Instructions for Vetting by SIRE
SIRE inspection - preparation...
INSTRUCTIONS FOR VETTING
There have been a few areas of on-going concern and the following elements are reminders of what we have to achieve during an OCIMF vetting inspection. This list will serve also as an aid memoir in the days to come. • All officers should be very familiar with VIQ requirements for their areas of responsibility. Senior officers need to be familiar with the complete VIQ and especially the Master who ensures VIQ compliance throughout the entire vessel. • The best results are usually obtained by involving all the ship’s crew and to do that it is worthwhile having one or two meetings – bring the ship’s staf into your confidence – and explaining what it’s all about and what everyone on board needs to do to improve the opportunities for achieving a good standard of SIRE. It’s all about teamwork. • Presenting a SIRE inspection in a positive way to ships staf will always result in a better SIRE than the senior officers presenting it in a negative manner. Where vessel management and personnel are good then you will get good results. (Please read this last sentence again) • Start of on the right foot. Please ensure you have the necessary security watch in place and everyone who comes on board goes through the security check, including the inspector. Ensure a safety net is correctly rigged at the gangway and the inspector is escorted to the ships office. All staf need to be in clean boiler suits and appropriate PPE. • Remember that the inspector will be able to listen in on board radio discussion for most of the inspection. Good clear English is to be used at all times. NO OTHER LANGUAGES USED AT ANY TIME • Ideally the Master should be with the inspector for all parts of the inspection except the engine room where it should be the Chief Engineer. Do not allow junior officers to accompany the inspector. • During the inspection it is not confession time. Look after the Owners interests. Do not ‘volunteer’ information which is not requested. Do not however try to nonsense the inspector as he will be a step ahead of you in this. Inspectors typically inspect some 100 vessels a year and they have heard all the excuses before. They have generally had a lot of experience as sea going senior officers – in other words they are smart people and know the paperwork. • The closeout meeting is fundamental and must be properly managed. Remember, the inspector is reporting on your command and your management of the vessel. As a minimum we need the Master and the Chief Engineer in attendance for the closeout meeting. You need to win over the inspector and you need to manage the meeting such that you do all that is possible to minimise the number of observations. Several Masters have been really efective at this with a firm understanding of what is required. A small minority of Masters appear to be somewhat bewildered as to what they are there to achieve. One Master in the past signed for two observations that were not discussed at the closeout meeting. Unbelievable! • When an inspector raises an observation he must do so against the VIQ and he must be able to clearly show where vessel does not comply with the VIQ. Avoid an argumentative stance with the inspector – you are the Master, use your management skills; an argument will not work. Please have the updated SIRE Programme ready for reference. • We know it may not be helpful but the fact is the shipping industry counts observations and the accepted perception is the fewer observations you get the better the vessel is. We have a barrier at 5 observations and you must do whatever is possible to get 5 or below. Thereafter the next line of resistance
you need to try for is 4 or less observations – remember Dan Olsson has set us a KPI for the average of all inspections to be 4 observations or less. We have a psychological barrier at 10 observations. Don’t go there. To get double figures is very, very bad. If you have a picky inspector and for some reason you are up at this number of observations do all you can to get a 9 as oppose to a 10 or worse. We need to avoid double figure observations. In other words no inspections results in more than five observations, the fleet average is less than four, no observations are high risk, repeat or related to housekeeping. These are crucial. BP have informed NMM that they are placing extra emphasis on repeat observations within their assurance and clearance process. They see repeat observations as an indication of increased risk through poor inefective management. Repeat observations must be avoided. • If you do not fully agree with the inspector’s wording of an observation then endeavour to negotiate a change. This is very important. • Remember that the inspector gives a ‘confidential’ report to the inspecting company. Basically the question the oil company asks is, “would you be happy chartering this vessel with the personnel on board”? • Master has to provide NMM with a detailed response for each observation. Why it happened. What you have done on board to correct the observation and what you have put in place to avoid a recurrence. You have to be wholly honest with us. One Master in January 2012 lied to us about the cause on an observation. This can be very unhelpful when communicating with an Oil Majors vetting dept. • We need your professional and objective feedback on the inspector. From a recent inspection the Master said nothing about an unprofessional inspector and we only knew due feedback from the attending FSS. Always remember that the inspector is there to inspect the vessel and your management of the vessel, not to inspect the attending FSS / Supt. • NMM has to respond to OCIMF with clear and detailed answers to all observations and we in the office cannot second guess what was observed and discussed on board. The detail we give to OCIMF must be accurate and you have to be aware that the inspectors talk with the oil major who employs them. If you have an awkward observation then it is what it is, be honest with us and give us the full facts so we can work together to answer the observation and mitigate the concerns that the inspecting company may have. The following have been recurring observations / discussion points during inspections; • Trading Certificates – incorrect or conflicting details regarding names and dates. Please sight all these presently on board to confirm all details correct. • Officer certification and documentation – please ensure all are correct and available for inspection in one place. If any officer has a CRA please check validity of this. Any problems contact operations. • It is a must that all vessel files, certification and documentation that inspector needs to see are organised and are available in one convenient location. This makes the inspectors job a lot easier and shows to him good forward thinking and organisation. • It is essential that an up to date HVPQ has been submitted to Glasgow office prior inspection so we can upload to the OCIMF database. • Your on board officer matrix MUST agree with that which company electronically submits to the OCIMF database. We will forward you an updated matrix, which will be the same as in the OCIMF database.
• Charts and nautical publications are corrected and up-to-date. T&P file and nav warning file properly corrected with appropriate notices on voyage charts. Bridge filing is tidy. • No newspapers, novels, magazines, video disk libraries, dirty cups etc., etc. on the bridge. It is not a cofee shop, it is the navigation centre of the vessel. The same applies with the MCR. • Remember to write comments / times on the echo sounder trace and course recorder. • Evidence that Master is checking that charts and nautical publications are corrected. • The passage plan is in line with the latest Company requirements. Ensure that OOW is recording alter course positions in the deck log. Master and officers to have signed the passage plan. • Clear evidence of cross checking vessel positions using more than one position fixing method must be charted. Make this obvious on the chart. Do not fix vessel from floating objects unless it can be shown their position has been verified. If you state in the passage plan that frequency of position fixing is 10 minutes then you must position fix at intervals not exceeding 10 minutes. • Particularly for costal navigation largest scale charts must be in passage plan and used. • ECDIS – officers must be familiar with on-board equipment. The ECDIS Type Specific Training Familiarisation Checklist shall be completed by all Masters and Navigating Officers prior to taking a watch. The related Type Specific Certificate shall be available for all Masters and Navigating Officers as per Fleet Circular 73 and this should clearly show the make and model as being the same as that on-board. 2/0 needs to be clear to inspector that primary means of navigation is the paper charts. • Proper filing, updating and charting of nav warnings and T&P notices. Also cancelling of same. Most important and some vessels are not up to the mark with this. • Housekeeping – Oil / water in save-alls, mops/brushes lying around in an untidy manner, scupper plugs defective or loose, save-all drain plugs missing or not fitted. Good housekeeping is essential throughout the vessel. Make sure an officer goes ‘round the job’ before the inspector. You know where the difficult areas are on the vessel, make sure they are presented well at time of inspection. • Deck watch to be very clear that all scupper plugs are properly shipped. • Deck watch to know location of emergency pump stop and when they should use this. • Oil spill pumps tested as proved working. Ensure suction hose /filter is clear. • Manifold pressure gauges defective or indicating trapped pressure suggesting leaking valve seats. Ofshore manifold gauges should read zero. • Hydraulic oil leaks on deck from mooring machinery / control stations / cranes are never acceptable. • Soot accumulations on the poop deck and external accommodation decks which had quite clearly not been hosed down for some considerable period of time. • Oil and water leaks around the Main & Auxiliary Engine Cylinder covers and streaks down the sides of the engines. Should be clean for inspection. • Bilges not as clean as they should be – oil / chemical/ water stained again suggesting long periods between cleaning. • Various used / defective engine parts left lying around the Engine room in full view and often unsecured. Please remove / cover / dispose of such items as agreed with Superintendent.
• Items stored in the Cross Alley on deck in an untidy / unsecured / unsightly manner. • Paint / Chemical / Gas Bottle Lockers – some are very orderly and well organised – others are not and need to be tidied or cleaned more often. Each gas bottle must have a U clamp fitted – secured by rope is not acceptable. Proper safety goggles at chemical locker and MSDS information. • Cargo samples properly stowed. • Public rooms / General Offices untidy or cluttered in some cases. Should be well presented. • Smoking Regulations not being fully adhered to – Master to enforce this – zero tolerance for defaulters. I.e. designated areas clearly marked, no more than 3 during cargo operations, safety ashtrays/matches, no lighters, proper disposal arrangements, etc. In 2010 we had to dismiss a C/O for violation of smoking policy and we are presently terminating a 2/E for alcohol and smoking violations. • All on board hand held torches must be intrinsically safe. • Hospital – We recently noted that on one vessel hospital was found not ready for immediate use – dirty bath, smelling drains / scuppers. This questions the efectiveness of the Masters weekly inspections as well as management of the vessel. • Ventilation Flaps / fans – there are still instances being observed where flaps are closed and fans are stopped prior to entry into the space. This includes such places as Foc’sle Space, Paint Locker, Chemical Locker, Steering Flat, etc. Please ensure all flaps are correctly set and fans are in operation PRIOR to inspection and entry on each occasion. Stena Provence lately got a PSC observation at Rotterdam due a/c vent flap would no close due they had not been worked during weekly checks. • Ventilation Flaps not clearly labelled / identified. Giving these a number only is not enough – they must be identifiable quickly and locally on site. • Mooring Winch Brake handle locking pins not in place or not being used. • Garbage areas – some are untidy / dirty / have drums lashed by ropes to the handrails / wooden lids. All must be fully compliant with present regulations. • Wheelhouse / ECR / CCR – in some cases no special efort has been made to clean / tidy these spaces prior to attendance of a Vetting Inspector • Cargo plan for discharge port is in line with the latest Company requirements regarding format and information to be contained • Cargo records and calibration records are up to date and readily available • All lighting on external decks should be checked to ensure they are in good condition and urgent steps taken to rectify any lamps that are out. This includes nav lights • Soft patches on pipes – you should be aware of any such temporary repair, which if applied correctly will not be apparent. Oil companies do not accept soft patches. Any temporary repair such as this must be followed up with the submission of a SFTEC8 for permanent repair either in service or next shipyard as agreed with Superintendent. • Lock Out Tag Out system not being fully utilised and documented on some vessels in line with SMS requirements • Work Permits / Hot Work Permits / Entry Permits not being filled in completely, often with no reference to Risk Assessment. It is recommended that the Master and Chief Engineer sight and sign all Hot Work and Entry Permits prior to the work / entry being carried out. This is not happening in some cases and permits have been sighted with only the 2/E signature in some cases. Are the
Master & Chief Engineer actually aware of this intended work / entry? Has it been planned and discussed in a work meeting at all levels? Some evidence suggests this may not be happening on some vessels. • Hours of rest records checked and correct. This will be checked by the inspector. • Any deficiencies identified during self-check have either been resolved or the appropriate measures have been put in place e.g. items added to SFTEC 29 or SFTEC 8, Purchase Orders raised, Safety Committee discussions etc. • The LSA and FFA are checked/maintained as per SFSAF 2 requirements. LSA and FFA are not obstructed in any way (this is a regular fault). Ensure ELSA sets are in good condition. • Check SCBA bottle pressures – must be full. Check torches are working. • The galley, stores and fridges are clean and orderly. • Any oil drip cans to be removed prior the inspection. • Gangway watch maintained at all times. Sign at foot of gangway if possible. Strong visitor control at the top of the gangway by the security watchman is essential and ID must be asked for and presented before the visitor is to permitted to proceed to the accommodation. • Uniforms to be worn in the dining saloon at all times, B’fast, Lunch & Dinner. Cook & Messmen to be appropriately dressed. • Check life raft weak link is correctly connected and bridge wing lifebuoy tag line is not secured. • Only senior officers should be allowed to escort inspector round the vessel. • ORB’s checked and checked again for correct entries, up to date entries and signed. Use correct date format stating MONTH, i.e. 04-Mar-11; not 04/03/11 or is it 03/04/11? Ensure entries are signed for by the RESPONSIBLE PERSON and countersigned each day by the C/E Having required spares on board for planned maintenance. No on-board spares and overdue maintenance will be an almost certain rejection. Ensure there are no drip cans around nor ‘soft patches’ on any pipelines. The former are considered bad housekeeping and a fire hazard while soft patches are liable to become ‘permanent’ We have had repeats of these two items at recent SIRE inspections and this must not be the case anymore. Please pay particular attention and explain to your staf the necessity to avoid such situations. The above not being in order gives the impression that on board management is not wholly efective. Equally, where there are high standards on board and high attention to detail then this allows the inspector to report very favourably on your vessel.