Annual Report on Port State Control regarding the ISM … Report on Port State Control regarding the...

Annual Report on Port State Control

regarding the ISM Code

Aug. 2004

NIPPON KAIJI KYOKAI

CONTENTS

Introduction

Chapter 1 ISM Non-compliant Ships

1.1 General 2

1.2 Changes made after Mandatory Application of the ISM Code to All Ships 3

1.3 ISM non-compliant ships sorted by Flag State 4

1.4 ISM non-compliant ships sorted by Type of Ship 7

1.5 ISM non-compliant ships sorted by Age of Ship 8

1.6 ISM non-compliant ships sorted by Gross Tonnage 9

1.7 Port State of non-compliant ship 10

Chapter 2 Analysis of deficiencies related to ISM Code

2.1 ISM deficiencies sorted by dominant causes 13

2.2 Number of ISM deficiencies sorted by section of ISM Code for the past 4 years 14

2.3 Number of ISM deficiencies sorted by the States of PSC 15

2.4 Particulars of ISM deficiencies sorted by PSC 17

2.4.1 Japan 18

2.4.2 Hong Kong 18

2.4.3 United Kingdom 19

2.4.4 Belgium 20

2.4.5 Australia 21

2.4.6 U.S.A. 22

2.4.7 China 23

2.4.8 Korea 23

Chapter 3 ISM deficiencies and Action Code

3.1 ISM deficiencies and Action Code 25

3.2 Action Code sorted by sections of ISM Code 26

Chapter 4 Companies managing the ISM non-compliant ships

4.1 Management companies and number of ships 29

4.2 Management companies and years of ISM system operation 30

4.3 Nationalities of companies managing ISM non-compliant ships 31

Chapter 5 Analysis of ISM Non-compliant Ships based on Open Information

5.1 General 32

5.2 ISM non-compliant ships sorted by Flag State 33

5.3 ISM non-compliant ships sorted by PSC 34

5.4 ISM deficiencies classified by ISM Code section 35

Conclusions 38

1

IntroductionThis Annual Report shows you the summaries of reports which were collected by the Head

Office of ClassNK from its Branch and Overseas Offices, Flag States and various ship management companies on current activities of the PSC all over the world, during a year of 2003, from January to December, as well as information revealed on web sites by the PSC about the ships against which actions had been taken by PSC, especially for the ISM Code related deficiencies. ClassNK has compiled this Annual Report in the hope that such information should be helpful to all personnel concerned to deepen their recognition of PSC’s attitude addressing to the ISM Code and for the further improvement of their safety management systems.

Chapter 1 presents various tables and figures that show the number of ships against which action had been taken by PSC for the ISM Code related deficiencies (hereunder referred to as “ISM non-compliant ship”) among the ships classed with NK or ships for which the SMC was issued by NK (hereunder referred to as “NKSMC ship”). The analyses were made for four types of breakdowns, namely under Flag States, Type of Ships, Age of Ships, Gross Tonnage and Port States.

Chapter 2 presents the results of analyses for ISM deficiencies pointed out by PSC. The breakdowns of deficiencies have been analyzed for number of ISM deficiencies per ship, for the requirements referring to each section of the ISM Code, and for those examples that resulted in the detention of ships.

Chapter 3 presents the results of analyses over the actions taken by PSC for ISM deficiencies and their relations to each section of the ISM Code.

Chapter 4 presents the actual situation of companies that are managing ships pointed out with ISM deficiencies including the size of company; and the relation between years of system operation experience and number of ISM non-compliant ships.

Chapter 5 presents the results of various analyses of ISM non-compliant ships based on information gained from the web sites of Tokyo MOU, Paris MOU and USCG.

Note: Definition of key words used in this Report:

PSCO: Port State Control Officer

ISM deficiency: a deficiency related to the requirements of the ISM Code

ISM non-compliant ship: a ship taken action by PSC due to the ISM Code related

deficiencies, i.e. due to non-compliance with the ISM Code.

Taken action by PSC: directives given by PSCO to a ship to take corrective action to rectify an ISM deficiency(non-compliance with the ISM Code) pointed out by PSCO

NKSMC: a ship holding a Safety Management Certificate issued by NK NKDOC: a company holding a Document of Compliance issued by NK

RO: (Recognized Organization) an organization recognized by a Flag State to conduct audits

and issue certificates on its behalf

1

2

Chapter 1 ISM Non-compliant Ships

1.1 General

During one year period from January to December 2003, NK Head Office received reports from its Branch and Overseas Offices, ship management companies, Flag States and other parties, on a total of 249 ISM non-compliant ships, which was an increase of 1.22 times over the 204 ships of 2002. Of the total of 249 ISM non-compliant ships, 172 ships were NKSMC ships; of which 155 ships were classed with NK and 17 ships were classed with other societies. The total number includes 77 ships classed with NK but in possession of SMCs issued by other ROs. The number of ISM non-compliant ships during the past five years sorted by SMC issuing organizations are shown on Table 1.1.1 and Fig. 1.1.1.

Table 1.1.1 ISM non-compliant ships sorted by SMC issuing organization

ISM non-compliant ships 1999 2000 2001 2002 2003

NK classed ships with SMC issued by other RO 8 9 11 53 77

NKSMC ships classed with other society 14 14 5 16 17

NKSMC ships classed with NK 46 45 70 135 155

Total 68 68 86 204 249

Fig.1.1.1 ISM non-compliant ships sorted by SMC issuing organization

The total number of ISM deficiencies for all 251 ISM non-compliant ships were 491 items, which was a steep increase by 1.40 times of 350 items of 2002.

Fig.1.1.2 Total number of ISM deficiencies for the past four years

Number of ISM deficiencies

113

132350

491

46 45

70

135

Number of ISMnon-compliantships

155

2

3

1.2 Changes made after Mandatory Application of the ISM Code to All Ships

The mandatory application of the ISM Code had come into effect in two steps for different types of ships. Phase I application (for oil tanker, chemical tanker, gas carrier, bulk carrier, passenger ship and high speed craft) came into effect on 1 July 1998, and Phase II application (for other cargo ships and MODU) came into effect on 1 July 2002, then the requirements of the ISM Code became to cover all types of ships of 500 G/T and more engaged in international voyages.

Tab. 1.2 Number of ISM non-compliant ships per month in 2003

Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec TotalPhase I

Phase II

Total 2003

Total 2002

In 2003, it had been 1.22 times of the previous year, and its breakdown had been 1.06 times

of 2002 for Phase I ships, and 1.39 times for Phase II ships. The tendency of increase for

“other cargo ships”(Phase II) has been in line with it.

Monthly fluctuation of number of non-compliant ships in 2002 and 2003 are shown in

Fig.1.2.

Fig. 1.2 Number of ISM non-compliant ships per month in 2002-2003

Number of ISMnon-compliantShips

3

4

1.3 ISM non-compliant ships sorted by Flag State

1.3.1 ISM non-compliant ships sorted by Flag State in 2003

Flag states of ISM non-compliant NKSMC ships (172 ships) and percentage of non-compliance are listed in Table 1.3.1 and Fig. 1.3.1. (Percentage of noncompliance = Number of ISM non-compliant ships/ Number of NKSMC ships x 100)

Tab.1.3.1 ISM non-compliant ships sorted by Flag State in 2003

Flag State

No. of ISM

non-compliant

ships(A)

No. of

NKSMC ships(B)

Percentage

(A/B)

Fig.1.3.1 Percentage of non-compliant ships sorted by Flag State 2003 (%)

This graph shows only those Flag States which have 50 and more NKSMC ships.

Percentage of ISMnon-compliantships

4

5

1.3.2 ISM non-compliant ships sorted by Flag State for over four years.

The total number and percentage of ISM non-compliant NKSMC ships sorted by Flag States for over four years are shown in the following Tables (1.3.2 & 1.3.3) and Figures (1.3.2 & 1.3.3). As for the number of ISM non-compliant ships, Panama increased a bit, and Liberia and Turkey showed a sign of decrease, and Singapore, Hong Kong and Japan showed a tendency of increase.

Tab. 1.3.2 Number of ISM non-compliant NKSMC ships

Flag State 2000 2001 2002 2003

Fig.1.3.2 Number of ISM non-compliant NKSMC ships


5

6

Percentage of ISM non-compliant ships are shown in Table 1.3.3. and Fig.1.3.3.

Tab.1.3.3 Percentage of ISM non-compliant ships( )

Fig.1.3.3 Percentage of ISM non-compliant NKSMC ships (%)

This graph shows only those Flag States which have 50 and more NKSMC ships.

Number of ISM

ships

non-compliant

6

77

1.4 ISM non-compliant ships sorted by Type of Ship.

The total number of NKSMC ships (3434 ships) are sorted into various types of ships as shown in Table 1.4.1. Percentage of “other cargo ship” decreased a bit to 42% from 45% of previous year. Percentage of ISM non-compliant ships was 5.0% for all NKSMC ships. Breakdown of this percentage for each type of ships were: other cargo ship 6.8%, gas carrier 5.1%, chemical tanker 5.0%, bulk carrier 4.9%, oil tanker 1.5%. Although the average percentage was 4.4% in the previous year, this figure has still been kept increased up to 5.0% in 2003.

Tab.1.4.1 ISM non-compliant ships sorted by Type of Ship

Percentage (%)

A/B

Type of Ships

No. of ISM

non-compliant

NKSMC ships

(A)

No. of NKSMC

All Ships

(B) 2000 2001 2002 2003

Percentage of

each Ship’s

Type

(B/C)

Bulk Carrier 54 1112 3.9 4.8 4.5 4.9 32

Gas Carrier 8 156 4.9 2.7 2.0 5.1 5

Oil Tanker 10 682 0.5 2.2 3.0 1.5 20

Chemical Tanker 2 40 0.8 0.8 6.7 5.0 1

Other Cargo 98 1438 - 0 5.1 6.8 42

Passenger & HSC 0 6 0 0 0 0 0(0.2)

Total 172 3434(C) 2.2 2.7 4.4 5.0 100

Fig1.4.1 Percentage of NKSMC Ships sorted by Type of Ship (2003)

Gas Carrier 5% Oil Tanker 20%Chemical Tanker 1%

Passenger & HSC 0.2%

Fig. 1.4.2 Percentage of ISM non-compliant ships sorted by Type of Ship

Fig 1.4.2 Percentage of ISM non-compliant ships sorted by Type of Ship

Percentageof ISM non-compliantships (%)

Bulk Carrier 32%Other Cargo 42%

7

88

1.5 ISM non-compliant ships sorted by Age of Ship

The number of ISM non-compliant ships and their percentage of NKSMC ships sorted by Age of Ships for over past four years are shown in Table 1.5.1 and Fig. 1.5.1.

Tab.1.5.1. ISM non-compliant ships of NKSMC ships sorted by Age of Ship

ISM non-compliant ships(A) NKSMC Ships(B) Ship's Age

2000 2001 2002 2003 2000 2001 2002 2003

0 to 4 7 10 27 16 779 848 959 866

5 to 9 9 19 29 39 609 690 952 1039

10 to 14 8 5 15 25 378 342 471 452

15 to 19 17 22 49 39 442 486 510 467

20 to 24 15 13 21 40 306 315 369 424

Fig.1.5.1. Percentage of ISM non-compliant ships of NKSMC ships sorted by Age of Ship (%)

Percentage = A/B x 100(%)

In general, the higher the Age of Ship the higher the percentage of ISM non-compliance, as we have seen in every year. In 2003, this percentage for ships of 10 years and above is exceeding the average of the total and also for ships of 15 years and above shows high percentage. This tendency has remain unchanged during the past four years. Fig. 1.5.2 shows the percentage of ISM non-compliant ships sorted by Age of Ships for three different types of ships. The percentage of ‘Bulk Carrier’ is increasing rapidly if the age is over 15 years, and as for ‘Other Cargo Ship’ it is also increasing from the age of 10 years or more.

Fig. 1.5.2 Percentage of ISM non-compliant ships sorted by Age of Ship

for three types of NKSMC ships

Percentageof ISM non-compliantships ( )

25 and more 3 6 10 13 150 121 186 186

Percentageof ISM non-compliantships (%)

8

99

1.6 ISM non-compliant ships sorted by Gross Tonnage

The number of ISM non-compliant ships and its percentage of NKSMC ships sorted by Gross Tonnage are shown in Table 1.6.1 and Fig. 1.6.1.

Tab.1.6.1 Number of ISM non-compliant ships sorted by Gross Tonnage

ISM Non-compliant ships(A) NKSMC ships(B) G/T

(x 1000) 2000 2001 2002 2003 2000 2001 2002 2003

0 to 10 12 20 70 83 811 826 1239 1228

10 to 20 32 14 26 42 635 677 763 716

20 to 30 6 16 31 13 332 362 396 426

30 to 40 3 8 8 15 318 335 383 366

40 to 50 3 4 5 6 179 209 221 235

50 to 60 0 0 3 0 88 97 108 119

60 to 80 0 10 1 4 92 88 107 102

80 and more 3 3 7 9 209 217 235 242

Fig.1.6.1 Percentage of ISM non-compliant NKSMC ships sorted by Gross Tonnage

for over past four years (%)

Percentage = A/B x 100 (%)

In 2003, the percentage of ISM non-compliant ships has increased with ships of 20,000 G/T and smaller, which is exceeding the average of percentage, and most of them are consisted of “other cargo ships”.

G/T ( x 1000)

Percentageof ISM non-compliantships(%)

9

1010

1.7 Port States of ISM non-compliant ships

Number of ISM non-compliant ships sorted by Port States and six regional areas of the world are shown in Table 1.7.1 and 1.7.2, and Figure 1.7.2. In comparison with the previous year, the number in Asia has still been in a tendency of increasing, of which percentage is more than 50% of the total. Number of ISM non-compliant ships sorted into Port States are as follows.

Tab.1.7.1 Number of ISM non-compliant ships sorted into six regional areas and their percentage.

Percentage

(A B) (%) Area

No. of ISM

non-compliant

ships (A) 2001 2002 2003

Asia 135 33 43 54

Europe 64 40 28 26

Oceania 23 10 15 9

North America 21 10 10 8

South America 5 7 2 2

Russia 1 0 2 1

Total 249 B 100 (%) 100 (%) 100(%)

Fig.1.7.1 Percentage of ships sorted by area

North America 8%

South America 2%

Russia 1%

Asia 54

Oceania 9%

Europe 26%

0 2 0 4 0 6 0 8 0

Vie tnam

P o la nd

Argen tine

P ortuga l

B raz il

F ranc e

Ind ia

S ingapo re

Ita ly

G erm any

C anada

B e lg ium

K o rea

N e the r la nd

U .S .A.

C h ina

U .K .

Aus tra lia

H ong K ong

Japan

Tab.1.7.2 Number of ISM non-compliant ships sorted in Port State (2003)

Fig.1.7.2 Number of ISM non-compliant ships sorted in Port States(2003)

Number of non-compliant ships

10

1111

Number of ISM non-compliant ships sorted by Port States for over four years are shown in Table 1.7.3 and Figure 1.7.3. Increasing tendency in number of ISM non-compliant ships is seen in Japan, Hong Kong, Korea and China in Asian areas, and U.K. and Belgium are increasing in Europe areas.

Tab.1.7.3 Number of ISM non-compliant ships sorted by Port State

Number of ISM non-compliant ships Port State

2000 2001 2002 2003

11

1212

Fig.1.7.3 Number of ISM non-compliant ships sorted by Port State

12

13

13

Chapter 2 Analysis of deficiencies related to the ISM Code

2.1 ISM deficiencies classified by dominant cause

During 2003, the total number of ISM deficiencies reported for all 249 ISM non-compliant ships was 491 items as shown in Table 2.1.1. The average number of deficiencies per ship did increase from 2002 as shown in Fig. 2.1.1.

Tab.2.1.1 Number of ISM deficiencies of ISM non-compliant ships

Number of ISM deficiencies in 2003 sorted by ISM Code sections are shown in Table 2.1.2 and Figure 2.1.2

Year

No. of

deficiency

(A)

Ships

(B)

Rate

(A/B)

2000 113 68 1.66

2001 132 86 1.53

2002 350 204 1.71

2003 491 249 1.97

ISM Code section No of ISM

deficiencies

1.General 1

2.Safety Policy 8

3.Company Responsibilities 12

4.Designated Person 1

5.Master's Responsibility 24

6.Resources and Personnel 60

7.Shipboard Operation 45

8.Emergency Preparedness 96

9.Non-conformity 23

10.Maintenance 159

11.Documentation 43

12.Company Review 13

13.Certification 6

Total 491

Fig. 2.1.1 Number of ISM deficiencies per ship

Tab.2.1.2 Number of ISM deficiencies sorted by ISM Code section 2003

Fig. 2.1.2 Number of ISM deficiencies sorted by ISM Code section


(%)

13

1414

2.2 Number of ISM deficiencies sorted by section of ISM Code for the past four years

Number of ISM deficiencies sorted by ISM Code section for the past four years is shown in the following Tables 2.2.1 and Figures 2.2.1.

Tab.2.2.1 Number of ISM deficiencies sorted by ISM Code section for the past four years

ISM Code section Year

1 2 3 4 5 6 7 8 9 10 11 12 13 Total

2000 5 0 3 3 5 11 7 17 7 34 7 4 10 113

2001 5 0 1 0 10 16 18 27 4 28 19 2 2 132

2002 6 9 1 3 20 53 37 46 18 101 31 10 15 350

2003 1 8 12 1 24 60 45 96 23 159 43 13 6 491

In general, deficiencies relating to Section 8 “Emergency Preparedness” and Section 10 “Maintenance” were increasing rapidly, Section 3 “Company Responsibilities”, Section 6 “Resources and Personnel”, Section 7 “Shipboard Operation” and Section 11 “Documentation” have shown an increasing tendency year by year. During the PSC inspection the matters relating to maintenance of the ship and equipment are addressed with greatest care and their deficiencies are comparatively easy to find out. As the number of deficiencies pointed out increases, the company and ship shall be pointed out of their insufficient control over the maintenance system of SMS, which has not been operating functionally.

Fig.2.2.1 Number of ISM deficiencies sorted by ISM Code section for the past four years


14

1515

2.3 Number of ISM deficiencies sorted by the States of PSC

Number of ISM deficiencies pointed out by respective Port States is shown in Table 2.3.1 and Figure 2.3.1. A feature in 2003 shows the same tendency of increasing as the previous year, of which total number is 1.4 times of 2002. Particularly in Tokyo MOU, a remarkable increases in number from 2002 to 2003 are noted in Japan(77 to 107), Hong Kong(59 to 93), China(15 to 25). On the other hand in Paris MOU, U.K.(9 to 38), Belgium(5 to 38). In the meantime, other Port States such as Poland, Brazil and Vietnam did commence pointing out ISM deficiencies at their PSC inspections.

Tab.2.3.1 Number of ISM deficiencies sorted by the State of PSC (2000-2003)

Port State 2000 2001 2002 2003

15

1616

Fig. 2.3.1 Number of ISM deficiencies sorted by the State of PSC(2001-2003)


16

1717

2.4 Particulars of deficiencies sorted by PSC

Number of ISM deficiencies sorted by the ISM Code sections, and number of pointing out that caused the detention of ship (Action Code 30) sorted also by the ISM Code sections in eight port States are shown in Table 2.4. These eight States are Japan, Hong Kong, U.K., Belgium, Australia, U.S.A., China and Korea, which have pointed out greater number of ISM deficiencies than other States. Actual examples of statements of PSC pointing out deficiencies that caused the detention of ships are also shown under each State.

Tab. 2.4. No. of ISM deficiencies sorted by the ISM Code section each PSC

ISM Code section PSC

ISMDeficiencies

Japan

ISMDeficiencies

Hong Kong

ISMDeficiencies

U.K.

ISMDeficiencies

Belgium

ISMDeficiencies

Australia

ISMDeficiencies

U.S.A.

ISMDeficiencies

China

ISMDeficiencies

Korea

ISMDeficiencies

Other

ISMDeficiencies

Total

ISM Deficiencies: Total number of ISM deficiencies pointed out by PSC officer

Ship detained : Total number of ISM deficiencies pointed out by PSC officer with

Action Code 30.

17

1818

2.4.1 JAPAN

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

ISM Deficiencies

Fig. 2.4.1 ISM Deficiencies that caused ship’s detention, sorted by ISM Code section

ISM Code

section

Action

CodeDeficiencies

–

2.4.2 Hong Kong

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

Ship detained

ISM deficiencies

Fig. 2.4.2 ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section

ISM Code section

ISM Code sections

18

1919

ISM Code

section

Action

CodeDeficiencies

’

“ ”

’

2.4.3 United Kingdom (U.K.)

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

ISM Deficiencies


ISM Code section

19

2020

ISM Code

section Action Code Deficiencies

2.4.4 Belgium

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

ISM deficiencies


ISM Code

section

Action

CodeDeficiencies

–

–

ISM Code section

20

2121

ISM Code

section

Action

CodeDeficiencies

–

2.4.5 Australia.

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

Ship detained

Fig. 2.4.5. ISM Deficiencies that caused a ship’s detention, sorted by ISM Code section

ISM Code

section

Action

CodeDeficiencies

‘

’

–

‘

’ ‘ ’

ISM Code section

21

2222

2.4.6 U.S.A.

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

ISM Deficiencies

ISM Code

section

Action

CodeDeficiencies

…


ISM Code section

22

2323

2.4.7 China

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

Ship detained


ISM Code

section

Action

CodeDeficiencies

’

2.4.8 Republic of Korea

ISM Code

section1 2 3 4 5 6 7 8 9 10 11 12 13 Total

Ship detained


ISM Code section

ISM Code section

23

2424

ISM Code

section

Action

CodeDeficiencies

’

’

24

2525

Chapter 3. ISM deficiencies and Action Code

3.1 ISM deficiencies and Action Code

For all 491 ISM deficiency items the analyses were made to sort them by the ISM Code sections in the vertical column, and by the Action Code on the horizontal line, as shown in Table 3.1.1. 146 items (30% of all deficiency items) were related to detention of the ship (Action Code 30). This number was 1.4 times of the same of 2002 where it counted up to 102 detentions. 75 items (15%) were required correction of the defect before departure of the ship (Action Code 17), 173 items (35%) were required correction within 3 months (Action Code 18), and 22 items (4%) were required correction within 14 days (Action Code 16). The aggregate percentage of the above was 85% of the all deficiency items. Many items relating to Action Code 18 were pointed out about the functional defects of key element of the SMS, and the company was required to carry out the investigation and analysis of the root cause, and establish the measures to prevent recurrence.

Table 3.1.1 ISM deficiencies arranged by matrix of Action Code and ISM Code section

Action Code

0 10 12 15 16 17 18 19 25 30 50 70 99ISM Code

sectionNo. of ISM

deficienciesNo

actionRectified

All

rectified

Next

port14 days

Before

departure

3

month

Rectify

MNCDelay

Detain-

ed

Flag

informd

Class

informdOther

1.General 1 1

2. Policy 8 1 4 1 2

3.Company 12 4 4 4

4. DP 1 1

5. Master 24 1 4 4 3 11 1

6. Resources 60 2 8 19 4 1 21 5

7. Operation 45 1 10 18 3 6 1 6

8.Emergency 96 7 14 29 11 32 3

9. NC Report 23 3 8 2 6 4

10. Maintenance 159 1 3 17 73 13 45 8

11.Documentation 43 4 12 13 3 9 1 1

12. Review 13 4 1 1 1 6

13. Certification 6 1 3 2

Total(2003) 491 1 0 0 0 22 75 174 41 1 146 1 1 30

Total(2002) 350 1 1 0 3 22 52 136 7 0 102 1 7 18

Fig. 3.1.1 Number of ISM deficiencies sorted by Action Code (2002,2003) Action Code

Number of

ISM

deficiencies

25

2626

3.2 Action Code sorted by section of ISM Code

The patterns of Action Codes have been analyzed by the respective section of the ISM Code. Section numbers selected from the ISM Code are 10."Maintenance of the Ship and Equipment”, 6."Resources and Personnel”, 8." Emergency Preparedness”, 7."Development of Plans for Shipboard Operations”, 11."Documentation” and 5."Master’s Responsibility and Authority”.

3.2.1 ISM Code section 10 Maintenance of the ship and equipment

Action

Code0 10 12 15 16 17 18 19 30 50 70 99 Total

2002 1 2 2 3 55 3 30 3 2 101Number of ISM

deficiencies 2003 1 3 17 73 13 45 8 159

The number of deficiencies relating to ISM Code Section 10. was 1.6 times of the previous year, which showed a tendency of high increase. PSC usually take an action to require ‘a correction within 3 months’(72), or ‘detain the ship’(45). In most cases, poor maintenance of the hardware such as fire fighting equipment, life saving appliances, bilge separator and closing appliances which are required by the relevant Conventions are pointed out, and then improper system for maintenance plan and its implementation are pointed out as ISM related deficiencies. This tendency still remains unaltered.

3.2.2 ISM Code section 6 Resources and personnel

Action

Code0 10 12 15 16 17 18 19 25 30 50 70 99 Total

2002 5 9 18 1 15 1 4 53Number of ISM

deficiencies 2003 2 8 19 4 1 21 5 60

The deficiencies relating to training and qualification of crew and its certifications required by STCW are often pointed out, and also lack of the execution and record for familiarization and education on board (OJT), consequently, unsatisfied results of the drill on board due to

Number ofISMdeficiencies

Action Code

Number ofISMdeficiencies

26

2727

insufficient training are pointed out, which causes to detain the ship until it is corrected. Poor understanding of ship’s personnel about SMS are often pointed out, which means that more training or education for SMS to ship’s crew are required both on ship and shore.

3.2.3 ISM Code section 8 Emergency preparedness

Action

Code0 10 12 15 16 17 18 19 30 50 70 99 Total

2002 3 7 15 3 17 2 47

2003 7 14 29 11 32 3 96

In 2003, ISM Code 8 deficiencies are drastically increasing, most of ship’s detention are due to lack of drill plan or program to respond to emergency situations such as fire fighting and life saving drills, insufficient executions of drills at a required interval and lack of familiarization and records of it. At the same time, poor maintenance and record of equipment and machinery used to respond to emergency are pointed out. In this respect, more effective training and education (OJT) for ship’s crew are required. Also company should pay attention to shipboard drills in order to prevent detention of the ship due to above reasons.

3.2.4 ISM Code section 7 Development of plans for shipboard operation

Action

Code0 10 12 15 16 17 18 19 30 50 70 85 99 Total

2002 2 10 17 6 1 1 37

2003 1 10 18 3 6 1 6 45

In 2003, PSC inspections have been covering over wide range of shipboard operations, such as ‘Chart Corrections’ or ‘Old Nautical Publications’ which were not properly corrected, recorded and updated for her next passage, and then lack of proper procedures and records for updating nautical charts and publications are pointed out. On the other hand, PSC pointed out that a plan or instructions for shipboard operations are not properly prepared (ISM Code 7 deficiency) when they found several deficiencies due to poor maintenance of

Action Code

Action Code

Number of ISMdeficiencies


27

2828

equipment for shipboard operations. Therefore, ship and company should pay attention to proper procedures and record of execution for chart correction in addition to several checklists.

3.2.5 ISM Code section 11 Documentation

Action

Code0 10 12 15 16 17 18 19 30 50 55 70 99 Total

2002 4 9 12 2 1 2 30

2003 4 12 13 3 9 1 1 43

Ships are seldom detained due to deficiencies of documentation, but, in case that ‘Checklist had already been signed by checker/senior manager prior to actual checking’, ‘Improper filing of important documents/certificates were pointed out’ or ‘A copy of DOC or SMC was not available on board’, the ship was detained. In addition to incorrect entry on certificates or amendment to documents, failure to show them to PSC inspectors due to wrong filing has been pointed out.

3.2.6 ISM Code section 5 Master’s responsibility and authority

Action

Code0 10 12 15 16 17 18 19 30 50 70 99 Total

2001 1 1 1 1 6 10

2002 3 4 13 20Number of ISM

deficiencies 2003 1 4 4 3 11 1 24

Ships have often been detained due to insufficient conversance of the master with SMS, failure to review the SMS by the master at a regular interval in accordance with ship’s SMS, failure of the master to explain his overriding authority or his responsibility and authority relating to SMS, and failure to identify DPA.

Action Code



28

2929

Chapter 4 Companies managing the ISM Non-compliant ships

With regard to those companies which are managing ships that have ISM non-compliant deficiencies, analysis was made regarding the number of ships under their management and duration of years of SMS operation (counting from the year when the company registered the ISM operation with ClassNK).

4.1 Management companies and number of ships

Table 4.1.1 shows the relation between the number of ISM non-compliant ships and number of ships under management sorted by eight different sizes of companies which have been grouped by the number of ships under their management. For a group which holds 1 to 5 ships, its detailed breakdown is shown. For each group the percentage of ISM non-compliant ships was calculated. As a result, we can see that percentage of non-compliant ships for 1-10 group and 41-50 group are exceeding to the average. The total number of 172 ISM non-compliant ships belong to 135 companies of which 111 companies hold DOC issued by ClassNK. 27 companies had more than one ISM non-compliant ships, and the worst company had 6 ships.

Table 4.1.1 Number of ISM non-compliant ships and size of company

No. of managing

ships

No. of

Managing

company

No. of ISM

non-compliant

NKSMC ships

(A)

NO. of NKSMC

ships

(B)

Percentage (%)

(A/B)

1124 12 124 9.7

280 10 160 6.3

349 9 147 6.1

452 14 208 6.7

535 13 175 7.4

1 5340 58 814 7.1

6 10101 48 752 6.4

11 1539 18 501 3.6

16 2017 9 300 3.0

21 3017 16 432 3.7

31 406 9 218 4.1

41 503 8 125 6.4

50 over 5 7 292 2.1

Total 528 172 3434 5.0

Fig. 4.1.1Percentage of ISM non-compliant ships sorted by size of companies (%)


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4.2 Management company and years of ISM system operation

In Table 4.2.1 the calendar years are arranged vertically, and number of companies to which DOCs were issued by ClassNK (NKDOC company) are listed corresponding to the year (when the company registered the ISM operation with ClassNK). For each year the number of ISM non-compliant ship and the number of ships managed by respective companies are listed, and percentage of ISM non-compliant ships was calculated. The percentage of ISM non-compliant ships shows a tendency that the older the registration of the company, the lower the percentage.

Table 4.2.1 Year of ISM Register of Companies and Non-compliant Ships

Year

No. of NKDOC

company

No. of ISM

non-compliant

ships(A)

No. of NKSMC

ships (B)

Percentage (%)

A/B

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

Total

Fig. 4.2.1 Year of ISM Register of Companies and Percentage of ISM non-compliant ships


Year of ISM register

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4.3 Nationalities of companies managing ISM non-compliant ships

Table 4.3.1 shows the list of nationalities to which the companies that are managing the ISM non-compliant ships have registered. For each nationality the percentage of ISM non-compliant ships was calculated against the total number of NKSMC ships. The percentage of ISM non-compliant ships in China and Taiwan was relatively high compared with other countries, and in Greece and Turkey was exceeding the average, although the number was decreased.

Table 4.3.1 Nationality of companies managing ISM non-compliant ships

Nationality

No. of NKDOC

Company

No. of NKDOC

non-compliant

ships (A)

No. of NKSMC ships

(B)

Percentage

(A/B)

( )

China

Taiwan

Greece

Turkey

Philippines

Japan

Hong Kong

Singapore

Malaysia

Fig. 4.3.1. Percentage of ISM non-compliant ships sorted by the Nationalities(%)

This graph show only those nationalities which have 15 and more NKDOC companies.

Percentage of ISM non-compliantships(%)

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Chapter 5 Analysis of ISM Non-compliant Ships based

on Open Information

5.1 General

This Chapter shows the results of analyses on actions taken by various PSCs for ISM non-compliance, based on the data collected from open information revealed on the web sites of the Tokyo MOU, Paris MOU and USCG. The data includes those ships detained during the period of January to December 2003 collected from the Detention Lists. Therefore, the data of those ships, which were pointed out the ISM non-compliance, but were not detained, are not included in this Chapter. On the other side, the data include those ships, which were detained by a deficiency not related to the ISM Code. The number of ISM non-compliant ships and the number of ISM deficiencies pointed out in the above three areas during the year of 2003 amounted to: 144 ships and 198 items in Tokyo MOU; 393 ships and 708 items in Paris MOU; and 51 ships and 74 items in USCG. In comparison with the previous year the total number of non-compliant ships and total number of deficiencies were decreased

Tab. 5.1 Number of ISM non-compliant ships and ISM deficiencies

ISM non-compliant ships Number of ISM deficiencies Region

2001 2002 2003 2001 2002 2003

Tokyo MOU 81 174 144 93 244 198

Paris MOU 231 422 393 299 693 708

USCG 37 61 51 128 127 74

Fig. 5.1.1 Number of ISM non-compliant ships

Fig. 5.1.2 Number of ISM deficiencies



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5.2 ISM non-compliant ships sorted by Flag States

Number of ISM non-compliant ships under various Flag States sorted by three areas are shown in Table 5.2.1 and Figure 5.2.1.

Tab.5.2.1 ISM non-compliant ships sorted by Flag States

Tokyo MOU Paris MOU USCG Total

Panama 52 40 25 117

St. Vincent and the Grenadines 3 39 3 45

Turkey 0 43 0 43

Malta 3 25 6 34

Cambodia 15 15 1 31

Cyprus 2 22 3 27

Korea, Democratic 7 12 0 19

Belize 13 4 1 18

Georgia 0 18 0 18

Ukraine 1 13 1 15

Fig.5.2.1 ISM non-compliant ships sorted by Flag States

The above Table and Figure show only those Flag States which have 15 and more of

ISM non-compliant ships.

Number of

ISM

non-compliant

ships

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5.3 ISM Non-compliant Ships sorted by Port State

The number of ISM non-compliant ships taken action in five regional areas are shown in Table 5.3.1 and Figure 5.3.1. It increased in Europe area and decreased in North America area.

Tab.5.3.1 ISM non-compliant Ships sorted by Port State

Regions ISM non-compliant ships Percentage ( )

Europe 379 64

Asia 126 21

North America 56 10

Russian 20 4

Oceania 7 1

ISM non-compliant ships sorted by each State of PSC is shown in Fig. 5.3.2

. FFig.5.3.2 ISM non-compliant ships sorted by State of PSC

The above figure shows only those States of PSC which have 10 and more

ISM non-compliant ships.

Europe 64% Asia 21%

North America 10

Russia 4% Oceania 1%

Fig.5.3.1 Percentage of ISM non-compliant ship sorted by PSC areas(%)


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5.4 ISM deficiencies sorted by ISM Code section

Table 5.4.1 shows the number of ISM deficiencies (deficient items) pointed out by PSC in Tokyo MOU, Paris MOU and USCG sorted by sections of the ISM Code.

Tab.5.4.1 ISM deficiencies sorted by PSC areas and ISM Code section

Tokyo Paris USCGISM Code section No.

2001 2002 2003 2001 2002 2003 2001 2002 2003

General 1. 0 0 0 0 0 0 0 1 0

Safety Policy 2. 1 9 10 4 9 46 8 14 14

Company Responsibilities 3. 0 7 5 8 14 24 5 14 19

Designated Person 4. 0 8 6 4 32 48 0 0 1

Master's Responsibility 5. 4 43 23 7 31 64 18 12 4

Resources and Personnel 6. 6 37 46 27 49 60 12 10 4

Shipboard Operation 7. 46 13 8 46 78 28 12 7 1

Emergency Preparedness 8. 16 30 29 86 92 91 5 15 1

Non-conformity 9. 3 7 10 9 20 27 20 11 5

Maintenance 10. 6 37 24 54 183 238 36 27 9

Documentation 11. 6 23 12 35 95 58 7 9 6

Company Review 12. 0 4 19 1 12 16 4 4 6

Certification 13. 5 26 6 18 82 8 1 3 4

Fig.5.4.1 Tokyo MOU: Number of ISM deficiencies sorted by ISM Code section (2001- 2003)

of Incies Number of ISM deficiencies

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3636

Fig.5.4.2 Paris MOU: Number of ISM deficiencies sorted by ISM Code section (2001-2003)

Fig.5.4.3 USCG: Number of ISM deficiencies sorted by ISM Code section (2001-2003)



36

3737

The tendency of pointing out the ISM deficiencies by PSCs of three areas has been analyzed and summarized in percentage to correspond to each section of the ISM Code as shown in Table 5.4.2 and Figure 5.4.4.

Tab 5.4.2 Percentage of ISM deficiencies sorted by ISM Code sections (%)

General 1.

Safety Policy 2.

Company Responsibilities 3.

Designated Person 4.

Master's Responsibility 5.

Resources and Personnel 6.

Shipboard Operation 7.

Emergency Preparedness 8.

Non-conformity 9.

Maintenance 10.

Documentation 11.

Company Review 12.

Certification 13.

In the area of Tokyo MOU, many deficiencies have been pointed out relating to the ISM Code section 6.“Resources and Personnel” and section 8.“Emergency Preparedness”. In the area of Paris MOU, deficiencies relating to section 10.“Maintenance of the Ship and Equipment” were pointed out at higher rate as was in the previous year. Deficiencies relating to section 2. to 6. were pointed out many more than other areas. In the area of USCG a specific feature is seen in pointing out deficiencies relating to section 2. “Safety and Environmental Protection Policy” and section 3. “Company Responsibility and Authority”. These were remarks to point out an insufficient functioning of SMS and that the companies have not been fulfilling their responsibilities to support their ships.

Fig.5.4.4 Percentage of ISM deficiencies sorted by ISM Code section in each areas (%)

(%)

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Conclusions

This report is the 5th “Annual Report on Port State Control regarding the ISM Code” issued by ClassNK, which is summing up the detained ships and deficiencies in relation to ISM Code for all types of the ships who have NK SMC through the year of 2003.

We regret to say that the average percentage of ISM non-compliant ships has increased up to 5 %, and the average deficiency of each ISM non-complaint ship has become about 2 per ship. We can consider that main factors of such increases of detained ships and deficiencies are that ‘Other cargo ships’ (Phase II ships) and their management companies have just started operation for SMS from 1st, July 2002, and have still been not familiar with SMS, which could be seen in the fact that PSC pointed out mainly on ISM Code section 10 ‘Maintenance of the ship and equipment’ and section 8 ‘Emergency Preparedness’ for such ships. In the meantime, viewing a global tendency, such deficiencies related to ISM Code section 10 and 8 are decreasing, but section 3 ‘Company’s responsibilities’ is increasing in Paris MOU.

All data shows that the longer a management under SMS has been implemented, the lower a deficiency of a ship has been pointed out by PSC. It is expected that 6.8 % as the percentage of ISM non-compliant ship for ‘Other cargo ships’ can be decreased down close to 5 % as the average of other specialized ship when ‘Other cargo ships’ and their management companies have more experience for operating ships under their SMS. On the other hand, as for ‘Specialized ships’, it is necessary that ships over 15 years old of age should be concentrated to analyze for searching the root causes of deficiencies and reviewing the system.

The ships and their management company should take prompt actions and countermeasures if the ship is detained or pointed out as major non-conformity due to ISM related deficiencies by PSC. Most of detentions may be released for departure if the relevant repair or maintenance works or successful drills for emergency preparedness can be completed, which, however, it still remains the analysis for root causes for ISM related deficiencies, the review of the system and the educations and trainings for crew, which should be resolved by both the management companies and the ships. Therefore, it is important that the company and the ship should have close communications in between for reporting deficiencies from the ship and their rectification actions as support from the company, and also through the internal audit by the company.

SMS should be implemented not only for the avoidance of major casualties or maritime pollution accidents, but also for the enhancement of actions and decision-makings and support activities by the company and the ship for the restoration in an early stage in order to minimize the damages, which can be achieved by continuous routine works on board, education and training under their SMS. Furthermore, the investigations for root causes of deficiencies, rectification actions, and reviews and analysis for their system should be essential for development of the system.

In the meantime, it is said that ISPS (International Ship and Port Facility Security Code) effective from 1st, July 2004 can be considered as one of the important ISM related shipboard operations. Although it is different requirements of Chapter in SOLAS, it is introduced from ISM Code to ISPS Code for their procedures, compliance, trainings or report of deficiencies, etc.

We wish this report could be helpful for the SMS activities of your company and the ship.

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Key Contacts

Head office

Information Center

Safety Management Systems Department

Nippon Kaiji Kyokai

1-8-5 Ohnodai, Midori-ku, Chiba 267-0056

Tel:+81-43-294-5999 Fax:+81-43-294-7206

E-mail: [email protected]

Regional Offices

South Asia and Oceania Singapore Office

Nippon Kaiji Kyokai

101, Cecil Street,

#21-01 Tong Eng Building,

Singapore, 069533

Tel: +65-62223133,

Fax: +65-62255942


Middle East, East Mediterranean

and Black Sea Piraeus Office

Nippon Kaiji Kyokai

39-41 Akti Posidonos,

Moschato 183 44,

Piraeus, Greece

Tel: +30-1-09420020,

Fax: +30-1-09420079


Europe and Africa London Office

Nippon Kaiji Kyokai

6th Floor, Finsbury Circus House,

12-15 Finsbury Circus,

London, EC2M 7EB,

United Kingdom

Tel: +44-20-7621-0963,

Fax: +44-20-7626-0383


The Americas New York office

Nippon Kaiji Kyokai

One Parker Plaza, 11th Floor

400 Kelby Street, Fort Lee,

N.J. 07024, U.S.A.

Tel: +1-201-944-8021,

Fax: +1-201-944-8183


402

NIPPON KAIJI KYOKAIFor more information on this publication, please contact the

Safety Management Systems Department1-8-5, Ohnodai, Midori-ku, Chiba 267-0056, Japan

TEL +81-43-294-5999 FAX +81-43-294-7206 e-mail: [email protected] http://www.classnk.or.jp

NIPPON KAIJI KYOKAI

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