Member Authorities of the Tokyo and the Paris Memoranda of Understanding (MoU) on Port State Control will launch a joint Concentrated Inspection Campaign (CIC) on STCW. This campaign will be held for three months, commencing from 1 September 2022 and ending 30 November 2022. By examining compliance with the STCW Convention and Code, it aims to reduce or eliminate safety risks in respect of manning, the crew’s fitness for duty, training and fatigue. The Black Sea MoU will conduct a same campaign simultaneously.

I. Objectives

The campaign on STCW aims to confirm that:

1. the number of seafarers serving on board and their certificates are in conformity with the relevant provisions of STCW Convention and Code and the applicable safe manning requirements as determined by the Flag State Administration;
2. all seafarers serving on board, who are required to be certificated in accordance with STCW Convention, hold an appropriate certificate or a valid dispensation, or provide documentary proof that an application for an endorsement has been submitted to the Flag State Administration;
3. the seafarers on board hold a valid medical certificate as required by STCW Convention;
4. the watch-keeping schedules and hours of rest indicate compliance with the requirements of STCW Convention and Code.

The CIC will assist in raising the awareness of shipowners, operators and crew on the specific requirements in the STCW Convention and Code.

II. Areas of inspection

The CIC inspections will be applicable for all ships and conducted in conjunction with the regular Port State Control inspection. During the period of the campaign, a ship is supposed to be subject to only one inspection under this CIC. IMO Resolution A.1155(32) provided guidance for the PSCO on certification of seafarers, manning and hours of rest. The documentation required for the inspection referred to in these Guidelines consists of:

.1 certificate of competency;

.2 certificate of proficiency;

.3 endorsement attesting the recognition of a certificate (flag State endorsement);

.4 documentary evidence (passenger ships only);

.5 medical certificate;

.6 minimum safe manning document;

.7 muster list;

.8 table of ship working arrangements and/or watch schedule; and

.9 records of daily hours of rest.

A more detailed inspection may follow if there are clear grounds for believing that such an inspection is necessary so that the PSCO could verify the seafarer’s related competency and the proper response to emergency situations. The results of the campaign will be analysed and findings will be presented to the governing bodies of both MoUs.

III. List of questions

Port State Control Officers (PSCOs) will use a list of predefined questions during the CIC. If 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 of time to detaining the ship until the detainable deficiencies have been rectified.

Note: if “No” is ticked for questions marked with an asterisk “*”, the ship may be considered for detention.

IV. Interpretation to inspected items

Questions 1-5 are first to be inspected by PSCOs when they get on board. Although the requested certificates and document may not be an issue for most ships, masters and crews should not take these questions lightly. During the Paris and Tokyo MoU PSC inspections in the first half of 2022, 16 ships were detained due to problems with respect to the minimum safe manning document and 10 were detained due to crew certificate issues. As many as 803 deficiencies relating to crew certificates were identified in the 2021 Tokyo MoU inspections, representing 2% of the total number of deficiencies. Companies and ships are encouraged to take into account the following:

• the period of validity and extension of certificates issued by flag States
• whether a bosun, chief mechanic or welder who are assigned duty of a watch hold valid certificate of competence
• familiarization of GMDSS operators (a total of seven ships were detained due to improper operation of GMDSS equipment during the Tokyo and Paris MoU inspections in the first half of 2022)
• whether written evidence can be provided to demonstrate medical measures, such as regular blood pressure tests, records of diagnosis, and arrangement for health check on shore, are taken on the ship to address the situation of a particular crew member who requires follow-up medical care as indicated by his certificate.

Question 6 relating to hours of rest represents a major category of deficiency. To comply with the Convention’s requirement on minimum hours of rest, there are indeed instances of false or inauthentic records of hours of rest on ships, which may be easily spotted by the PSCO if compared with other logs or document kept on board, since records for critical operations such as arrival/departure, berthing/unberthing, equipment repairing, bunkering, taking supplies and emergency drills are likely to give away signs for disturbed rest. According to report by the Paris MoU, eight ships were detained for not in compliance with the hours of rest requirement in the first half of 2022.

Question 7 concerns mainly alignment of the relieving crew with the watch schedule, and the competency of anyone assigned the duty of a watch, especially when it comes to crew members such as the bosun, the motorman, the welder, the ordinary seaman or the cadet. In the first half of 2022, six ships were detained for incompetence of the watchkeeping crew during PSC inspections under the Paris MoU.

Question 8 may not be as simple as it seems. In the first half of 2022, 14 ships were detained under the Paris MoU inspections for not being familiar with emergency procedures while 86 ships were detained for underperformance in drills. This question is attached with great importance since it concerns compliance under both the STCW Convention and the SOLAS Convention.

Question 9 should be most concerned by ships with a multinational crewing practice. For crew members from non-English speaking countries with English as the working language, it is probably manageable to read paper documents and records, but not so much when communicating verbally. The PSCO would determine whether the crew members are able to clearly understand the instructions of the master and to respond accordingly as appropriate. Deficiency with respect to communication problems may take great efforts in subsequent rectification and indeed poses a serious threat to safe navigation. The Association has also noticed many cases where ineffective communication between crew members is one of the major causes of safety incidents.

With companies increasingly recognising the importance of rationality and integrity of voyage plans, most ships now have voyage plans that cover the whole route from berth to berth as required by Question 10. Still, it is recommended to cover the furthest possible berth when planning the voyage even if specific berth information is not yet available prior to arrival. Adjustments can be made upon later confirmation so that time can be saved and detainable deficiency with respect to incomplete voyage plan prevented.

V. Conclusion

By looking at the list of questions set out in the CIC and comparing records of detention under the Tokyo and Paris MoU, we may come to realize that the crew’s skills in operational practices are being examined with greater emphasis, in addition to the focus on the certificates and documents. To better prepare for the inspection, members are recommended to carefully review all items to be inspected referring to the above list of questions and any other Port State Control documentation and ensure adequate competence and skill of the crew as per relevant operational requirements.

For more information, please contact Managers of the Association.