PRACTICES FOR PSC DETENTION PREVENTION

CRS Fleet monitoring and preparation of the ship for the PSC inspection

CRS Fleet monitoring

Croatian Register of Shipping (CRS) aims to improve the safety record of their fleet and to provide added value to the owners and companies in terms of regulatory compliance and performance. It is a fact that even good ships, manned by well qualified crew can be and are sometimes detained for deficiencies that can easily be prevented. CRS has a plan of action to rectify the problems and closely monitor the ships. Namely,  ships which fall under requirements for Fleet Monitoring measures are continuously tracked and monitored by CRS. 

The measures used, serve as a tool for upgrading the ship and its crew with regards to maritime safety, security, and environmental protection and with regards to preparation for the future PSC inspections.

The criteria for identifying ships to be monitored and the measures imposed as additional surveys/audits are contained in CRS procedure SURVEYS OF DETAINED SHIPS AND SHIPS UNDER THE SPECIAL MONITORING REGIME. Such ships are under a special monitoring regime in the duration of three years from the moment of entering the status.

 

The criteria (reactive and proactive) for identifying ships for monitoring are given in the following definition:

Ship under the special monitoring regime is a ship:

a) detained more than once by PSC in past 3-year period, and consequently placed on BLACK LIST;

b) detained once by PSC in past 3-year period, and consequently placed on GREY LIST;

c) that has a High Risk Profile as defined in Article 10 of the Directive 2009/16/EC;

d) that in past 3 year period had Class withdrawn on account of overdue surveys/conditions of class (the same may be applied to the ship with Class suspended in past 3 year period, upon the Fleet Services Division team consideration),

e) that has more than 5 COC and/or STA recommendations per year (during a three-year period) in the ship survey status,

f) that has a (IACS PR17) report of deficiencies possibly affecting the implementation of the ISM Code, exclusively when the reported deficiencies are found related to SMS failures according to Cr review, or

g) which in the past three years has significantly (for more than three times) exceeded the percentage of the number of deficiencies per ship, in the Company with at least three ships.

Which monitoring measures are to be imposed on certain ship are based on the following criteria: the reason why ship entered the monitoring regime, ship Flag Administration and the nature of ship certificates issued by the CRS.

 

For ships being detained by the PSC, following measures are implemented:

1. In the case of a ship with the flag of the Rep. of Croatia having SMC certificate issued by the CRS - “The ship is under the special monitoring regime due to previous PSC records (date and place of detention). Additional ISM audit shall be carried out each year during annual surveys until (enter the date that is 3 years from the date of last detention) on condition that no new PSC detentions occur.”

2. In the case of a ship with the flag other than the Rep. of Croatia having SMC certificate issued by the CRS - “The ship is under the special monitoring regime due to previous PSC records (date and place of detention). Additional measures shall be enforced according to requirements/instructions.”

3. In the case of a ship which doesn’t have SMC certificate issued by the CRS - “The ship is under the special monitoring regime due to previous PSC records. Renewal and Intermediate surveys shall be carried out by at least two surveyors2 until (enter the date that is 3 years from the date of last detention). Particular attention shall be paid to items covering structural safety, bilge pumping arrangements, load lines and fire safety measures. Any possible safety management system failure is to be reported on QF-PRP-67 (according to IACS PR 17)”

 

For ships having entered monitoring due to other reasons:

4. for the ship that has a High Risk Profile as defined in Article 10 of the Directive 2009/16/EC, the ship survey status will be updated with the following MEM “The ship is under the special monitoring regime due to calculated High Risk Profile. Renewal and Intermediate surveys shall be carried out by at least two surveyors* until (enter the date that is 3 years from the date of the MEM imposed) or until the ship has ceased to be High Risk Profile ship;

5. for the ship that has entered the special monitoring regime due to reasons given/set in d) or in e), the ship survey status will be updated with the following MEM “The ship is under the special monitoring regime due to (enter the applicable reason). Renewal and Intermediate surveys shall be carried out by at least two surveyors3 until (enter the date that is 3 years from the date of the MEM imposed) or until the ship has ceased to be subject to the special monitoring regime”.

6. for the ship that has entered the special monitoring regime due to reasons given/set in f) or in g), the ship survey status will be updated with the following MEM “The ship is under the special monitoring regime due to (enter the applicable reason). During periodical surveys, particular attention shall be paid to possible safety management system failures (enter the date that is 3 years from the date of the MEM imposed) or until the ship has ceased to be subject to the special monitoring regime”.

* In extraordinary cases, upon the approval of D, Fr (or Kr, in case K is responsible for the ship), may decide to appoint only one surveyor for the particular survey.

 

WHY CAN CRS BE TRUSTED IN THIS REGARD?

•              CRS has 70-year experience in the classification and certification of ships (ships) and a long-term experience in the certification of the IMO/ILO standards as well as safety management systems in the marine economy.

•              CRS is one of the 12 IACS Members and actively participates in all IACS panels.

•              CRS is an RO for most of the mayor flag administrations and for many more.

•              CRS performs inspection / certification activities engaging our own exclusive SURVEYORS/auditors in Croatia and other dislocated organizational units - branch offices in Shanghai, Turkey, Dubai and Costanza.

•              CRS has no RO related detentions on our fleet, in Paris MoU, USCG and Tokyo MoU, for more than past three years.

 

Preparation of the ship for the PSC inspection

With regards to preparation of your ship for the PSC inspection, it is recommended to use your own company check lists, as well as instructions / check lists prepared by the Flag State administrations, such as:

-              Panama Maritime Authority Pre Arrival Check-List to prepare ships for PSC inspection: https://panamashipregistry.com/wp-content/uploads/2021/05/MMC-381-Check-list-26-05-2021-.pdf

-              Saint Vincent and the Grenadines Maritime Administration Pre Arrival Check-List from CIRCULAR N° PSC 032 - Rev.1: http://www.svg-marad.com/Downloads/Circulars/Port%20State%20Control/PSC%20032%20Actions%20to%20be%20taken%20on%20ships%20in%20view%20of%20PSC%20Inspections%20-%20Rev.%201.pdf

-              RMI Critical Items Checklist for ships prior to arrival in a port, particularly suitable to prepare ships for the USCG inspections: https://www.register-iri.com/search/?fwp_global_search=+Critical+Items+Checklist+

-              The Commonwealth of Bahamas Marine notice with regards to PSC inspections: 

-              Pre Arrival Check-List of the Maritime Safety Directorate, at the Ministry of Sea Transport and Infrastructure of the Rep. of Croatia: https://mmpi.gov.hr/UserDocsImages/arhiva/psc_Check%20list%2021-2_17.pdf

 

Any enquiry regarding Fleet Monitoring measures applied to your ship (ships) can be sent directly to CRS Head Office at the following address:

CROATIAN REGISTER OF SHIPPING
21000 SPLIT
Marasovica 67
P.O.B. 187
CROATIA
Attn. to: Fleet Services Division
Phone No.: + 385 (0)21 408 117
E-mail: fleeft.services@crs.hr 

PORT STATE CONTROL INSPECTIONS