1 5 5 5 - Bulk Carrier Port State Control. 2 5 Bulk Carriers Bulk Carrier Port State Control - 12/10/2007 1 – “Initial” inspection: - examination of certificates/documents.

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5 - Bulk CarrierPort State Control

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Bulk Carrier Port State Control - 12/10/2007

Bulk Carriers

1 – “Initial” inspection: - examination of certificates/documents - manning control - provisions of STWC 95 - provisions of ILO 147

2 - “More detailed” inspections: - inspection of ship structure and equipment

- operational requirements

3 - “Expanded” inspection: subject to be performed once during a period of 12 months and is conducted on the Bulk Carriers, older than 12 years of age.

Port State Control

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Procedures for more detailed inspection of ship structural requirements

1 - PSCO’s impression of hull maintenance and the general state on deck, the condition of deck fittings and areas of corrosion or pitting, influence the PSCO’s decision.

2 - Significant areas of damage or corrosion, or pitting of plating and associated stiffening affecting seaworthiness may be a ground for detention. It may be requested to check underwater part.

3 - PSCO will pay particular attention to the structural integrity and seaworthiness of Bulk Carriers.

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4 - PSCO’s assessment of the structure of Bulk Carriers is based on the Survey Report File (ESP File) carried on board. This file contains:- Reports of structural surveys,- Structure Condition Evaluation Report,- Thickness Measurement Reports,- ESP Planning

The lack on board of the ESP File is normally considered as a PSC deficiency / ground for detention.

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5 – Based on the examination of the ESP file (or if no ESP file is on board), a more detailed inspection of the structure may be performed by PSCO, who will inspect the hull structure, piping system i.w.o. holds, cofferdams, pipe tunnels, void spaces i.w.o. cargo space, ballast tanks, etc.

6 - PSCO inspects holds’ main structure for any obviously unauthorized repairs.

7 - If applicable, bulk carrier booklet will be verified by PSCO to confirm whether is endorsed for any restriction imposed for carriage of solid bulk cargoes and for loading triangle permanent marking.

8 - PSCO checks that water level alarms in cargo hold are fitted.

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Procedures for expanded inspection of Bulk Carriers

1 - Closing of the watertight doors.

2 - Possible corrosion of deck machinery foundations.

3 - Possible deformation and/or corrosion of hatch covers.

4 - Possible cracks or local corrosion in transverse bulkheads.

5 – Access to the cargo holds.

6 - Verification that the ESP file contains the relevant documents endorsed by the Classification Society.

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PSC Statistics: Transport Canada – Annual Report 2005

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PSC Statistics: Transport Canada – Annual Report 2005

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Paris MOU – Annual Report 2005

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Paris MOU – Annual Report 2005

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USCG – Annual Report 2005

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Tokio MOU – Annual Report 2006

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Detained Bulk Carriers in recent years

The following deficiencies have been found and considered as ground for detention by the PSCO on Bulk Carriers:

ESP FILE MISSING: - Thickness survey measurement survey report.- Structural Condition Evaluation Report.- ESP Planning.

TOP SIDE WB TANKS:- Bulkheads between TSWB Tanks were found cracked and perforated.- The web frames, brackets, floors in TSWB Tanks were found corroded, holed and cracked.- Numerous worn out anodes were found in the TSWB Tanks.

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AFT PEAK TANK:- Engine Room Aft Bulkhead was found corroded and perforated.- Aft Peak found heavy rusted and corroded, 1st platform found corroded and holed.

HATCH COVERS AND HATCH COAMINGS:- Hatch end beam wasted.- Hatch covers damaged.- Cracks on the hatch covers.- Several hatch covers closing devices (cleats) were in poor condition.- Hatch coaming brackets wasted and cracked. - Hatch girder plates were found cracked.

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CARGO HOLDS - Lower stools in cargo hold - bolts and nuts missing on covers.- Cargo hold side shell frames’ brackets damaged and distorted.- Cargo hold hatch opening radius corner fractured.

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Reminder from BV Rules

ESP FlLEThe owner is to supply and maintain an ESP file containing the following documentation (kept for the life time of the ship).

A survey report file:- Reports of structural surveys- Hull Condition Evaluation Report- Thickness Measurement Reports & other info which may identify suspect areas - ESP Survey Plan

The following additional documents is to be made available on board:- Main structural plans of cargo holds and ballast tanks- Previous repair history- Cargo & Ballast history- Ship’s personnel reports on: structural deterioration/defects, leakage on the bulkheads & piping system, condition of coating or corrosion prevention system- Other info that may help to identify suspect & critical structural areas

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PSC – Web Frame in Top Side W.B. Tank

Detention date: 02/10/03

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PSC – Side Shell Longitudinal in Top Side W.B. Tank

Detention date: 02/10/03.

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Detention date: 02/10/03.

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PSC – Sloping Longitudinal in Top Side W.B. Tank


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PSC – Deck Longitudinal in Top Side W.B. Tank


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PSC – Deck Longitudinal in Top Side W.B. Tank


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PCS – Stringer platform in Aft Peak Tank


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PSC – Hatch Coaming Plate and Brackets

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PSC – Hatch Coaming Bracket

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PSC – Hatch Cover Top Plating

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PSC – Hatch Cover Bracket

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PSC – Hatch Cover Fwd Plate

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PSC – Holed Forecastle Deck Plate

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PSC – Leaking from the APT

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CASE STUDY - 1

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30 June 2004

• The ship is placed on Technical Monitoring

21 February 2008

• The ship is placed on the list for Vertical Technical Audit to be carried out in 2008

From 12 February till 29 March 2008

• Class and Statutory Renewal Surveys

13 June 2008

• The ship is detained at Tarragona, Spain.

• Following identification of structural defects iwo Fore Peak Tank, the detention was determined as Class Related by PSC. Visit of EMSA onboard

From 25 June till 01 July 2008

• VTA carried out at Algeciras, Spain

• Significant number of technical deficiencies identified throughout the vessel

• Decision for investigation of the circumstances of the case by DNS

Chronology

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Fore peak tank

VTA findings

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No. 1 SB Top Side Tank

VTA findings

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No. 4 PS Top Side Tank

VTA findings

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Cargo Holds

VTA findings

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Miscellaneous

VTA findings

Duct Keel Hatch Coaming

Hatch Cover Hatch Cover

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Miscellaneous

VTA findings

WBT Air Vents

Damper Electrical

WBT Air Vents

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Miscellaneous

VTA findings

Electrical

Anchor Chain Small Hatches

Accommodation

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Why was the vessel detained less than three months after the class renewal surveys were completed ?

Why was the vessel in such a substandard condition ?

Root Cause Analysis

• BV procedures/instructions not followed by attending surveyors

• Lack of preparation for the surveys

• Means of access not provided

• TM not properly carried out and supervised

• Repair works not properly done

• Lack of supervision during survey

• Lack of maintenance after the surveys

Each of the above factors have been analysed to ascertain their contribution to the substandard condition of the ship

Root cause analysis - Several factors may have contributed to the detention:

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The ship was under technical monitoring and a message was sent to the SSOM, delegate SSOM and attending surveyors, prior to the commencement of surveys, requesting information on ship's maintenance status and for a selection of photographs to be taken and sent to the MO

• The information requested was not provided

The report of the annual survey carried out 6 months before SSH states that the coating in all cargo holds was POOR and that each hold had areas of substantial corrosion in way of cross deck internal structure, sloping and hopper plates, and that indents were found on the inner bottom plating and hopper plates

• The SSH report states that there are NO areas of substantial corrosion existing nor indents and that NO remedial works were carried out

• The survey preparation was clearly insufficient. Important findings on last annual survey report have been ignored by attending surveyors

General context / Survey preparation

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The "survey planning questionnaire" was submitted by the owner 3 weeks after the start of SSH surveys

• It should have been submitted 5 months prior to the commencement of surveys

The survey plan was submitted by the owner 3 weeks after the start of SSH surveys

• It should have been submitted 2 months prior to the commencement of surveys

There was no evidence that the survey plan was prepared in cooperation between the owner and the connecting district

Survey planning

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As per BV Rules, "The renewal survey is not to commence until the survey programme has been agreed".

• The survey started 3 weeks prior to the survey plan being countersigned by the attending surveyor

The meeting on board is reported as having taken place prior to the start of surveys. There is no evidence that the Master attended the meeting and the survey plan could not be discussed as there was no survey plan at that date.

Survey planning

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The required two certified surveyors were not arranged to undertake the SSH surveys from the start of the job.

• The second surveyor began attending the vessel more than 4 weeks after commencement of surveys

Close-up surveys and thickness measurements were not all undertaken at the same time, as required.

• Surveyors time sheets reveal that time spent onboard by both surveyors is clearly insufficient to cover the full extent of close-up surveys required, especially with regards to TST and D/B ballast tanks

Thickness measurements were carried out during 35 days. Surveyors time sheets do not reflect sufficient time onboard in order to cover all the overall surveys, close-up surveys and to take control of the TM process:

• Lead surveyor spent about 44 hours onboard and second surveyor spent only 9 hours onboard during the surveys

Survey organisation

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There is NO evidence that close-up surveys were carried out in areas of the fore peak tank which required the use of staging

• The surveyor informed that he had requested additional staging however this had not been provided by the superintendent. The survey has been credited anyway

The attending surveyors did not provide any list of recommendations and repairs to be carried out during the survey to the owner's representative.

• For long duration surveys, TNS 01 requires that such a list is to be provided, in writing, as early as possible during surveys, to the owners representative who shall countersign the list.

• The surveyor shall keep a copy of the list to be used throughout the survey.

Survey organisation

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It was established that neither surveyor was onboard during the last 4 days of repairs and consequently could not ascertain that the repairs have been performed as required on completion of survey

• Nonetheless, the survey has been fully credited and certificates issued

Two surveyors were required to attend onboard to jointly perform renewal surveys to the extent necessary to agree on actions required to complete the survey

• It has been established that no simultaneous inspections were performed

• Defects identified by second surveyor were reported to the lead surveyor, however he was not let to confirm that same had been repaired.

• It must be reminded that, when 2 surveyors are required, both are to be mutually supportive and have joint responsibility for the surveys.

Survey organisation

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TM of transverse bulkheads in ballast tanks not carried out to the full extent required by the Rules.

• No TM reported for the vertical plating of the collision bulkhead.

• The residual strength analysis carried out by LPO using TM taken at Algeciras recommended structural enhancement due to wastage

Regarding side shell frames, the surveyor endorsed a memorandum stating that requirements of IACS UR S31 were complied with.

• The TM report does not contain the required number of gaugings for side web frames, zones A, B, C & D (5, 5, 3, 5 minimum gaugings per zone), instead only one gauging in each zone is shown.

• The surveyor admitted that he did not properly control these TM requirements

Survey execution – Thickness measurements

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According to the VTA report from Algeciras, the transverse main beams, under deck within cargo holds, were visibly damaged and corroded

• No TM reported for these beams

• Lead surveyor confirmed that no TM were taken in way of these areas

Survey execution – Thickness measurements

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Regarding the areas of side shell frames at cargo hold No. 3 required to be renewed by the attending surveyor in Algeciras:

• These areas have been missed by the attending surveyors during the SSH surveys. Nonetheless, a memorandum stating compliance with UR S31 was endorsed.

• These areas have been reported as having been carried out during intermediate survey, 18 months before.

• In fact, survey at Algeciras identified that no repair work had been done in these areas, in contradiction to INT and SSH survey reports

Regarding the poor corroded condition of the cargo hatch sealing arrangements, as found during VTA:

• The surveyor informed that even though repair work was carried out on all hatches he had only witnessed hose tests of 2 of the cargo hatches

• The SSH survey report stated that all hatches had been hose tested

Survey execution – Structure

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As regards the coating condition of the fore peak ballast tank:

• In June 2003, after completion of the previous SSH, the coating condition was identified as POOR

• In September 2006, the INT survey report identifies the coating condition as POOR

• The ballast tank protection form issued on completion of the SSH survey identifies the coating condition as FAIR.

• There is no technical explanation or description of coating repairs in the SSH report that could justify the upgrade of the coating condition.

• The ASMS report provides a dedicated field for description of any technical justification for upgrading of coating condition. This has not been used by the attending surveyor.

Survey execution – Structure

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The report of the annual survey carried out 6 months before SSH states that the coating in all cargo holds was POOR and that each hold had areas of substantial corrosion in way of cross deck internal structure, sloping and hopper plates, and that indents were found on the inner bottom plating and hopper plates

• The SSH report states that there are NO areas of substantial corrosion existing nor indents and that NO remedial works were carried out

Survey in Algeciras identified an indentation on the bulbous bow of approximately 1.1 m x 0.9 m, 120 mm in depth with internal structure deformation, requiring repair

• Memo endorsed by the surveyor stating "no necessary for repairs"

Survey execution – Findings / Reporting

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It has been established that the SSOM has been at least once onboard during the surveys, yet the evident poor condition of the vessel did not prompt any particular monitoring nor subsequent follow-up visit from his side.

• No information on the ship's condition was forwarded to the CD/CM/MO in the course of the survey

• The BV supporting structure has not been used. An action towards the owner at the time of the survey could have prevented this CR detention

No PR17 report was issued even though many SMS shortcomings were evident

Survey monitoring and follow up

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CASE STUDY - 2

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From 18 Dec. 2007 to 20 January 2008

• Class and Statutory Renewal Surveys

13 July 2008

• The ship is detained at Cardiff, UK.

• Following identification of structural defects on Cargo Hatch cleat brackets severely wasted, ship maintenance and equipment. Visit of EMSA onboard on 14/07/08

From 10 July till 24 July 2008

• VTA carried out at Cardiff, UK

• Significant number of technical deficiencies identified throughout the vessel

• Detention was considered as class related

Chronology

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Following e-mail received from MCA on 15/07/08:

• Thank you for your survey report received yesterday. To date 183 new cleat brackets have been fitted following the detention 09/07/08. From what the ships crew tell me these new cleat brackets were placed onboard during dry dock January 2008. The point of the Class responsibility is that these long term deficiencies should have been rectified before the vessel sailed, and were not. We cannot accept that they were placed onboard for the crew to carry out during operations, given the extensive wastage which had greatly reduced their securing ability.

Chronology

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The auditor's List of Findings identified 103 deficiencies, of which many were of a serious nature

• Representative photographs are shown in next slides

"Sample of the most serious findings:

• All ER fan housing intake louvres to repair.

• Corrosion to external bulkhead of oxygen room to be repaired

• Corroded areas of hatch cover stiffening to definitively repaired.

• All hatch cover stiffening to be ultrasonically thickness gauged and repaired as required.

• All hold access house vent louvres to be repaired.

• All hatch coaming face plates to be de-scaled, ultrasonically thickness gauged and repaired as required.

• All hatch cover closing stops to be de-scaled and repaired as required.

• All DB ballast tanks adjacent to fuel tanks to be de-scaled, ultrasonically gauged and repaired in area 1m from fuel tank bulkhead.

VTA findings

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The vessel has left UK on 25/07/08 proceeded to XXX for definitive repairs .

She arrived shipyard on 06/09/08 for definitive repairs

A follow-up VSA has been carried out on 10/10/08, following comments made by the auditor:

Repairs to hatch coamings, coaming tops & cover panels appear complete. Repairs to DB’s & tanktops are almost complete. Blasting of external areas of hatch cover panels and various other areas on deck in progress making definitive examination difficult. Embarkation ladders midships & aft renewed along with various sections of hold access ladders.

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Surveys have been completed on 20/10/08 and following repairs have been carried out:

AA- Hatch Coamings no.1 to 7:

a- Fw'd and Aft transverse plates-partly,

b- Top plates - stbd and port,

c- hatch coaming stays - partly,

BB- Hatch Covers: a- Stiffeners on No.1 and No.7 - partly, b- Bottom plate on No.4 - partly, c- Side plate on No.6 - partly,

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Surveys have been completed on 20/10/08 and following repairs have been carried out:

AA- Hatch Coamings no.1 to 7:

a- Fw'd and Aft transverse plates-partly,

b- Top plates - stbd and port,

c- hatch coaming stays - partly,

BB- Hatch Covers: a- Stiffeners on No.1 and No.7 - partly, b- Bottom plate on No.4 - partly, c- Side plate on No.6 - partly,

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CC- Tanktop (innerbottom) plating:a- No.3 cargo hold - partly,b- No.5 cargo hold - partly,c- No.6 cargo hold - partly,d- No.7 cargo hold - partly,

DD- Double Bottom Tanks:a- No.6 WBT:

Aft wt bulkhead at fr. 68 (P&S) - partly,Fw'd wt bulkhead at fr.39 (P&S) - partly

b- No.2 FOT:Long'l o.t. bulkhead and attached long'l stiffeners between fr.s no:137-

171 (P&S),

c- No.3 FOT:Long'l o.t. bulkhead and attached long'l stiffeners between fr.s no:102-

137 (P&S),

d- No.4 FOT:Long'l o.t. bulkhead and attached long'l stiffeners between fr.s no:68-102 (P&S),

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e- No.3 WBT:plate floor - partly at fr.189 (S)

f- No.4 WBT:plate floors - partly at fr.s no.142(S), 145(S), 148(S), 151(S),

154(S), 157(S), 160(S), 166(S),

g- No.5 WBT:plate floors - partly at fr.s no. 73(S), 76(S), 79(S), 82(S), 85(P&S),

88(P&S), 91(S), 94(S), 97(P&S), 100(P&S), 102(S), 105(P&S), 108(S), 111(S), 114(P&S), 117(S), 120(P&S), 123(P&S), 126(P&S), 129(P&S),

132(P&S), 135(S),

h- No.6 WBT:plate floors - partly at fr.s no. 42(P&S), 45(S), 54(S), 63(S),

66(P&S)

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CONCLUSION

BULK CARRIERS ARE HIGHLY TARGETED SHIPS BY PORT STATE CONTROL

STRUCTURAL CONDITION IS CURRENTLY SURVEYED BY PSC WHEN ATTENDING ON

BOARD A BULK CARRIER

STRUCTURAL DEFICIENCIES ARE OFTEN CONSIDERED AS A GROUND FOR DETENTION

1 5 5 5 - Bulk Carrier Port State Control. 2 5 Bulk Carriers Bulk Carrier Port State Control - 12/10/2007 1 – “Initial” inspection: - examination of certificates/documents.

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