August 7, 2013, 10:28 am
The Maritime Authorities of the Paris, Black Sea, and Tokyo Memoranda of Understanding (MoU) on Port State Control (PSC) will launch a joint Concentrated Inspection Campaign (CIC) with the purpose to ensure compliance with SOLAS Chapter II-1. The scope of the CIC is the safety of propulsion and auxiliary machinery, especially the working order and maintenance of the main engines, auxiliary engines, auxiliary equipment and their related alarm systems. Special attention will be given to familiarity of the crew with safety and emergency procedures with regard to these systems. This inspection campaign will be held for three months, 1 September 2013 through 30 November 2013.
Owners and operators of U.S. flag vessels should expect that during regular PSC inspections selected items will be inspected in more detail for compliance with SOLAS Chapter II-1. Port State Control Officers will apply the enclosed questionnaire of 12 selected items to verify critical areas for the propulsion and auxiliary machinery installations, some of which are related to documentation, main and auxiliary equipment, crew familiarization and operational controls.
When deficiencies are found, actions by the Port State may vary from recording a deficiency and instructing the master to rectify it within a certain period to detaining the vessel until serious deficiencies have been rectified. Additionally, U.S. vessel detentions may result in a follow-up inspection by the Coast Guard and/or the authorized classification society if applicable. The results of the campaign will be analyzed and findings will be presented to the governing bodies of the MoUs for submission to the IMO.
U.S.-flag vessel owners and operators are encouraged to take the steps necessary to become familiar with the CIC criteria prior to the campaign. Specifically, regarding questionnaire item #2, for certain U.S. inspected vessels; documentary evidence of fitness can be demonstrated through a properly endorsed Certificate of Inspection for periodically unattended machinery space. Verifying that vessels meet applicable requirements under SOLAS in advance of foreign voyages and port calls can go a long way toward facilitating PSC inspections.
Officers in Charge, Marine Inspection (OCMIs) are requested to facilitate wide distribution of this Notice to vessel operators that could be affected. The Coast Guard stands ready to assist vessels owners and operators in this compliance effort. Please contact your OCMI with questions.
August 7, 2013, 10:27 am
Guidance for Coast Guard marine inspectors, Recognized Class Societies (RCS) and U.S. vessels owners/operators for meeting the provisions of the MLC.
The 94th (Maritime) Session of the International Labor Conference (ILC) (Geneva, February 2006) adopted the MLC, an important new international agreement that consolidates almost all of the 70 existing ILO maritime labor instruments in a single modern globally applicable legal instrument. The MLC establishes comprehensive minimum requirements for working conditions of seafarers including, among other things, conditions of employment, hours of work and rest, accommodation, recreational facilities, food and catering, health protection, medical care, welfare and social security protection. It combines rights and principles with specific standards and detailed guidance as to how to implement these standards at the national level. The Convention is comprised of three different but related parts: the Articles, the Regulations, and the Code. The Articles and Regulations set out the core rights and principles and the basic obligations of members ratifying the Convention. The Code contains the details for the implementation of the Regulations. The Code comprises Part A (mandatory standards) and Part B (non-mandatory guidelines).
The Maritime Labor Convention, 2006 will enter into force on August 20, 2013. The MLC requires certain ships that engage on international voyages have a valid Maritime Labor Convention certificate issued by its flag administration. The U.S. has not ratified the MLC. Until such time that the U.S. ratifies the MLC, the Coast Guard will not mandate enforcement of its requirements on U.S. vessels or upon foreign vessels while in the Navigable Waters of the United States. However, Article V, paragraph 7 of the Convention contains a "no more favorable treatment clause" which requires ratifying governments to impose Convention requirements on vessels from a non-ratifying government when calling on their ports irrespective of their status of ratification. As a result, U.S. vessels not in compliance with the MLC may be at risk for Port State Control actions including detention when operating in a port of a ratifying nation.
Guidance on MLC compliance is currently being developed. Once completed it will be posted.
Statement of Voluntary Compliance Declaration of Maritime Labor Compliance Part II: The SOVC-DMLC Part II should be prepared by the vessel owner/operator and outlines the measures put in place to ensure ongoing compliance with the requirements of SOVC-DMLC Part I. The format for Part II can vary depending on how the owner/operator decides to document their compliance measures. The enclosed template is available for owners/operators to download.
Self Declaration: United States commercial vessels, including uninspected commercial vessels, less than 500 GT ITC engaging on international voyages to ports of MLC ratifying nations may also be required by PSC authorities to meet U.S. laws and regulations or other measures conforming to the MLC requirements. The Convention does not require these vessels to be issued compliance certificates but it does require them to be in compliance with the MLC standards. To better facilitate a PSC exam, it's recommended these vessels voluntarily develop their own Declaration of Maritime Labor Compliance (self declaration).
For additional info, please go to https://homeport.uscg.mil/
Click on Missions > Domestic Vessels > Domestic Vessel General > Maritime Labour Convention, 2006
Or - contact LCDR Chris Gagnon, Office of Commercial Vessel Compliance, christopher.j.gagnon@uscg.mil
August 7, 2013, 10:23 am
Finally the DHS has allowed the STCW Final Rule to be submitted to the Office of Management and Budget (OMB) for review before publication in the Federal Register. Typically OMB review takes 3-4 months and then an additional month of final USCG review before publication in the Federal Register, So we should see the changes at the end of 2013. The OMB site info is at: http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201210&RIN=1625-AA16
but it does NOT have any details for review.
Anyone eligible for an original or upgrade to Master 500/1600 or any engineer officer (DDE/ Ch Eng Ltd) endorsement to get their application submitted to a REC ASAP as the path will get more expensive and longer soon!
August 7, 2013, 10:22 am
"Alternate Design and Equipment Standard for Floating Offshore Installations (FOI) and Floating Production, Storage, and Offloading (FPSO) Units on the U.S. Outer Continental Shelf"
After consultation with industry, facilitated by classification societies who have classed FOIs & FPSOs in the Gulf of Mexico, U.S. Coast Guard Headquarters, Office of Design and Engineering Standards (CG-ENG), has published CG-ENG Policy Letter No. 01-13, "Alternate Design and Equipment Standard for Floating Offshore Installations (FOI) and Floating Production, Storage, and Offloading (FPSO) Units on the U.S. Outer Continental Shelf."
This 23 page policy letter can be found on the CG-ENG website http://www.uscg.mil/hq/cg5/cg521/docs/CG-ENG.PolicyLetter.01-13.pdf
This policy letter establishes an alternative design and equipment standard to 33 CFR 143.120(b) for FOIs and FPSOs located on the U.S. OCS.
It only covers design and equipment and does not cover operational, manning and training requirements. Under this policy letter FOIs or FPSOs would not need to obtain an equivalent level of safety on a case by case basis, although that option would continue to remain available where appropriate.