will then do a more detailed inspection to see if there are other
possible deficiencies.

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 Some examples of "clear grounds"
Inaccurate certificates and documents, including evidence that the oil record book has
not been properly kept, or evidence that the logbooks and manuals are falsely kept, or
not kept properly.

Crew members not able to communicate adequately with each other.

Shipboard operations such as cargo work not being conducted safely and according
to IMO guidelines.

Lack of muster list, fire control plan, or damage control plan, or crew members not
aware of their fire fighting and abandon ship duties.

Unsatisfactory life-saving appliances.

Lack of proper maintenance.

Excessively unsanitary conditions.

Serious hull or structural deterioration that risks the structural, watertight, or weather
tight integrity of the ship.

If no deficiencies are found, the inspector will issue a Form "A" report, and the
inspection is finished.

If deficiencies are found, the inspector will issue a Form "A" report and a Form "B"
report showing the deficiencies, and the time allowed to correct them. All inspection
reports are put into an online database.

5.2. Overriding Factors

In some cases, ships are given a more detailed inspection instead of an initial
inspection. These may be required due to overriding factors. These are:

Complaints:
A complaint made by a pilot, a port authority, or another State, or a complaint by a
crew member, or by anyone with a legitimate but external interest in the ship.

Outstanding deficiencies:
Ships which have outstanding deficiencies and a record of detentions, or ships which
have been allowed to proceed to another port to work on deficiencies but which do
not arrive on time, usually within 14 days.

Operational concerns:
Incidents which could lead to a more detailed inspection include:
• Collision, grounding or stranding on the way to the port.
• Alleged pollution
• Erratic or unsafe manoeuvring or unsafe navigation
• Not complying with reporting procedures

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 Suspended from recognised organisation (RO):
Ships which have been suspended or withdrawn from their RO for safety reasons in
the last six months.

Whether the more detailed inspection was due to 'clear grounds' or to overriding
factors, the reporting procedure is the same. If no deficiencies are found, the
inspector will issue a Form "A" report, and the inspection is finished.

If deficiencies are found, the inspector will issue a Form "A" report and a Form "B"
report showing the deficiencies, and the time allowed to correct them.

A more detailed inspection may well involve two PSCOs and may take 6-8 hours.

Some MoUs also run Concentrated Inspection Campaigns (CIC). These run for a
specified period of time, during which the authority checks on special matters, or
areas of particular concern. For example, an authority might decide to make special
checks on an area where high levels of deficiencies have been found, or they might
decide to check on areas covered by a new Convention

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 6. DETENTION AND BANNING

6.1. Detention

If, as a result of the inspection, the PSCO has serious concerns about the ship,
they have the power to detain it. This sanction is only applied when the PSCO
finds deficiencies that:
• pose an unreasonable risk to the environment
• make the ship unfit to go to sea
• indicate serious failings in the employment or working conditions on
board
• indicate a failure in the safety management system under the ISM Code

The PSCO must decide whether the ship should be detained until the
deficiencies are put right, or whether it could be allowed to sail, and put right the
deficiencies within a certain number of days, maximum 14, or at the next port.

If the PSCO considers that the ship should be detained, they must inform the
Master that there is a right to an appeal, or, for some MoUs, a review.

The PSCO must make all possible efforts to avoid detaining a ship without proper
reasons. The main purpose of port State control is to prevent a ship going to sea
if it is unsafe, or if it presents an unreasonable threat to the crew, and/or harm to
the marine environment.

PSCOs use their professional judgement to decide if the ship can sail even
though it has certain deficiencies, depending on the type of voyage it is going to
make. For example, the PSCO should recognise that equipment can fail, that
replacement parts are not always available, and that safe alternative
arrangements may have been made.

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 If the grounds for detention are due to accidental damage during the ship's
voyage to the port, a detention order should not be issued, provided:
• the flag state has been notified
• the port State authority has been told the details beforehand
• action is being taken to repair any damage
• deficiencies clearly hazardous to safety, health, or the environment have
been dealt with.

So a ship which has been damaged simply because of heavy weather can still
be detained, for example, if it has deficiencies which are clearly hazardous to
safety. The PSCO might ask the owner's representatives to make proposals to
correct the situation. The PSCO might also ask the flag state to get involved, as
well as the recognised organisation (R/O) which has issued the relevant
certificates.

If deficiencies cannot be put right at the port of inspection, the PSCO may let the
ship sail to another port, but on condition that the flag state and the next port of
call are told of the results of the inspection.

A Classification society surveyor may be asked to come to the ship and put
deficiencies right in a way which is acceptable to the PSCO.

6.2. Banning

Some MoUs and the US Coast Guard also have the power to ban ships from
their region.

In the Paris MoU region, a banning order can be made to refuse access to ships
visiting the region. It can be applied to:
• All ship types flying a Paris MoU grey listed flag.
• All ship types flying a Paris MoU black listed flag.

Your ship will be banned from entering any of the ports in the Paris MoU region if:
• You jump detention.
• You fail to call at an indicated repair yard.
• You experience multiple detentions

Any such ban relates to the vessel and will remain in place even if there is a
change of owner or manager.

Multiple detentions are when:

• The ship is detained, or issued with a prevention of operation order
[PoO], more than twice in the preceding 36 months, and your flag State
is on the Paris MoU blacklist.
• The ship is detained, or issued with a prevention of operation order
[PoO], more than twice in the preceding 24 months, and your flag State
is on the Paris MoU grey list.

For more details of the Paris MoU regulations, go to www.parismou.org

The US Coast Guard also bans sub-standard foreign vessels. A foreign vessel
that has been detained three times within the previous twelve months will be

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 subject to an International Safety Management [ISM] Code expanded
examination, if it is determined that failure to effectively implement the vessel's
Safety Management System [SMS], is a contributing factor for the sub-standard
conditions that led to the detentions.

If the vessel fails its expanded examination following three detentions within the
previous twelve months, a Letter of Denial will be sent to the vessel's owner and
company informing them that the vessel will be denied entry into any port or
place in the United States unless specific actions are completed to the
satisfaction of the US Coast Guard. The vessel's flag administration and
appropriate Memorandum of Understanding [MoU] secretariats will be notified of
this action.

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 7. FREQUENTLY ASKED QUESTIONS

What if it's not convenient to have an inspection at that time?

A PSCO may defer an inspection if another inspection is already
going on, for example by a Recognised Organisation. The crew may
then be too occupied for a PSC inspection to take place at that time.

How do I know which regulations apply, and which laws take precedence?
A good Master should have been informed by their company which
regulations apply, but be sure to refresh your knowledge of the
latest regulations before you arrive.

What if I don't agree with the inspector's decision?

If you have a genuine complaint, there are appeal and review
procedures in place, but it might be best for your Recognised
Organisation, flag State, owners, or company to handle this.

What if I argue with the inspector?

Discussions are good because they may clarify the issue. If the
discussion stops being constructive, it may be best to let your
owners or company handle it.

Who explains what's going on to the ship's owner?

It is up to the Master to explain the inspection results to the owners,
and/or the operator.

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 8. FURTHER RESOURCES

Videotel training programmes

MLC Training Course Code No
878 MLC 2006 Code No 986
US Port State Control (Edition 2) Code No 1171

© Videotel 2020