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Issue 15
Inspector Bulletin
Latest updates & News feeds for Inspectors. 28th July 2020
Good Observation
VIQ 8.27 (C) Where fitted, is the condition of the cargo
tank heating system satisfactory, is it regularly tested
and is any observation tank free of oil?
When overheating or overcooling could result in a dangerous
condition, an alarm system which monitors the cargo
temperature shall be provided. (See also operational
requirements in 16.6.) (IBC 7.1.5.4)
Inspectors Observation: The vessel was carrying heat
sensitive flammable inhibited cargo yet the cargo
computer alarm settings for tank temperatures were set
to zero at the time of the inspection. Further, there were
no records of monitoring of the temperatures during
transit.
IBC 16.6 Cargoes not to be exposed to excessive heat
16.6.1 Where the possibility exists of a dangerous
reaction of a cargo, such as polymerization,
decomposition, thermal instability or evolution of gas,
resulting from local overheating of the cargo in either the
tank or associated pipelines, such cargo shall be loaded
and carried adequately segregated from other products
whose temperature is sufficiently high to initiate a
reaction of such cargo (see 7.1.5.4).
Disclaimer: this material discusses OCIMF activities based on
personal experience and opinion and not necessarily in
agreement with OCIMF or OCIMF members views.
Inspectors are encouraged to share their experiences for us
all to learn from here.
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Experience Transfer Advice and Guidance Regulation Updates
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?
This is the sole question within the VIQ that directly addresses rest and fatigue, hence this question
has some significant importance and inspectors are encouraged to focus in this area during the
inspection.
Lack of fatigue management has been identified as a significant contributory factor in accidents on
vessels. This is further supported through research where shortfalls have been highlighted in
current fatigue management with expectations that seafarers are responsible for their own fatigue
management that can lead to a tolerance to fatigue in the long run.
There are a number of points to look at when addressing
this question from an inspection view. It is not a case of
a simple review but of rest hours recorded;
1. Are there records of work / rest hours maintained and
are these records accurate (cross check with operations)
2. Are individuals completing their own rest hour records
to ensure record accuracy (can be hard copy or soft copy
access)
3. Are the crew well aware of their watch and duty
periods both at sea and in port for planning their own rest
(duty roster should be posted in public areas)
4. Are the duty schedules and planning of watches
effective (ensure 6/6 rotations and extensive duty periods
are not scheduled)
5. Is the work and living environment onboard designed
to facilitate quality rest (noise/ light/ heat/ vibration)
It is essential that senior management are aware of any
issues of fatigue or rest infringements onboard the vessel
and there should be clear evidence of shore management
involvement with the operations onboard;
1. Are non-conformities raised through an effectively
high channel to ensure actions taken and taken timely
here, not just months after the issues
2. Is there a person designated responsible ashore
for monitoring the rest hour compliance (do they take
an active interest here)
3. Is there an effective planning process to mitigate
the risks of rest hour breeches (maybe electronic
planning tools)
4. Does the shore management take effective further
action where the trend on breeches is rising or
extensive (additional manning / out of service
downtime / amendments to C/P)
The attached link to AMSA guidelines on fatigue is a
useful publication looking at the problems and
possible solutions: https://www.amsa.gov.au/sites/
default/files/amsa-fatigue-guidelines-web.pdf and
the IMO Guidelines on Fatigue http://www.imo.org/
en/OurWork/HumanElement/Documents/MSC.1-
Circ.1598.pdf
AWP Marine Consultancy Ltd
EMAIL: admin@awpmarine.com TELEPHONE: +44 (0) 151 792 4882
 Please keep up to date on the latest news and the high quality services that AWP marine provided: http://awpmarine.com/

Issue 15

Inspector Bulletin Latest updates & News feeds for Inspectors. 28th July 2020

Experience Transfer Advice and Guidance Regulation Updates

Experience Transfer

VIQ 5.5 Are the crew aware of the requirements for wearing
personal protective equipment such as boiler suits, safety
footwear, eye and ear protection, safety harnesses, respiratory VIQ 8.68 (LPG) and VIQ 8.72 (LNG) Are officers aware of the operation of the chemical
and chemical protective equipment? dry powder system, and is the system in good order?
VIQ 5.32 Are lifejackets in good order and correctly located?
Inspectors observation: The fixed dry powder stations contained sodium bicarbonate
Inspectors observation: The vessel had a number of non SOLAS based chemical reagent rather than potassium bicarbonate as recommended by MSC.1/
approved life vest/work vests located at the gangways for Circ.1315
working over side / rigging ladders.

There is no requirement for work vests to be SOLAS approved,

though equipment , especially PPE should be fit for purpose.
Personal floatation devices and work vests have four main
buoyancy levels: 50, 100, 150 and 275.

Standards applicable to this level range from EN 393 or ISO

12402 – 5 to EN 399 or ISO 12402 – 2.
Hence the work vests should be in good condition and meet a
suitable standard that is stated within the companies ISM
procedure.

VIQ 10.2 If the machinery space is certified for unmanned
operation is it being safely operated in that mode without
regular alarms occurring under normal conditions?
Inspectors Observation : There were 5 off scan alarms indicated
on the engine alarm system relating to bilge well alarms and fuel
tank overflow alarms.
Inspectors should check if there are any alarms that have been
isolated (or offscan) and where possible establish the reason
why this could be. Especially relevant where the machinery
space is operating unmanned and isolation of alarms can
identify serious problems.
Only chemicals based on the salts of potassium should be used. Dry chemical storage
containers should be designed to pressure codes of practice acceptable to the
Administration, for the maximum system pressure developed at 55ºC. MSC.1/Circ.1315 3.4
So why should potassium bicarbonate be used rather than sodium bicarbonate? Simply in
order of performance, fire tests on flammable liquids have shown potassium bicarbonate
based dry chemical to be more effective than sodium bicarbonate based dry chemical.
Similarly, the monoammonium phosphate based dry chemical has been found equal to or
better than the sodium bicarbonate based chemical. Hence this is the standard required.
VIQ 2.10 Are the Engine Room (Part I) and Cargo (Part II) Oil Record Books (ORBs) correctly
completed, free of any pollution incidents, violations and are slop/waste oil disposal certificates
provided?

Inspectors Observation; The oil record book part 1 recorded the evaporation of water from the oil residue tank
under C 12.4, however this was not recorded as an approved means of reducing water content under 3.2.3 of the
IOPP Form B.

With reference to MEPC.1/Circ.640 and MEPC.1/Circ.736Rev.2, the heating of oil residue (sludge) as a method of
reducing its volume by evaporation should be recorded in the Oil Record Book, Part I, under Code (C) (Collection,
transfer and disposal of oil residues (sludge)), paragraph 12.4 on condition that the sludge tank is listed in section 3.1
of IOPP supplement. There is no requirement that such natural evaporation should be marked within the IOPP
certificate however, and as such this need not be recorded as a means of disposal of oil residue.

AWP Marine Consultancy Ltd

EMAIL: admin@awpmarine.com TELEPHONE: +44 (0) 151 792 4882