Annual Report on Port State Control

related to ISM Code

on Ships with SMC issued by ClassNK

2008

June 2009
CONTENTS

Introduction ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・ 1

Chapter 1 ISM deficiency cases

1.1 Total number and average rate ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・ 2

1.2 Comparison ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・ 2
.1 Per factors related to ship ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・ 2
.2 Per factors related to Company ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・ 6
.3 Per port state who carried out PSC inspection ・・・・・・・・・・・・・・・・・・・・・・・・・・ 9

Chapter 2 ISM deficiencies and PSC actions

2.1 Comparison of deficiencies per ISM Code requirement ・・・・・・・・・・・・・・・・ 10

2.2 Comparison of deficiencies and detentions per port state ・・・・・・・・・・・・・・ 11
2.3 Analysis of deficiencies recorded along with PSC actions applied ・・・・・ 12
Appendix Extract from PSC inspection reports ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・ 15
Introduction

This annual report is to offer ship management companies and others concerned with ship
safety management systems analysis of cases where deficiencies related to ISM Code
requirements were recorded as a result of port state control (PSC) inspection, which may be
useful in reviewing a ship safety management system for its improvement.

The analysis was made with information available from reports of PSC inspections that were
carried out in the world in the year 2008 for ships holding an international safety
management certificate issued by ClassNK under the authorization of the flag administration.
Statistic data of such cases in the past several years are also presented to show changes by
calendar year.

It comprises of two chapters. Chapter 1 presents analysis of the cases where deficiencies
related to ISM Code requirements were recorded in the PSC reports showing comparison of
number of such cases per type, age, gross tonnage and flag of ship, number of ships under
the management, etc. of Company and port state. Chapter 2 focuses on the deficiencies
recorded and actions required by port states for their rectification.

In this report, terms defined below are used.

NKSMC ship Ship holding an international safety management certificate issued by

ClassNK
NKDOC company Company holding a Document of Compliance issued by ClassNK
ISM deficiency Deficiency of a safety management system related to a requirement of
ISM Code
ISM deficiency case Case where any ISM deficiencies were recorded in a PSC inspection
report
ISM deficiency ship Ship having a safety management system an ISM deficiency of which
was recorded in a PSC inspection report
ISM deficiency rate* percentage of ISM deficiency ships to the whole NKSMC ships or a
group of NKSMC ships in consideration

* Defining ISM deficiency rate as percentage of ISM deficiency cases to NKSMC ships that subjected to a PSC
inspection is more meaningful. However, as the total number of such NKSMC ships is unknown, the total
number of the whole or a group of NKSMC ships was used instead.

1
Chapter 1 ISM deficiency cases

1.1 Total number and average rate

The total numbers of ISM deficiency cases and the average ISM deficiency rates in the past 4
years are shown in Table 1.1.1. The rate shows increasing tendency since 2005 and became
4.9% in 2008.

Table 1.1.1 Total number and rate of ISM deficiency cases

ISM deficiency NKSMC ISM deficiency
cases ships rate
Year
(A) total No. （A/B）
（B）
2005 81 3799 2.1
2006 121 3895 3.1
2007 142 3993 3.6
2008 202 4148 4.9

1.2 Comparison

1.2.1 Per factors related to ship

(a) Per type of ship

ISM deficiency rate per type of ship is shown in Table 1.2.1(a) and Figure 1.2.1(a).
z The ISM deficiency rate of the other cargo ship and gas carrier increased remarkable.
z The ISM deficiency rate of bulk carrier increased slightly and it of oil tanker decreased
slightly.
z There was no report of ISM deficiency of chemical tanker, passenger & modu in 2008.

Table 1.2.1 (a) ISM deficiency rate per type of ship

No. of ISM No. of ISM deficiency rate （％） （A/B）
deficiency NKSMC ships
Type of ship cases
2008 2008 2005 2006 2007 2008
(A) (B)
Bulk carrier 76 1504 3.4 4.5 4.8 5.1
Other cargo ship 105 1638 2.2 3.2 3.3 6.4
Oil tanker＊ 15 755 0.7 0.6 2.3 2.0
Chemical tanker** 0 41 0.0 13.6 7.0 0
Gas carrier 6 205 0.0 0.0 0.5 2.9
Passenger & MODU 0 5 0.0 0.0 0.0 0
Total 202 4148 2.1 3.1 3.6 4.9
* Including oil/chemical tankers. ** Excluding oil/chemical tanker.

2
 1 4 .0
2005
1 2 .0 2006
ISM 1 0 . 0 2007
2008
defic.
rate 8 .0
(%)
6 .0

4 .0

2 .0

0 .0
B u lk c a r r ie r O th e r c a rg o O il t a n k e r C h e m ic a l G a s c a r r ie r P assenger
s h ip ta n k e r & MODU

Figure 1.2.1(a) ISM deficiency rate per type of ship

(b) Per age of ship
The numbers of ISM deficiency ships per age group of ship in 2005 to 2008 are shown in Table
1.2.1(b) together with the numbers of NKSMC ship and the ISM deficiency rates in Figure
1.2.1(b)-1, and ISM deficiency rate per type and age group of ship in 2008 in Figure 1.2.1(b)-2.
z The older a ship is greater the ISM deficiency rate tends to be. This is attributed to the
increase in the number of deficiencies due to inadequate maintenance of ship including
equipment and fittings with aging of ships.

Table 1.2.1(b) No. of ISM deficiency ships per age group of ship

No. of ISM deficiency cases （A） No. of NKSMC ships （B）

Age
2005 2006 2007 2008 2005 2006 2007 2008
0 - 4 6 13 14 32 991 1109 959 1440
5 - 9 14 25 23 32 1039 974 855 822
10 - 14 14 15 38 57 599 678 966 849
15 - 19 10 21 13 12 365 367 420 355
20 - 24 30 34 27 35 543 501 364 373
25 - 7 13 27 34 237 266 429 309
Total 81 121 142 202 3774 3895 3993 4148

12 2005 2006

10
ISM 2007 2008
8
defic.
rate
6
(A/B)
(%) 4

0
0‐4 5‐9 10‐14 15‐19 20-24 25-

Figure 1.2.1(b) -1 ISM deficiency rate per age group of ship

3
 16.0
Bulk carrier
14.0
ISM Other cargo ship
12.0
defic. Oil tanker
10.0
rate 8.0
(A/B) 6.0
(%) 4.0
2.0
0.0
0‐4 5‐9 10‐14 15‐19 20-24 25-

Figure 1.2.1(b) -2 ISM deficiency rate (%) per ship type and age group of ship

(c) Per gross tonnage of ship

The numbers of ISM deficiency cases per gross-tonnage group of ship in 2005 to 2008 are shown
in Table 1.2.1(c) together with the numbers of NKSMC ship, and the ISM deficiency rates in
Figure 1.2.1(c).
z The ISM deficiency rate of large ships of more than 80,000 gross tonnage has stayed low
around 1 %.

Table 1.2.1(c) No. of ISM deficiency ships per GT group of ship

GT No. of ISM deficiency cases （A） No. NKSMC ships (B)

（ x 1,000） 2005 2006 2007 2008 2005 2006 2007 2008
0 - 10 22 34 34 67 1249 1253 1197 1189
10 - 20 22 29 44 34 745 755 749 782
20 - 30 11 18 24 32 490 490 488 505
30 - 40 11 18 18 39 445 486 533 551
40 - 50 6 11 10 13 258 289 340 380
50 - 60 0 3 4 8 153 156 168 197
60 - 80 5 4 4 4 127 136 141 135
80 - 4 4 4 5 307 330 377 409
Total 81 121 142 202 3774 3895 3993 4148

8 2005

7 2006

6 2007
ISM
defic. 5 2008
rate
4
(A/B)
(%) 3

0
0-10 10-20 20-30 30-40 40-50 50-60 60-80 80-
GT ( x 1,000)
Figure 1.2.1(c) ISM deficiency rate per GT group

4
(d) Per flag of ship
ISM deficiency rate per flag of ship in 2005 to 2008 is shown in Table 1.2.1(d) together with the
numbers of ISM deficiency cases.

Table 1.2.1(d) ISM deficiency rate per flag of ship

2005 2006 2007 2008
Flag
No. Rate No. Rate No. Rate No. Rate
St. Vincent and the
- - - - 1 5.3 4 30.8
Grenadines
Dominica - - - - - - 1 16.7
Cyprus 3 3.5 12 14.8 3 4.1 7 10.3
Malta 2 1.5 2 1.6 2 1.7 10 8.5
Turkey 2 3.5 2 3.7 3 6.0 4 8.3
Greece - - - - - - 3 6.4
Liberia 1 0.5 11 5.8 10 5.2 12 6.2
Philippines 2 2.2 3 3.7 1 1.2 4 6.1
H.K., China 10 4.1 12 4.7 10 4.3 11 4.7
Panama 40 1.9 57 2.7 78 3.4 113 4.7
Marshall Islands 2 5.0 3 5.3 5 8.2 4 4.2
Thailand 7 8.3 5 5.8 5 6.7 3 4.1
Singapore 7 1.7 8 1.9 10 2.3 16 3.7
Japan - - - - 4 3.0 5 3.6
Vanuatu - - - - - - 1 3.6
Malaysia 3 4.3 1 1.7 3 6.4 1 2.3
Bahamas 1 1.5 1 1.2 6 6.8 2 2.0
(Others) 1 - 4 - 1 - 1 -
Total/Average 81 2.1 121 3.1 142 3.6 202 4.9

5
1.2.2 Per factors related to Company
Note: The analysis presented in this section covers only NKSMC ships under the management of NKDOC
Companies but not those issued with DOC by another organization.

(a) Per number of ships under management of Company

ISM deficiency rate per group of Companies corresponding to the number of ships under their
management in 2008 are shown in Table 1.2.2(a) together with ISM deficiency rate.
z The ISM deficiency rate of the group of 1-5 ships is 7.3%, the highest, followed by that of
11-15 ships, 5.3%.
z In 2007 the ISM deficiency rate was highest of the group of 41-50 of ships under the
management. However, in 2008, the rate decreased for the group with larger number of
ships under their management.

Table 1.2.2(a) ISM deficiency rate per number of ships under management of Company

No. of ships No. of No. of ISM

under No. of ISM deficiency NKSMC ships deficiency
management Companies cases rate
(A) (B) (A/B)
1-5 326 54 741 7.3
6 - 10 99 30 752 4.0
11 - 15 35 24 452 5.3
16 - 20 21 17 379 4.5
21 - 30 27 32 674 4.7
31 - 40 11 16 397 4.0
41 - 50 7 14 315 4.4
51 - 6 15 438 3.4
Total 532 202 4148 4.9

8
7
ISM 6
defic.
5
rate
4
(%)
3
2
1
0
1-5 6-10 11-15 16-20 21-30 31-40 41-50 51-
No. of ships under management of Company

Figure 1.2.2(a) ISM deficiency rate per No. of ships under management of Company

6
(b) Per length of Company’s SMS operation
The numbers of ISM deficiency cases and ISM deficiency rate per length of Company’s operation
of ship safety management system in 2008 are shown in Table 1.2.2(b). The length of Company’s
SMS operation, in terms years, is based on the assumption that the Companies started such
operation when it was issued with NKDOC for the first time.
z Although the ISM deficiency rate shows the difference among the groups with 9 years or less
of length of SMS operation, there was no significant difference of the figures among the
groups over 9 years.

Table 1.2.2(b) ISM deficiency rate per length of Company’s SMS operation
No. of No. of
Length ISM deficiency cases NKSMC ships ISM deficiency
No. of
of SMS (A) (B) rate
Companies
operation Total Per Total Per (A/B)
company company
15 4 3 0.75 72 18.0 4.2
14 23 23 1.00 587 25.5 3.9
13 49 36 0.73 732 14.9 4.9
12 82 31 0.38 732 8.9 4.2
11 60 15 0.25 400 6.7 3.8
10 15 7 0.47 136 9.1 5.1
9 11 8 0.73 87 7.9 9.2
8 30 5 0.17 149 5.0 3.4
7 43 21 0.49 287 6.7 7.3
6 18 3 0.17 85 4.7 3.5
5 15 5 0.33 66 4.4 7.6
4 9 2 0.22 48 5.3 4.2
3 14 1 0.07 85 6.1 1.2
2 20 6 0.30 84 4.2 7.1
1 16 1 0.06 43 2.7 2.3
Total 409 167 0.41 3593 8.8 4.6

10
ISM 8
defic.
rate 6
(%) 4
2
0
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Length of Company’s SMS operation

Figure 1.2.2 (b) ISM deficiency rate per length of Company’s SMS operation

7
(c) Per country/region in which Company is located
ISM deficiency rate per country/region in which Companies are located is shown in Table 1.2.2(c) ,
together with the numbers of ISM deficiency cases, and in Figure 1.2.2(c).
z The averaged ISM deficiency rate of ships under the management of Companies located in
Turkey and India has increased to around 9 % from around 4 % in 2007.
z That of ships under the management of Companies located in Thailand has decreased to
5.3% from 9.0 % in 2007 and that in Singapore has decreased to 2.8 % from 4.0 % in 2007.
z Those of ships under the management of those in other countries were equivalent or
increased.
Table 1.2.2(c) ISM deficiency rate per country/region in which company are located
No. of No. of ISM deficiency
No. of ISM deficiency NKSMC ships rate
Country/Region
Companies cases (B) (A/B)
(A)
Turkey 25 10 101 9.9
India 6 3 31 9.7
Germany 4 2 22 9.1
China 29 6 68 8.8
H.K.(China) 21 22 289 7.6
Philippines 21 13 180 7.2
Canada 2 1 14 7.1
Greece 80 21 294 7.1
U. S. A. 3 1 16 6.3
Thailand 5 5 95 5.3
Japan 204 88 1942 4.5
Korea 15 3 88 3.4
Taiwan 11 4 121 3.3
Singapore 55 18 647 2.8
(Others) 51 5 240 2.1
Total 532 202 4148 4.9

1 0 .0
9 .0
8 .0
ISM 7 .0
defic. 6 .0
rate
(%)
5 .0
4 .0
3 .0
2 .0
1 .0
0 .0
Canada

Japan
Turkey

Korea
Greece

U.S.A.

Taiwan
H.K. China
China
India

Singapore
Thailand
Philippines
Germany

Figure 1.2.2(c) ISM deficiency rate per country/region in which company are located

8
1.2.3 Per port state who carried out PSC inspection
The number of ISM deficiency cases per port state who executed PSC is shown in Table 1.2.3.
● The numbers of ISM deficiency cases in Australia, Japan, Italy France and Korea have
increased double in 2008.
● The numbers of ISM deficiency cases in other countries increased slightly to those in
2007 or were equivalent

Table 1.2.3 ISM deficiency case per port state

who executed PSC
No. of ISM deficiency cases
Authority
2005 2006 2007 2008
Australia 29 37 26 48
U.S.A. 5 15 34 34
Japan 14 22 10 19
China 3 14 9 12
Korea 1 11 4 11
Italy 7 4 5 9
Spain - - 2 8
Germany 2- 5 0 6
France 3 2 4 7
U.K. 9 12 7 7
Russia 0 4 6 5
Belgium 4 2 6 4
Poland - - 2 4
Brazil 1 2 1 3
Canada 1 2 5 3
Taiwan - - - 3
India - - - 2
Ireland - - - 2
Iran - - - 2
Singapore 0 2 1 2
Viet Nam - - - 2
Argentina - 4 1 1
Chile - - 3 1
Netherlands 4 2 4 0
Portugal - - 2 0
H.K.(China) 2 8 1 0
(Others) 11 11 10 7
Total 96 159 143 202

9
Chapter 2 ISM deficiencies and PSC actions
2.1 Comparison of ISM deficiencies per ISM Code requirement
The total numbers of ISM deficiencies recorded in PSC reports in 2005 to 2008 and those divided
according to ISM Code requirements, by its sections, are shown in Table 2.1.

Table 2.1 Total No. of ISM deficiencies and distribution per ISM Code requirement

ISM Code requirements (Section No.)

Year Total
1 2 3 4 5 6 7 8 9 10 11 12 13 99*
2005 3 2 4 0 4 11 16 21 21 68 2 3 0 3 158
2006 5 4 9 3 10 44 19 38 11 109 15 6 8 2 283
2007 1 4 1 2 9 26 32 27 20 92 17 7 3 0 241
2008 1 19 14 2 24 27 46 33 30 114 21 6 6 2 345
99* : The ISM Code requirement with which the deficiencies were raised was not specified.

Section Requirements for

1 General (1.2.3 Compliance with mandatory rules, etc.)
2 Safety and environmental protection policy
3 Company responsibilities and authority
4 Designated persons
5 Master’s responsibility and authority
6 Resources and personnel
7 Development of plans for shipboard operations
8 Emergency preparedness
9 Reports and analysis of non-conformities, accidents and hazardous occurrences
10 Maintenance of the ship and equipment
11 Documentation
12 Company verification, review and evaluation
13 Certification and periodical verification

z The total number of ISM deficiencies increased to 345 in 2008 with the increase of ISM
deficiency cases to 202. The number of ISM deficiencies per ISM deficiency case is 1.7
equivalent to it in 2007.
z Percentage of ISM deficiencies related to “10.Maintenance of the ship and equipment” is
33%, and continued largest among those sorted by ISM Code requirements.
z The percentage of ISM deficiencies related to “6.Resources and personnel” and
“8.Emergency preparedness” decreased from 10.8% to 7.8% and from 11.2% to 9.6%
respectively.
z Contrary the percentage of ISM deficiencies related to “7.Development of plans for shipboard
operations” and “9.Reports and analysis of non-conformities, accidents and hazardous
occurrences” are around 13% and 8% respectively, equivalent to them in 2007.

10
2.2 Comparison of deficiencies and detention per port state
The numbers of ISM deficiencies and detentions of ship recorded in PSC reports in 2008 per ISM
Code requirements and port state who executed PSC are shown in Table 2.2.1. Those in the
brackets are the numbers of detention.

Table 2.2.1 No. of ISM deficiencies & detention per port state & ISM Code requirements
ISM Code requirements (Section No.)
Authority Total
1 2 3 4 5 6 7 8 9 10 11 12 13 99*
6 11 1 15 9 11 18 2 1 1 75
Australia
(1) (1) (2) (3) (7)
7 1 3 4 12 7 7 22 5 2 1 1 72
U.S.A.
(1) (2) (1) (3) (7) (2) (16)
1 1 1 1 2 4 3 10 1 24
Japan
(0)
2 1 1 1 2 4 1 8 1 21
Spain
(1) (8) (8)
1 1 1 4 3 1 5 1 1 3 21
Italy
(1) (1) (1) (2) (5)
1 4 1 1 9 1 17
China
(1) (4) (5)
1 1 1 1 3 7 2 16
U.K.
(1) (1) (1) (2) (3) (8)
2 3 3 1 1 4 1 15
France
(2) (1) (2) (5)
2 3 2 5 2 14
Korea
(2) (1) (2) (5)
2 3 3 3 11
Germany
(2) (2) (3) (3) (10)
3 2 1 1 5 6 4 5 23 8 1 59
(Others)
(３) (2) (1) (1) (1) (2) (1) 2 (10) (23)
1 19 14 2 24 27 46 33 30 114 21 6 6 2 345
Total
(1) (7) (5) (1) (8) (7) (5) (8) (4) (42) (0) (2) (2) (0) (92)

( ): Number of detention
99*: The ISM Code requirement by Section with which the deficiencies were raised was not specified.

z The largest number of ISM deficiencies was pointed out at PSC inspections carried out in
Australia, followed by U.S.A., Japan, Spain and Italy.
z As to the number of ISM deficiencies that were taken as grounds for detention of the ship,
U.S.A. was the largest, followed by Germany, U.K., Spain and Australia.
z The detainable ISM deficiencies related to “10.Maintenance of the ship and equipment”
numbered 42. It accounted for 45.6% of all the detainable ones, whereas the percentage of
those related to “5.Master’s responsibility and authority” and “8.Emergency preparedness”
are 8.7% respectively.

11
2.3 Analysis of deficiencies recorded along with PSC actions applied
The distribution of ISM deficiencies recorded in PSC reports in 2008 per ISM Code requirements
by its sections and PSC actions taken is shown in Table 2.3.1 and the distribution of the same by
ISM Code requirement in Figure 2.3.1.

Table 2.3.1 Distribution of ISM deficiencies per ISM Code requirement and PSC Action

PSC Action Codes1)

10 15
Defic. to be rectified by 16 17 18 302) 40 50 70 99 -

before back to US port

Grounds for detention
Defic. to be rectified

Defic. to be rectified

Defic. to be rectified

Defic. to be rectified

Defic. to be rectified

Defic. to be rectified
before departure

within 3 months
ISM Total
Defic. rectified

within 14 days

within 30 days
within 7 days
Code
req.

Unknown
next port

Others
Sect.
No.

1 1 1
2 19 1 2 3 7 4 2
3 14 4 5 5
4 2 1 1
5 24 1 1 3 6 8 4 1
6 27 7 8 7 1 2 2
7 46 2 1 5 23 5 1 7 2
8 33 5 18 8 1 1
9 30 2 4 13 4 2 2 3
10 114 1 18 42 42 3 1 7
11 21 3 4 8 2 1 3
12 6 3 2 1
993) 8 2 1 2 1
GT 08 345 3 1 10 49 130 92 2 4 19 14 21
4) 241 3 3 12 30 82 51 3 12 17 12 16
GT 07
Notes:
1) The Action Codes are those used under Paris MOU, Tokyo MOU, and USCG as follows.
Action Code 10, 15, 16, 17 and 30 are used under Paris MOU, Tokyo MOU and USCG
Action Code 18 and 99 are used under Paris MOU and Tokyo MOU
Action Code 40, 50 and 70 are used under USCG.
2) The number of Action Codes 30 includes Action Code 19 “Rectify major non conformity before departure
(Only for ISM defective items and always with a detainable deficiency)” used under Paris MOU, Vina Del
Mar MOU, etc., not used under Tokyo MOU and USCG.
3) Related ISM Code requirement is not specified.
4) Ground total. The data of 200７ were presented for comparison.

12
 150
2007
No. 100 2008
of
ISM
defic. 50

0
0 10 15 16 17 18 30 40 50 70 99 Blank

Action Code
Figure 2.3.1 Distribution of ISM deficiencies per ISM Code requirement

Analysis with collected ISM deficiency data, which are summarized in Table 2.3.1, and the
descriptions of ISM deficiencies related to the requirements of ISM Code Sections 6 to 10
recorded in PSC inspection reports along with PSC actions are presented below.
For more information an extract from reports of PSC inspections carried out in Australia, China,
Japan, Korea, India, U.S.A., Canada, U.K., France, Italy, Germany, Spain and Belgium in 2008 is
given at the Appendix showing the descriptions of ISM deficiencies together with relevant
deficiencies on ship constructions, equipment, etc.

General
z Among PSC actions, per Action Code, applied to the ISM deficiencies, the number of the
deficiencies related to “Defic. to be rectified within 3 months” was the largest one which
accounted for 37.7%, followed by those related to “Grounds for detention” accounting for
26.7% and those related to “Defic. to be rectified before departure” accounting for 14.2%.
z The detainable deficiencies in 2008 increased to 92 from 51 in 2007. Among the numbers
per ISM Code requirement, “10. Maintenance of ship and equipment” was the largest one,
followed by similar numbers of “5. Master’s responsibility and authority”, “8. Emergency
preparedness”, “2. Safety and environmental protection policy” and “6. Resources and
personnel”.

ISM Code Section 6 Resources and personnel

z The ratio of ISM deficiencies related to ISM Code 6 to the whole has been decreasing to
7.8% in 2008 and the ratio of “Ground for detention” has been decreasing to 25.9%. However,
requirement for personal understanding of contingency performance, operation of safety
equipment and environment protection equipment and operation of GMDSS facilities is
increasing with requirement for quality of ballast water management system in PSC
inspection. These requirements are not only completeness of documents or records but
sometimes extended to observation of personal performance.

ISM Code Section 7 Development of plans for shipboard operations

z The ratio of ISM deficiencies related to ISM Code 7 to the whole was 13.3 % same to that in
2007, but the ratio of “Ground for detention” has been increasing to 10.9%. The main
deficiency related to ISM related deficiency was the landing procedure/equipment of
helicopter on board, followed by the operation of ballast water management system.

13
ISM Code Section 8 Emergency preparedness
z The ratio of ISM deficiencies related to ISM Code 8 to the whole has been decreasing to
9.6% in 2008 and the ratio of “Ground for detention” has been decreasing to 24.2%.
The deficiencies can be divided into the following three cases as same as those in 2007.
(a) The crew were found unfamiliar with the procedures of abandon ship and/or fire
protection and extinguishing, or operation of lifeboats & launching appliances, or a fixed
fire extinguishing system.
(b) Abandon ship drill and fire drills were not carried out as required, or not recorded
properly if carried out, in particular launching and maneuvering of lifeboats at interval of
3 months.
(c) Serious damages or malfunctioning were found on life-saving appliances, fire
extinguishing systems or communication systems*
* e.g. emergency fire pump, fire damper, F.O. tank shut-down system, MF/HF radio
In 2008, there were 2 deficiencies related to the procedure of cargo tank purging operation
which pointed out in relation to ISM Code 8 .

ISM Code Section 9 Reports and analysis of non-conformities, accidents and

hazardous occurrences
z The ratio of ISM deficiencies related to ISM Code 9 to the whole was 8.7% almost same to
that in 2007, but the ration of “Ground for detention” has been decreasing to 13.3%.
Almost deficiencies pointed out were “Malfunction of hull construction, facilities, equipment,
etc., had not been reported to the company as non conformity in accordance with the
company SMS procedure.

ISM Code Section 10 Maintenance of the ship and equipment

z The ratio of ISM deficiencies related to ISM Code 10 to the whole has been decreasing to
33%.
z Among the action codes mentioned above: “Defic. to be rectified within 3 months” decreased
to 36.8% (39% in 2007), “Ground for detention” increased to 36.8% (25% in 2007) and “Defic.
to be rectified before departure” increased to 15.8% (7.6% in 2007 )
z The deficiencies which pointed out as the evidence of ISM deficiency related to maintenance
were that of the life saving appliance and fire fighting equipment, followed by leakage of fuel
oil, lubricating oil, water, etc. of main engine, auxiliary engine, various pumps, malfunction of
oily water separating system, and poor maintenance of hatch cover, weather tight doors,
magnetic compass, navigation lights, etc..
The following equipment/facilities were frequently pointed out due to malfunction or poor
maintenance.
(a) Life saving appliances
Engine of life boat engine, hull of life boat, furnishings of life boat/raft, on-load-release
gear/sling hook, maintenance record of life boat/raft, boat/raft davit, embarkation ladder,
life buoy, fittings, etc.
(b) Fire fighting equipment/facilities
Self closing device of fire door, CO2 fire extinguishing system, fireman’s outfit, hydrant,
fire extinguisher, emergency fire pump, fire damper, etc.

14
Appendix Extract from PSC inspection reports

An extract from reports of PSC inspections carried out in Australia, China, Japan, Korea, India,
U.S.A., Canada, U.K., France, Italy, Germany, Spain and Belgium in 2008 is given at the
Appendix showing below the descriptions of ISM deficiencies together with relevant deficiencies
on ship constructions, equipment, etc.

1. Australia
ISM
Action
Code Deficiencies
Code
Section
16 1. Accommodation stairway & outside doors lashing mechanisms defective
7 99 2. SOLAS training manual does not indicate procedures for re-setting on-load release mechanisms to port
& starboard lifeboats
17 3. Passage plan & passage plan check list do not comply with SOLAS V/34 requirements in regard to
marine environmental measures reference document chapter 2 bridge procedures guide
16 4. Compass error verifications records do not comply with STCW code chapter VIII/34 requirements
30 5. MF/HF functional test on DC power defective
5 18 6. GMDSS functional test failures have not been corrected & reported to company in accordance with ISM
code requirements
15 7. Magnetic compass monkey island large bubble
16 8. Port & starboard sidelights matt black paint defective
16 9. Emergency lighting various lights defective
15 10. Engine control room doors fore & aft lashing mechanisms defective
15 11. Numerous items of flammable material on various flats in engine room
17 12. Engine room aft bilge well high level alarm defective
17 13. Heavy oil service & heavy oil settling tanks gauge glass & tank drain cocks gagged
17 14. Lub oil settling tank gauge glass cock gagged
17 15. GE lub oil storage & GE lub oil purifier tanks gauge glass spring loaded cocks gagged
17 16. Waste oil settling tank spring loaded gauge glass cock gagged
15 17. Waste oil settling tank excess oil residue on walls of tank & in savealls
16 18. Crew messroom hot water supply tap leaking hot water
15 19. Crew & officers shower rooms shower head roses missing
99 20. Officers common toilet, one toilet defective
99 21. Crew messroom & officers recreation room chairs & settees coverings defective
99 22. Escape route from No.6 deck through boatswain forward store to mooring deck not sighted by
recommend IMO signs
12 18 23. Notify company head office of above items 1-22.
17 1. Water Ingress Alarm turned off at time of inspection
17 2. Fire alarm, "switch position" alarm activated.
16 3. Frequency of compass errors not as per STCW.
17 4. Passage plan not including chart 820. Required to be used for intended passage.
99 5. SOLAS training manual not ship specific.
99 6. Firefighting equipment for helicopter landing insufficient.
7 18 7. SMS fails to ensure safe landing procedures for helicopter landing. Deck marked winch only. Fire fighting
equipment not ready for use.
17 8. Bridge engine control alarm panel, buzzer defective.
30 9. MF/HF radio defective.
99 10. S-band radar defective.
9 18 11. SMS falls to ensure Master informs class ,flag and port state of defective essential equipment.
17 12. Open/close direction of operation not marked on numerous fire dampers.
17 13. Liferaft hydrostatic units not correctly rigged. Two liferafts rigged to one unit.
17 14. Liferaft ladders defective. Rotten
17 15. Liferafts gates seized.
30 16. Unable to secure cargo hatches for sea.
99 17. Cargo hatchway cover wheel excessive wear.

15
 30 18. Port lifeboat release system defective.
17 19. Crew toilets and showers in dirty condition.
99 20. Cargo hold dampers excessive corrosion.
17 21. Pilot ladder defective .Ropes rotten, boards split.
9 18 22. SMS fails to ensure previous deficiencies are not repeated on vessel.
10 18 23. SMS fails to ensure hatch maintenance as per MEPC 169(79) .See above evidence.
15 1. Magnetic compass monkey island large bubble noted.
15 2. Compass error verification log does not comply with STCW Code Chapter VIII/34 requirements.
3 99 3. Passage plan pro-forma checklist prepared/issued by company does not comply with SOLAS V/34 in
regard to environmental protection for all sea areas. (99: Notify company head office rectify at discharge
port)
15 4. ITU publication volume VI out of date.
30 5. MF/HF defective.
8 17 6. GMDSS GOC holders not familiar with operational aspects of GMDSS communications equipment.
99 7. Port lifeboat forward hook on-load release locking plunger not engaged fully. (99: Notify company head
office competent assessment/rectification prior to departure.)
15 8. Port lifeboat forward hook mousing guard seized.
17 9. E/R waste oil drain tank spring loaded gauge glass cock gagging device fitted.
17 10. Heavy fuel oil settling & service tanks spring loaded drain cocks gagging devices fitted.
17 11. Cylinder oil measuring tank spring loaded gauge glass cock gagging device fitted.
17 12. E/R bottom plates double bottom tanks spring loaded closers gagged open.
15 13. Crew common toilet, one toilet seat defective.
99 14. Crew common mess room/recreation room chairs/settee coverings defective. (99: Rectify within 2
months)
99 15. Officers mess room deck tiling, defective in way of pantry entrance. (99: Rectify within 2 months)
5 18 16. Master fails to comply with safety management system requirements refer to items listed.
99 17. Ballast tanks ventilator heads float gaskets perished. (99: Notify company head office implement
maintenance program within 0ne month)
30 18. Port lifeboat on-load release arrangement defective.

２．China
ISM
Action
Code Deficiencies
Code
Section
99 1. Cargo securing devices maintenance records not keep on board.
10 18 2. No evidence show the ship keep a good maintenance for equipment on board.
30 3. One set two-way VHF out of work.
30 4. MF/HF installation out of work with emergency source.
17 5. GMDSS station block with waste substance
30 6. Side light (portside and starboard side) holder broken.
30 7. Vent damper for engine room (starboard side) not close.
17 8. Bilge pumps inlet holes, missing operational handle.
17 9. Fuel oil not enough for lifeboats.
17 10. Front door (portside and starboard side) of lifeboat deformation.
17 11. Lifebuoys in bridge wing not in good condition.
17 12. lifebuoys on boat deck - the floating line not connect tightly.
17 13. Starboard side lifeboat hull at portside deformation.
30 14. Emergency fire pump out of work.
17 15. Quick closing devices in engine room out of order.
10 30 16. Ship not keep a good maintenance for ship's equipment.
16 17. Small corrected for chart No.342 not updated.
17 1. Admiralty catalogue of charts and publications - old edition
17 2. Admiralty sailing direction NP30, 32 - old edition
17 3. Last voyage plan from xxx to xxx - Not be verified by Master
17 4. Xxxxx port charts - Not be corrected up-to-date
17 5. Error of spare compass - more than 50 degree
17 6. Spare bulbs for daylight signaling lamp - Not available on board
17 7. Self igniting light on Stbd wing bridge - Not working
17 8. One stern light - Be broken by one vertical plate

16
 17 9. Pressure gauge for A/E starting air bottle - Failure
17 10. Cooling water pipe for emergency fire pump engine - Broken
17 11. One phase of 110V power for emergency generator switchboard - Earth contacted
6 17 12. Engineers - Not familiar with procedure of test for emergency light
17 13. Specific gravity for emergency battery - Not sufficient
6 17 14. Officers - Can not identify N.U.C lights

３．Japan
ISM
Action
Code Deficiencies
Code
Section
17 1. Fire Damper of E/R Ventilator Fan on Bridge deck-Not Closed Tightly
17 2. Officer not familiar with light & shape in the Japan Maritime Safety laws & regulations
17 3. Crew was not able to wear immersion suits properly
17 4. Crew not familiar with mores signal
17 5. Crew unable to wear fireman’s out fit properly
8 18 6. Substantial fire drill; not carried out Evidence: Item 5
6 18 7. Company did not provide sufficient SMS training for the crew Evidence: Item 1,2,3 & 5
10 18 8. Maintenance of the ship & equipment; not carried out correctly Evidence: Item 4
16 1. Emergency lighting stand on "B" deck - damaged
17 2. Anchor light body - cracked
99 3. Air compressor - damaged (crankcase, cylinder liner, con rod, crankshaft, etc. broken)
30 4. Oily water separator - discharge pipe to sea corroded through (3 holes).- oily dirty inside discharge pipe
into sea.
17 5. An emergency light next to S/side life raft - bulb broken
16 6. Life buoy life lines - not non-kinking type
17 7. Emergency fire pump (underneath) - remain oil too much
99 8. Oil record book - not recorded well (disposal of oily bilge and sludge to reception facility)
17 9. Sludge oil not properly kept in tanks (sludge oil remain in 3 drams in engine room)
9 18 10. Chief engineer did not know the procedure of the oily filtering equipment operation, maintenance, also
his tasks and responsibilities of the engine department.
10 18 11. Maintenance of the engine department from ship and company - not recorded of the information and
answer
10 18 12. Maintenance of the engine department - not carried out implemented (Item No. 3, 4, 7 and 9)
17 1. Some charts were not new edition.
7 18 2. The implementation of the Safety Management System on the vessel was not effective for nautical
publication control. Evidence: above mentioned item
99 3. Record of reception facilities for garbage was not written in the column which should be filled out.
17 4. Fire protection window between galley and mess room dose not latch properly.
17 5. Steam was leaked from heating pipe of OWS.
17 6. Oil level detector's sensitivity of OWS unable to adjusted properly & crews can not demonstrate oil level
detector test.
99 7. ISPP Certificate was not onboard.
99 8. Record book of engine parameters: not recorded
2 18 9. Safety and environmental protection policy: not compliance with mandatory rules & regulations
Evidence: Sewage system on board not surveyed and ISPP certificate not issued in accordance with
MARPOL IV.
30 10. Drainage from medical premises (hospital on boat deck), the: drain pipe not connected to sewage
system.

４．Korea
ISM
Action
Code Deficiencies
Code
Section
10 30 1. Ship's SMS regarding maintenance of fire-safety equipment not comply with SOLAS Chap II-2,Reg14,
and no inspection/maintenance records of fire-safety equipment.
6 30 2. Deck officers not familiar with Mf/HF DSC test & DC operation of GMDSS equipment. No record of
MF/HF DSC test over 10 months

17
 11 18 3. Documentation not maintained properly(life saving appliances inspection record missing on May 2008,
No.2 lifeboat launching drill record missing since January 2008)
16 1. Coastal state contact list for SOPEP not up to date.
16 2. Ship's not carried out regularly calibrated by span gas for portable gas detector.
17 3. Breathing apparatus for safety equipment not inspected and tested by an expert at least once a year.
10 18 4. Above the item 2 & 3, ship's instrument not be tested to ensure reliability for safety work..
16 5. International code of signal not up to date.
16 6. IAMSR manual Vol. III not up to date
11 18 7. Ship's not maintained properly relevant manual, code & guideline. (SOLAS, MARPOL & GAS code not up
to date)
16 8. No record compass adjustment since 04-10-2007.
17 9. Limit switch & Fuel oil filling plug for lifeboat P&S stuck.
16 10. 100V insulation in E/R Main Switchboard too low
17 11. CO2 cylinder not inspected since 19-10-2006.
17 12. Emergency fire pump suction pipe penetrate to engine room area without any complementary measures.
(not insulated by A-60)

５．India
ISM
Action
Code Deficiencies
Code
Section
17 1. Boiler flame failure alarm not working
30 2. E/R pipe insulation soaked with oil
30 3. Quick closing valves not in ready condition
7 17 4. Chief engineer does not have standing order
30 5. General condition of the E/R dirty
17 6. E/R bilge full of oil & water. Bilge alarm on high level
30 7. Incinerator found not working
17 8. Garbage segregating not done as per Annex V. All found mixed
30 9. Fire fighting equipment not ready in E/R
7 17 10. No watch keeping schedule posted in Engine control room
17 11. Lots of garbage accumulated in the E/R & on deck
7 30 12. No hot work & enclose space entry form not filled up
17 13. Lifeboat (Port side) damaged due to accident
17 14. FWD arm lifeboat davit damaged
17 15. Port side MOB missing
16. No.4 Shell plating of cargo hold damaged
17 17. Welded pipe in No.4 cargo hold. Class report to be submitted
17 18. Port side navigation light missing
30 19. No emergency supply (DC power) to GMDSS equipment
17 20. ALRS not corrected
17 21. Steering failure alarm not functioning
17 22. Echo sounder not working

６．U.S.A.
ISM
Action
Code Deficiencies
Code
Section
17 1. Vessel bypassed the scrubber high level alarm. Inert Gas System (IGS) had marginal performance
producing between 5% and 8% oxygen in the system before the deck seal. Vessel may not conduct cargo
operations until the IGS is verified in all modes of operation including shutdown and alarm by NK..
17 2. The vessel is to make ready for an expanded Port State Control Exam. in the area of cargo system
safety. The vessel's Certificate of Compliance will be held by the USCG until further notice. The
vessel may not depart port.
17 3. Vessel was found transferring cargo with cargo tanks at oxygen levels between 11% and 18% placing the
vessel and the port in a hazardous condition. MOCC for this cargo is 11%. Vessel's crew did not recognize
the need to cease cargo operation.

18
 10 17 4. Vessel failed to follow the Safety Management System with regard to operation of the IGS procedures to
be followed the SMS Manual by continuing to conduct cargo discharge..
2 17 5. Vessel is equipped with only 1 operable portable oxygen analyzer.
11 17 6. Vessel did not maintain appropriate recording of the oxygen content in the inert gas supply mains during
IGS operations on 8-9 May 2008.
30 1. Vessel's second officer did not follows ships emergency procedures during cargo tank purging operations
when tanks high pressure alarm sounded. 2nd officer left cargo control station to find the chief officer
out on deck. Procedures state vessel's person in charge is to sound alarm and notify facility person in
charge to stop operation.
8 30 2. Vessel dies not have procedures or checklists for shore side supplied cargo tank purging operations.
8 30 3. Vessel did not include purging operations in their pre loading/discharging brief with the facility person in
charge.
8 30 4. During cargo tank purging operations, Master and Chief Officer failed to identify a hazardous condition
and take appropriate actions. Master and Chief Officer allowed the closing of tank hatches without
considering P/V valve capacity compared to the facility's nitrogen output levels. Closing tank hatches is
contrary to standard marine practice and is an usual condition that created an especially hazardous
condition.
5 30 5. Clear Grounds for expanded examination was established on 31 July 2008 when the vessel's tank No.1
Stbd was over pressured and distorted during tank purging operations. PSCOs conducted an expanded
ISM exam with the focus on cargo procedures and crew training. There is objective evidence that the
vessel does not have adequate safety management procedures for cargo tank purging. This is a major
nonconformity, because it poses a serious threat to the vessel and crew and requires immediate
attention. The vessel is detained under the authority granted by SOLAS. Prior to departure from the
port of Houston/Galveston, the Master shall; 1) Conduct a Master's review of the ships cargo tank
purging procedures, 2) Provide recommendation to designated person ashore for immediate changes to
the ships SMS, 3) Immediately implement these changes and conduct training with the ships officers,
4) Provide written attestation from certificate issuing authority that changes to the vessels SMS have
been made, 5) Recommend to the certificate issuing authority that they conduct an external audit of
the SMS
10 30 1. Vessel has not conducted a safety inspection of E/R fire prevention items in accordance with vessel's
SMS document. SMS requires E/R fire prevention checklist to be completed monthly. Fire prevention
checklist was last completed 29 Oct 2008 (one month and 11days ago).
10 30 2. Chief Engineer appears to have inadequate knowledge of SMS requirements. Despite numerous
deficiencies identified in this examination, vessel was unable to provide documentation of non-conformity
report submitted, and the E/R fire prevention checklist done 29 Oct. 2008 and signed by C/E stated all
equipment was in good condition.
17 3. Numerous leaks/pools of fuel were found in E/R from vital systems to include, but not limited to, fuel oil
purifying system piping as evidenced by oil-soaked lagging on hot oil lines and the pooling of oil under all
generators. PSCOs observed the sub-standard practice using over 10 buckets for catching
waste/leaking oil from machinery that were being stored haphazardly throughout the E/R, creating a
safety/fire hazard. Vessel has no records or request for assistance from the company to correct the
state of maintenance as per instruction in SMS.
17 4. PSCO found three fire hoses that were tested and found unserviceable in that they leaked excessively
and one semi-portable foam fire extinguisher with an unserviceable nozzle assembly. The vessel has no
spare fire hoses onboard to replace these hoses. Class is required to attend vessel and survey E/R fire
fighting equipment.

７．Canada
ISM
Action
Code Deficiencies
Code
Section
40 1. NO non return valves in cargo hold bilges & main ejector valve defective - Class is to be advised and
action taken
40 2. Cargo hatches to be identified
17 3. Medical locker to clean & IMO medical guide to provide
17 4. Radar to be repaired
70 5. Water ingress system to repair
17 6. Magnetic compass to clean
17 7. Sailing directions - out of date, to procure prior departure
17 8. Notice to Mariners

19
 17 9. Fire alarm panel + push button system to verify/repair
17 10. Toilet vent., Stbd Bridge Deck - to repair
17 11. All fire doors in accommodation - self closers to adjust
17 12. E/R doors - packing is to be repaired with non-flammable type & doors to be able to close
30 13. E/R ventilation flaps do not work properly
16 14. Life boat ladders to renew
17 15. Life boat swivel hock
17 16. life boat light on deck
17 17. Oxy - Acetylene bottles to be properly stowed
17 18. Packing on manhole door to steering gear
17 19. Steering gear - paint to remove
17 20. Electric hazard on steering gear door
17 21. emerge fire pump evacuation system
17 22. Door to E/R control room + E/R escape - latch to repair
30 23. Quick closing valve in E.R
30 24. OWS - to function properly, frame to be clean
17 25. Accommodation entry doors to make watertight
30 26. Fire line Port side No.1 # cracked
17 27. sprinkler in paint locker
16 28. Pilot ladder ropes
17 29. Galley exhaust
17 30. Fire drill to be demonstrated
8 18 31. Emergency preparedness
10 18 32. Maintenance of ship and equipment

８．U.K.
ISM
Action
Code Deficiencies
Code
Section
30 1. Stbd pilot ladder broken & Port pilot ladder unsafe - Pilot ladder to be provided.
17 2. Freeboard/Draft Marks - Forward, Aft & Midship - partly not readable
17 3. Lifebuoy by Port pilot ladder fitted with light & line - should be light only
17 4. Sign for lifebuoy at Stbd pilot ladder - not correct
17 5. Magnetic compass - not readable, light defective
16 6. Magnetic compass - no deviation curve onboard, Compass should be properly adjusted.
30 7. Various fire doors in E/R & Accommodation either - damaged, not closing properly, some with holes. All
fire doors to overhaul.
17 8. Some sounding pipes in E/R - Self closing devices defective, to free up.
17 9. Dogs to weather tight door to funnel - seized, to free up.
17 10. Food stored on deck in cold room & dry stores - inadequate
17 11. Tin opener in galley - very dirty, to clean
17 12. Hot water to sink in toilet near cargo office - not working
16 13. Corroded step to ladder way, outside accommodation at Deck 3
17 14. Signs for fire extinguishers - some missing
10 18 15. Following failure of Stbd pilot ladder & condition of Port ladder - maintenance records checked, record
indicate ladders satisfactory at last inspection 30 June 2008 & previous monthly inspection, May records
missing
10 18 16. Maintenance records indicate lifebuoys satisfactory at last monthly inspection
10 18 17. Maintenance records for fire doors indicate all satisfactory, 27 June 08
10 18 18. Maintenance records D12-3-4 indicate deviation curve check is satisfactory 19 March 08
7 18 19. Procedures for pilot ladder rigging & compass deviation curves - not stated in safety maintenance
system
2 30 20. Given the number of non conformities noted, the safety & environmental policy has not been maintained
at all levels/onboard ship. Additional audit to be undertaken.

20
９．France
ISM
Action
Code Deficiencies
Code
Section
17 1. Two ropes to be changed
30 2. Damage due to collision with fishing vessel. Repair achieved according class society
17 3. Bottom of the stern plate impact damage to be checked
30 4. Air conditioning system to be repaired.
30 5. Main engine, diesel generators and bilges to be cleaned.
30 6. EPIRB Antenna found broken to be repaired or changed
17 7. When requesting a black out test, Superintendent refused (the ship is not provided with Emergency
Generator).
6 30 8. ISM Manual, instructions, all identification are in English whereas majority of crew members can not speak
English.
17 9. On the OWS 15 ppm equipment one pipe after the 3-way valve could be used as a by-pass, to be
removed.
6 18 10. Several evidences of lack of competence among Officers. (echo sounder, boiler)
10 11. Gangway, unsafe
16 12. Brake shoe to be renewed in the aft winch.
17 13. In the aft mast the safety door to be replaced on the platform.
16 14. Electric wire of antenna for GPS and Navtex not fitted properly between antennas and devices.
17 15. In the aft peak lighting insufficient.
17 16. Galley dirty
17 17. Cold Room temperature -10 degree instead - 18 degree
99 1. A lot of Paint stored in bos’n store (without fix fire fighting system)
17 2. Acetylene rubber pipe worn out
7 99 3. Seamen are painting above sea side without personal life jacket.
30 4. Port side lifeboat clutching system inoperative: no ahead propulsion.
30 5. Stb'd side lifeboat clutching system inoperative: no propulsion
17 6. One mooring rope worn out
17 7. Several lights not working in E/R. In funnel, several covers broken or missing
17 8. Steel parts stowed on Fan compartment floor
8 18 9. 30 minutes needed to perform E/R fire dampers test. Insufficient knowledge of safety system of engine
space (Engine team)
17 10. Steel remote control cable of port side E/R fire damper: worn out & disconnected
99 11. M/E Exhaust manifold lagging damaged in several places
16 12. E/R bilges oily
30 13. DO quantity insufficient in emergency generator fuel tank
17 14. Oil missing in quick closing valve remote control system: not ready for use
17 15. Vessel side shell port side bended at Fr. 13 and same type of damage on stbd side

１０．Italy
ISM
Action
Code Deficiencies
Code
Section
17 1. Endorsement for chief officer GoC and gas specified certificate and for 3rd officer GoC missing.
30 2. No.3 emergency batteries for VHF GMDSS portable radio expired on March 2008.
17 3. Certificate of compliance for VDR annual performance test missing.
16 4. Life saving signals table not up date (helicopter operation missing).
30 5. Batteries for radar transponders expired on 30 April 2008.
6 30 6. Company didn't carry out assessments regarding crew certificates (in relation to flag state endorsement
missing). RO additional audit required.
10 30 7. Ship maintenance plan not properly followed (in relation to the detainable deficiencies). RO additional
audit required.
7 18 8. AIS found switched off in port (according Italian law must be kept always on while ship is berthed).

21
 16 1. International Tonnage certificate: date keel laid to be updated.
17 2. Records of hours of work and rest have to be recorder for all the crew on board (master and chief eng.
missing).
16 3. List of national operational contact points (annex 2) for SOPEP to be updated.
16 4. Galley to be cleaned from the cockroaches.
17 5. All foods have to be placed in cold rooms and must be correctly stored.
16 6. Hydraulic cargo hold closing system no. 2 to be fixed and properly working.
16 7. Oil filtering (15 ppm) with alarm automatic stopping device to be properly maintained.
17 8. Galley's bulkhead (Class A) not in compliance with fire control plan approved by the Class. Society (fire
door missing) Class. Society shall investigate before departure.
30 9. Lifeboat's engine out of order.
17 10. Liferafts (25P) cannot be transferred from side to side at a single open deck level. Classification Society
shall investigate before departure.
2 18 11. Non compliance with Mandatory International Regulations as in EC dir. 2001/106/EC(MEI). Vessel did
not 3 days notice of arrival to the port where it becomes eligible to an Expanded Inspection.
10 18 12. The above mentioned deficiencies denote an improper implementation of maintenance program.
Corrective measures to adopted as necessary.
12 18 13. Company is requested to develop specific directions for maintenance and inspections of the above
mentioned equipment. ISM Internal audit to be carried out within 14 days followed by ABS external
verification within 3 months.

１１．Germany
ISM
Action
Code Deficiencies
Code
Section
1. Emergency escape breathing device - Two EEBDs in E/R without sufficient pressure. All EEBDs to be
checked/replaced when necessary.
2. Fire dampers - Hatch cover of the emergency exit at the top of the funnel; remote release system not
working
3. Protection machines/parts - Pressure gauges of welding gas bottles, stored at Stbd-side accommodation
to be exchanged.
4. MARPOL Annex V - All garbage stored in the steering room to be given ashore.
30 5. Magnetic compass - Magnetic compass not readable from the bridge. Found a bubble inside the
magnetic compass.
6. ITU publication "list of ship stations" and "list of coast stations" expired.
30 7. Nautical publications - Found about 50 expired sailing directions. (next port/voyage unknown by the
master.)
8. Found no squat and keel clearance information on the bridge and inside the voyage plan.
9. Immersion suits - The required two immersion suits fwd. are missing.
10. Electric equipment - A lot of cable conduit pipes corroded with holes. Found some flying wires around
the superstructure.
30 11. Ventilation - Several E/R ventilators on bridge deck corroded with holes. Many basement bolts are
missing.
12. Doors within main vertical zone - Several door frames on bridge and captain's deck corroded with holes.
30 13. Doors - Found some watertight doors on weather deck not closing properly
14. Accommodation ladder - On P & S accommodation ladder one stanchion damaged. On the Stbd side
pilot accommodation ladder some security hooks are missing.
30 15. Fire dampers - Several fire dampers not operable, rubber sealing missing, hard or damaged.
16. Cargo ports - On all booby hatch covers the securing pins missing
17. Safe means of access - The emergency exits not operable from each side.
18. Protection machines/parts - The holders for the spare propeller at the bridge deck are heavily
corroded.
19. Accident prevention - One portable Aluminum ladder is damaged.
20. Personal equipment - Found one SCBA not operable and one with low pressure.
21. Mooring arrangement - One mooring winch aft found with hydro. Leakage.
22. MARPOL Annex I - Many hydraulic jacks for the hatch covers are leaking.
23. Mooring winch - The basement of the midships mooring winch is heavily corroded. It should to be
specially examined and dealt with as found necessary by Class. Dito for the rollers on P & S.
24. Electric equipment - Found one cable box on P & S weather deck corroded with holes, not watertight.

22
 25. Anchoring device - The protection devices for the toothed wheels at the anchor winches corroded with
holes and unsafe.
26. Loading and unloading equipment - The derrick-pin socket and the blocks at the derrick fwd. are heavily
corroded.
27. Galley - Several tiles in galley damaged or missing.
28. Cleanliness - Found cockroaches in the crew pantry.
29. Furnishings - Found damaged chairs in crew messroom and one corrode freezer with holes in the crew
pantry.
30. Table of working hours - Table of shipboard working arrangement missing.
31. Protection of machines/parts - Rubber matt in front of the switchboard in the air condition room
missing.
10 30 32. Maintenance of the ship and equipment - Most of the above mentioned deficiencies indicate a lack of
maintenance. Reasons to be evaluated during an external audit.
3 30 33. Company responsibility and authority - The shore based management control of the maintenance
system is insufficient. An external audit required.
5 30 34. Masters responsibility and authority - The number and nature of the deficiencies indicate a lack of
effective and systematic implementation of the SMS. An external audit required.

１２．Spain
ISM
Action
Code Deficiencies
Code
Section
30 1. Fire damper fan ventilator for E/R, flap gripped
30 2. Port of Gijon chart N.1154 missing. Approaches to Gijon chart not original
30 3. VDR Display several errors and failures
30 4. Notice to Mariners last edition onboard was 10 April 08
17 5. Lifejackets not properly marked, Class must clarify SOLAS type approval
30 6. Parachute Rockets in Bridge store expired
30 7. P&S suction valve in forecastle obstructed pait tins
30 8. Annual performance test VDR missing
30 9. GMDSS unable to transmit from its batteries
10 30 10. Due to several deficiencies of maintenance of ship, internal audit must be carried out.
10 30 11. Distress flares expired
10 30 12. Chart Missing
10 30 13. Nautical publications not updated
30 1. Officers in charge of GMDSS unable to transmit on HF
30 2. Slippery bars for releasing life rafts, totally seized & rusted
30 3. Ventilating closing devices (Mushroom): WBT 1,3,4 (S) & 4,5 (P) found inoperative
6 30 4. Def. about unable operation GMDSS, SMS breakdown
10 30 5. Def. about Liferafts & air pipes, SMS breakdown
2 30 6. More than 100 Liters of paint stored in in Bos’n Store without fixed extinguishing system
30 7. Last Discharge of Plastic on 29 Aug., only a few plastic bottles stowed suspect of illegal discharge
30 8. Bowsing tackles for Lifeboats missing, During abandon drill crew intended to board lifeboat in poop
deck, instead stowed position
8 30 9. Above deficiency item 8, SMS breakdown
2 30 10. Above deficiency item 7, SMS breakdown
8 30 11. Crew unable to perform a satisfactory abandon ship drill (lack immersion suits, EPIRB missing)
30 12. Embarkation ladder for fwd Liferaft not ready for use
30 14. Remote control valve forward dewatering system inoperative
30 15. Forward instructions dewatering system missing
8 30 16. Deficiencies about dewatering system, SMS breakdown
30 13. Embarkation ladders for Lifeboats stowed outside range, not permitting embark
8 30 17. Crew unable to perform a satisfactory fire drill (fireman breathing apparatus inoperative, lack of fire
extinguishers, lack of control, no communication with bridge.)
17 18. CO2 pipes for cargo spaces on deck to be checked and properly maintained.
17 19. Fire training manuals missing in messroom (to be into two working languages on board; (Chinese &
English)
17 20. SOLAS training manual not specific for ship
30 21.No.1 Closed valve in F'cle instead of opened as label instruction required for dewatering system

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 30 22.Ingress water detector system, all Cargo Holds in alarm on (pre. alarms & main alarms): not as required
30 23.All air pipes on Deck must be overhauled and watertight (Attending surveyors believe enough
satisfactory)

１３．Belgium
ISM
Action
Code Deficiencies
Code
Section
1. Air conditioning unit out of order / air exhaust duct broken
2. Fault indication on Panel of dewatering system
30 3. Emergency fire pump – inoperative
4. Deficiency of fire control plan (details were unknown)
5. Fire detection system and control boxes for cargo holds - out of order/still remaining
6. Instructions for operation of CO2 system - missing in CO2 room and near control box for E/R and crew
unaware of operating and testing procedures
30 7. Air bottles of fireman's outfit - found empty
30 8. Ready availability of fire fighting equipment - section valve on fire line - found frozen
9. Lifebuoys - some lifebuoys of unapproved type
10. Crew unaware of use of lifeboat equipment and proper handling of lifeboat
11. Sounding pipes plugs aft. peak tank - missing / fore peak tank closing plugs - damaged
30 12. Abandon ship drills - lack of training
13. Sailing directions outdated / chart catalogue
14. CO2 room ceiling - holed
6 30 15. Resources and personnel - not according SMS
7 30 16. Development of plans for shipboard operations - not according SMS
10 30 17. Maintenance of the ship and equipment - not according SMS

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 For more information on this publication, please contact the
Safety Management Systems Department
1-8-5, Ohnodai, Midori-ku, Chiba 267-0056, Japan
TEL：+81-43-294-5999 FAX：+81-43-294-7206 e-mail: smd@classnk.or.jp
http://www.classnk.or.jp