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Note to all Inspectors

Following a number of issues that have come to light, and also from discussions at the last SIRE
Focus Group Meeting, a number of items need to be brought to your attention and require
clarification.

1. ECDIS Certificates.

It has been brought to the attention of the OCIMF Secretariat that there is some confusion
over the ECDIS generic training requirements. As you are well aware the IMO has produced
the Model course 1.27 with a detailed syllabus and it requires a 40 hours’ duration. If a
seafarer attends a training college to undertake Generic Training, this will almost exclusively
be performed on this model course and the certificate issued by the college may state as
much.

This model course produced by the IMO is just that a ‘model’ course. There is no obligation
on Flag states to follow this course and many will have their own requirements as to what
this Generic Training should entail. Flag states who are issuing Certificates of Competency
(License) may endorse the Certificate (license) that the seafarer has undergone ECDIS
training and this may not state that the training meets the requirements of IMO model 1.27.

With immediate affect inspectors are NOT to issue an observation if the Certificate of
Competency (License) does not mention that the training complies with IMO Model course
1.27. (Guidance notes in the VIQ will be amended accordingly).

2. Performance Standards of ECDIS

ECDIS units have to meet a minimum performance standard as set out in IMO MSC
Resolution 232 (82). ECDIS manufacturers will include additional features to make their
product more attractive to ship operators. The cost of an ECDIS unit can vary from about
$50k to $250k depending on the unit. We are seeing increasingly where inspectors are
making observations regarding ECDIS that it cannot perform certain tasks that they have
seen on other ECDIS units.

As long as the unit meets the minimum performance standard, then observations should
NOT be made even if it cannot perform other features you have seen on other units.

3. Smart Watches / Fitness bands.

The use of Smart watches / Fitness bands is increasing. ISGOTT recognises that conventional
battery powered watches can be used in a gas hazardous area as there is no risk of the
watch causing an explosion. The same cannot be said of the Smart Watches / Fitness bands,
these have far greater power and are not considered safe by many Companies/organisations
for use in gas hazardous areas.

The use of these smart Watches / Fitness bands is prohibited for use in gas hazardous
areas by inspectors conducting SIRE inspections. In addition, if during the course of your
inspection you observe a member of the Ship’s staff using a smart watch / Fitness band,
then an observation is to be recorded.
4. BNWAS

The SOLAS requirements for BNWAS is that it must be powered by the main power supply
and have a battery backup. This battery backup can either be an internal battery within the
BNWAS unit or can come from a bank of batteries that supplies other equipment.

There has been some confusion over the testing requirements that inspectors can
undertake. With respect to testing of the equipment, the inspector may ask for the mains
power supply for the BNWAS only to be simulated to fail and then to establish whether the
equipment is still operational and alarms on main power failure. There is NO requirement to
‘trip’ the backup battery supply.

5. Engineered Operations.

A note was previous sent out by my colleague Shaikh Rahim on this subject, however to
clarify I have included it in this general note. Ship Operators are of the view that Oil
companies will only screen a ship if the SIRE inspection was carried out whilst discharging
and in question 1.13, the option ‘Discharging’ or ‘STS discharging’ is selected. To try and
achieve this the ship’s crew /operators/charterers will try to ‘engineer’ a situation to ensure
that the inspector selects ‘discharging’. This can be done in a number of ways. To be able to
select ‘discharging’, the vessel must be conducting a discharging operation to shore
reception facilities or conducting an STS discharge to another vessel.

The following do NOT constitute discharging: -

 Internal recirculation of cargo within one cargo tank,


 Moving cargo from one tank to another on board,
 STS operations specifically set up by the ship to facilitate a ‘discharge’ inspection
whereby a small quantity is transferred to another vessel and then back loaded.

In addition, if when on board the vessel, it is alongside but is not conducting any cargo
operations for whatever reason (Shore requirements, problems on board etc.) during the
course of the inspection, then this must be considered an ‘Idle’ inspection.

6. Inspection of Records

We have received complaints from Ship Operators that inspectors are raising observations
concerning discrepancy of documentation going back a number of years. In one case an
inspector raised an observation on a hot work permit that was dated 4 years prior to the
inspection.

When reviewing records, inspectors need only review documents that go back no more
than 9 months old which have been completed under the current ship management
operation.

7. Electronic Certificates

The IMO has now approved the use of electronic trading certificates (SEC, Safcon etc.) and it
is reported that the Governments of The Netherlands and Denmark have started to issue
such electronic certificates. The IMO document FAL.5/Circ.39/Rev.1 provides information
on the format and security measures for these certificates. A copy of this document has
been uploaded onto the resources area of the SIRE website.
These electronic certificates are acceptable and should be viewed on board the ship’s
computer.

8. Officers Matrix.

The data entry fields on the officer’s matrix has been adjusted to fully harmonise it with the
CDI version. This now includes a facility to include ‘Time as a watchkeeping officer’ to all
ranks including the Master, however for some ranks this is optional.

Do not raise an observation if this field is not complete for all ranks.

9. Fixed CO2 Fire fighting Systems.

On CO2 systems there are ‘pins’ in the activation assembly, and traditionally, these pins had
to be removed for the system to be ready for immediate use. On some modern systems,
these ‘pins’ have to be left ‘in’ for the system to be ready for immediate use. When
inspecting the CO2 systems determine from the officer accompanying you whether the pins
should be ‘in’ or ‘out’ for the system to be ready for immediate use. If in any doubt refer to
the manufacturers operating inspections.

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