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Issue 1
Inspector Bulletin
Introduction - Inspector Bulletin
Welcome to the first edition of this inspector news
specifically here to share observations, OCIMF
guidance, material from clients/operators and any
other related feedback. I want to encourage you all to
share any feedback that you have so that we can all
learn from any specific situations onboard without
naming names or vessels here. Please let me know your
thoughts and remember that no question is too stupid
to ask if you are ever in doubt over any issues do let me
know. As we also have engineers on our network team I
would also welcome their professional input to any
technical points that come about.
=========================================
VIQ 7 – Initial Feedback
It’s been over 3 months since the introduction of the
VIQ and there have been a number of points raised from
the practicality of completing an inspection now within
the 8 - 10 hours guidance period to errors identified in
the actual guidance notes themselves. As a
self-improvement tool we encourage all inspectors to
review the operators comments to their reports as
discrepancies have been raised by operators identifying
incorrect guidance or misunderstandings in raised
observations. We do however all know many operators
will seek to challenge every item and discredit the
inspector, hence it is important that all observations
raised are both factual and clear especially when
referencing to regulation. Where there is doubt on the
inspectors side then I would encourage you to give
benefit of the doubt, but also do feel free to seek
further guidance from myself and/or client on the
issues.
The initial observation list left or discussed with the
master is just that, but at the same time observations
may well need tweaking for clarity in the final report,
though should not be changed within the meaning of
the observation itself.
SIRE Inspection Report
Latest updates & News feeds for Inspectors.
Experience Transfer Advice and Guidance Regulation Updates
Examples of Good Observations
I would like to share a number of good observations noted in the last few months;
Q) 4.3 Vessel was on voyaged of 1 to 2 days but steering gear tests as per SOLAS V/26.5
(power unit failure alarms) were not carried out once a week or prior every departure.
PMS records indicated alarms were tested annually and last done on 18 Sep 2018.
Q) 5.4 During testing of the steering system for the freefall lifeboat, the officers were
not able to demonstrate how to engage the emergency steering function.
The steering system was hydraulic and the activation of the system required the main
steering system to be operated by opening a bypass valve. (I have come across this on
a number of occasions as the crew often think they can just engage the manual tiller
and push either side)
Q) 5.26 There was no record for annual inspection of the oxygen and acetylene cylinder
gas regulators. This is a common finding with the new VIQ
Q) 5.43 The air compressor for charging the breathing
apparatus, EEBD and lifeboat air cylinders was fitted with
a 330 bar safety relief valve. Whilst this was correct for
the BA sets which had 300 bar operating cylinders the
EEBD and lifeboat air cylinders operating pressure was
200 bar and as such it would be possible to over
pressurise the air cylinders when recharging them. (Also a
common observation. There is a kit that can be fitted
here as an example to show what to look for)
225 barge relief valve fitted to the side here.
Q) 6.21 Two approved Ballast Water Management Systems (BWTS) available on board.
Both systems were reportedly operating good and was recorded as in use during
normal cargo operations as per the on board Ballast Water
Management Plan and the operator's procedures.
The BWTS on board required the ballast water to be treated both during ballasting and
during de-ballasting. However, according to the maker's manual the BWTS' seawater
temperature lower limit was 3,0 deg. C. The seawater temperature at the port of
inspection was 1,9 deg. C only and the BWTS could thus not be operated during
ballasting.
The operator's procedures for actions to be taken in case of BWTS failure, defect and/
or if the 'quality of the uptake water challenged the BWTS' (The uptake water outside
the BWTS design limits) required the vessel to inform the operator on a dedicated
'critical equipment defect report' and the
operator to inform class and/or the flag state regarding the intake of non-treated
ballast water.
The operator were then to agree with class/flag upon an action plan and inform the
vessel of same. Further the operator were to inform the PSC authority at the ballast
water discharge port.
The vessel had informed the operator by phone only.
There was no documentation on board that flag and/or class had been informed by the
operator. The vessel planned to do an ordinary ballast water exchange on route to the
next load port.
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Issue 1
Inspector Bulletin
Examples of Good Observations
Q) 8.50 There was no record of monitoring the slew
bearing of the hose handling crane. (Also a common
finding with the new VIQ)
Q) 10.32 The alarm panel in the engine control room
when checked was found to have 22 suppressed alarms.
These included the following:
MDO Tank high level alarm
Main engine air temperature cooler inlet alarm
Main engine fuel oil leak high level alarm
HFO Service tank No.2 high level alarm
Also the following alarms were suppressed due to sensor
failures:
HFO Storage Tank Port side level alarm
HFO Settling tank Port side high level alarm
===============================================
VIQ -7 Discrepancies
Through feedback and discussions we have identified the
following discrepancies within the VIQ to date. I would
encourage you all to share any other points that you have
also identified. OCIMF are aware of these;
• VIQ 3.2 Are the STCW and flag Administration’s
regulations that control hours of work to minimise
fatigue being followed and are all personnel maintaining
hours of rest records in compliance with MLC or STCW
requirements?
The Inspector should record an observation:
a failure by the manager to acknowledge
significant levels of non-conformance (3 or
more days containing “non-conformance” by
any individual on board)
The guidance lacks clarity in that it does not
state within what time period i.e. 3 or more
days in any calendar month.
• VIQ 3.8 Does the operator have measures in place
to prevent Drug and Alcohol abuse in accordance with
OCIMF guidance?
As a general rule the frequency of onboard
unannounced testing shall be less than the
shortest contract period on board to act as an
effective deterrent.
Latest updates & News feeds for Inspectors.
Experience Transfer Advice and Guidance Regulation Updates
VIQ -7 Discrepancies
This comment is unclear in that it may also include drug testing that
generally would not be done so frequently.
• VIQ 5.30 Is the rescue boat, including its equipment and launching arrangement, in
good order and officers’ familiar with the launch procedures?
Propeller guard. Each propeller on a lifeboat must be fitted with a propeller guard with a
maximum opening of 76 mm (3 in) on all sides on which a person is likely to be exposed.
(46 CFR 160.135.7(10)
Various OCIMF members are treating this in different ways from the replies that we have
seen. The USCG have confirmed the following “The requirements outlined in 46 CFR 160
are applicable to lifeboat manufactures that wish to receive a U.S. Coast Guard type
approval number for their product. For foreign ships operating in the U.S., SOLAS
approved lifeboats are acceptable.” Hence if the lifeboat and rescue boat meet SOLAS
requirements and NOT US flagged then this does not appear to constitute an
observation.
Similarities with questions under Chapter 5;
5.4) Are the ship's officers able to demonstrate their familiarisation with the
operation of fixed and portable firefighting, lifesaving and other emergency
equipment?
5.12) Are the crew familiar with the location and operation of fire and safety
equipment and have familiarisations been effectively completed for all staff?
5.15) Is there evidence of regular training in the use of life-saving equipment
undertaken and are crew familiar with those requirements and the location /
contents of the training manuals?
5.27) Are the officers aware of the requirements of LSA, are there ship-specific
life-saving equipment maintenance instructions available and are weekly and
monthly inspections being carried out?
5.35) Are the crew aware of the fixed firefighting equipment fitted, are ship
specific firefighting equipment maintenance instructions available and is
maintenance being carried out?
5.40) Are the crew familiar with the fixed fire extinguishing systems, where
fitted, are they in good order and are clear operating instructions Posted?
AWP Marine Consultancy Ltd
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Issue 1
Inspector Bulletin
Can any of our LNG experts identify
what this device is for??
This is a barrier punch device used in
emergency situations to penetrate
the membrane in the bottom of the
tank. The punch device is inserted
into the float gauge standpipe on
the trunk deck and the bottom of
the standpipe fitted with a split
perforated base to allow the
messenger to penetrate through to
the membrane. The invar
membrane is fitted with a thin
diaphragm and the plywood
insulation box thinner than normal
to allow penetration. This
operation is necessary only in the
event of damage to the membrane
such that LNG accumulates as a
liquid within the primary barrier
space rising up the lower chamber
and sidewalls as if liquid remained in
the sidewalls when the tank was
pumped out then severe damage
would occur.
Latest updates & News feeds for Inspectors.
Experience Transfer Advice and Guidance Regulation Updates
VIQ -7 Discrepancies
• VIQ 8.27 and 8.37 (oil and chems) Is the liquid level in the deck seal at the correct level, clearly
visible and are officers aware of requirements to periodically check the level? Some guidance in that
the use of double block and bleed systems is safely approved as alternative should be included here.
• VIQ 8.30 Are officers and ratings aware of safe entry requirements for the inert gas room(s), are
these procedures being followed and where applicable, is fixed oxygen detection provided? Vessels
delivered on, or after 01 Jan 2016, two oxygen sensors shall be positioned at appropriate locations in the
space or spaces containing the inert gas system.
These amendments entered into force on 1
January 2016, so only apply to ships the keels
of which are laid or which are at a similar
stage of construction, on or after the date. The
guidance should state: Vessels, the keels of
which are laid or which are at a similar stage
of construction, on or after 01 Jan 2016.
• VIQ 9.7 Is there a policy in place for the
testing of winch brakes and are the results
recorded?
Clarity in guidance to align with the MEG4 on
60% MBL of the line to 60% ship design MBL.
The Line Design Break Force (LDBF) shall be
100-105% of the ship design Minimum
Breaking Load (MBL)
VIQ 9.11 On split drum winches are all the lines made fast with no more than one layer on each
tension side of the drum?
If guidance is not available, a minimum of eight turns should be used.
MEG4 refers to the above under 5.7.6.2. However, 6.3.3.1 also states
“As a general guideline allow for the following:
• A minimum of ten turns for steel wire rope and HMSF mooring lines .
• A minimum of five to six turns for conventional fibre mooring lines.”
Obviously this is a little confusing but I believe we
need treat this in the sense that in all cases there
should be eight turns minimum, but if the makers
have provided guidance on the vessel and then in the
line management plan this can be accepted if less. I
also believe there needs to be some leeway here as if
just one winch has one turn too little it would be fair
to verbally point out to the vessel is the staff are well
aware of the requirements. We are after all
conducting a risk assessment and not trying to gain
points alone and our professional judgement should
be considered.
There is also of course the issue that if there is to be 10 turns are the split drums actually designed with
this capability as you can see from the photo here you possibly will be struggling to get 10 turns on the
drum first layer. New builds will have this considered moving on but existing vessels will be struggling
here.
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Issue 1
Inspector Bulletin
OCIMF Information Papers
OCIMF have recently published a number of information
papers and I would encourage you to read these and use
in relation to the SIRE inspections you perform. The
information papers can be downloaded from the OCIMF
website on the following link; https://www.ocimf.org/
publications/information-papers.aspx
Forecastle Overboard Valves
VIQ 6.10 Are the arrangements for the disposal of oily
water in the forecastle and other internal spaces
adequate and are officers aware of these requirements?
Where hand pumps or ejectors are fitted, pollution
prevention notices should be posted and the overboard
valves should be secured against accidental opening.
I often come across the overboard valves from forecastle
spaces padlocked closed and no key available for
emergency use. This is unacceptable and the valves
should be sealed with a breakable seal to prevent
accidental opening whilst at the same time able to open
in an emergency.
Latest updates & News feeds for Inspectors.
Experience Transfer Advice and Guidance Regulation Updates
Testing of Machinery Alarms
VIQ 10.21 If the vessel class notation allows UMS operation, are main engine bearing
temperature monitors, or the crankcase oil mist detector, in good order?
Testing of the detector alarm can be carried out either electronically or by removing a
cover and blocking the sensor path , in accordance with manufacturer’s instructions.
The photo shows a Visatron typical oil mist
detector alarm. Many engineers demonstrate
the alarm function by removing the two clips on
the face of the unit and that has the immediate
effect of causing an alarm on the vacuum failure
rather than testing the actual oil mist sensor.
Hence its good practise to look in the makers
instruction how to test the unit but I would
expect them to remove the centre plug in this
case and feed smoke into the unit or remove the
cover, place a plastic seal on the unit to prevent
the vacuum alarm and insert an opaque screen
that will set off the oil mist sensor alarm itself.
The picture is of a float type oil
leakage alarm fitted to an
auxiliary engine. Sometimes the
engineers offer to test this from
the electrical junction box circled
in yellow removing the cover and
bridging the alarm. I would
suggest physically checking the
float is operative as this can get
stuck with sludge.
The pictures here show the testing of the splash oil monitoring for the main engine.
This system acts as a pre failure warning of the engine bearings much sooner than the
oil mist detection.
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Hope you find the first edition here useful and I also hope that
it encourages you all to share your feedback here.
Disclaimer: this material discusses OCIMF activities based on personal experience and opinion and
not necessarily in agreement with OCIMF or OCIMF members views.
AWP Marine Consultancy Ltd
EMAIL: admin@awpmarine.com TELEPHONE: +44 (0) 151 792 4882