Technical Circular No: 010/2022
Download PDF1. Republic of Marshall Islands (RMI) Administration has issued Marine Advisory No. 05-22 informing that there has been a significant increase in detentions of RMI flagged vessels during USCG PSC inspections. Most of these detentions were easily preventable by proper and effective implementation of company and vessel Safety Management Systems.
2. In this regard, the Administration vide Marine Notice No. 5-034-5 had introduced the Critical Items Checklist (RMI Form MSD 340) to communicate preventable detainable deficiencies that could be expected in the United States based on historical trends.
3. Prior to arrival in a US port, the Master and Chief Engineer of RMI flagged vessels are required to complete, sign, and submit the Critical Items Checklist to NOA@register-iri.com in conjunction with the eNOA which is submitted 96 hours prior to arrival. Failure to complete the Critical Items Checklist could lead to suspension of the Master’s and Chief Engineer’s RMI seafarer documents and/or an additional audit of the vessel or Company SMS.
4. In the event of consecutive US port calls, the Critical Items Checklist (MSD 340) need only be submitted prior to the first US port. An updated Critical Items Checklist (MSD 340) must be submitted if the condition of the vessel changes during these consecutive port calls or after the vessel calls a port outside the US.
5. Proper physical verification of the items on the Critical Items Checklist is an effective tool for preventing PSC detentions.
6. However, the recent trends shows that RMI vessels are also being detained for items found in a substandard condition that are not specifically listed in the checklist, implying that the check list alone should never be used as an exhaustive list to identify all possible scenarios.
7. Further, it is noted that tank ships and gas carriers continue to schedule Certificate of Compliance (COC) exams when unprepared, resulting in detentions.
8. In view of above, the Administration has advised that if there are any concerns about the material condition of the vessel, operators must contact the Administration at inspections@register-iri-com to schedule a special inspection prior to scheduling the COC exam.
9. Further the Master and Chief Engineer of RMI flagged vessels have been advised as follows;
a. To accurately complete and verify the Critical Items Checklist. Reliance on statements that inspections are complete is not sufficient. All items must be physically checked and verified.
b. Be proactive and conduct a thorough inspections of their spaces prior to arriving in the U.S. and identify any substandard condition.
c. Senior officers and crew members to physically verify compliance and operation of onboard systems. Systems or areas that are most affected include firefighting, life-saving, environmental compliance, load line in terms of watertight integrity of doors and ventilation, and crew familiarity and performance.
d. Advise the RMI Administration of any non-operational equipment.
10. Owners/ operators and masters of Marshall Islands flagged vessels are advised to be guided by above. Further, the above requirement be included in the safety management manual and ensure compliance.
Enclosure:
Disclaimer:
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.