introduction to acs and the issues and concerns on psc

Dedicated to safe ships and clean seasDedicated to safe ships and clean seasDedicated to safe ships and clean seas

Introduction to ACS and the issues

and concerns on PSC inspections for

exchanging views with Tokyo MOU

Dedicated to safe ships and clean seas

Tokyo MOU Open Forum

in Majuro, Marshall Islands

14 October 2019

Dedicated to safe ships and clean seasDedicated to safe ships and clean seas

Contents

1. Introduction to ACS

2. ACS Activities

3. PSC Related Activities

4. Issue and concerns on PSC

Inspections


Introduction to ACS

Brief History of ACS

➢ 1993~: Asian Classification Societies

Annual executive meetings among CCS, IRS,

KR and NK (2002~ BKI and VR joined as observers)

➢ 2010: Association of Asian Classification Societies

Formalized by adopting Charter with CCS, IRS,

KR, NK, BKI and VR

➢ 2017.11: The Ship Classification Malaysia ( SCM ) became a

new member of the Association.

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Dedicated to safe ships and clean seasDedicated to safe ships and clean seasDedicated to safe ships and clean seas 4

Introduction to ACS


Purpose and Aims

➢ To promote ship safety at sea and protection of

the marine environment and, in cooperation

with other partners in the maritime community

➢ To pursue improvement of ACS Members’

performance and their technical contributions

to the international maritime community based

on their accumulated technical knowledge and

expertise.

Introduction to ACS


Working Group

(Quality)

Technical Management Group

(TMG)

Working Group

(Safety)

Working Group

(Environment)

Secretariat

(SO)

Executive

Committee (EC)

Project Teams (PTs)

Project Teams (PTs)

Introduction to ACS


ACS Activities

Monitoring of IMO conventions and regulations

ACS WG/Safety and WG/Environment keep monitor the

development of the IMO conventions and regulations on

maritime safety and clean environment.

They carry out the pre-IMO meeting activities to identify

the IMO and other international related issues of ACS’s

concerns for consideration of any necessary ACS actions

prior to the meetings.


and the post-IMO meeting activities to monitor

and review the result of the IMO and other international

meetings on the identified issues of ACS’s concerns for

necessary course of actions.

Develop the common understanding/positions

based on the proposal of WG chairman and

members/TMG chairman and members/Technical

officer/with the ASA/ASEF experts.

ACS Activities


ACS Guidelines

Development of the guidelines on international

regulations, e.g., SEEMP and EEOI,

Procurement & Installation of , Ballast water

treatment and Ship recycling, IGF/IGC Code,

etc. for the benefit of Asian maritime

communities. The guidelines developed are

uploaded on the ACS website.

http://asiancs.org/html/dh/lists/guide

ACS Activities

http://asiancs.org/html/dh/lists/guide


ACS Activities

No Guidelines Date

12Questionnaire to Address the Top 5 Detainable Deficiencies in the ACSfleet

2019-07-05

11 ACS Guidelines for Ships fuelled by LNG on domestic voyages 2018-12-14

10 ACS Guidelines for Port State Control Detention Prevention 2018-08-01

9 ACS Guidelines for SCR Systems and Reductant Agent Supply 2018-06-29

8 Guidance on Ship Energy Efficiency Management Plan(SEEMP) 2018-06-05

7Guidance to Survey/Auditor for Checking Crews Familiarity with Shipboard Operations

2018-05-25

6 Comparative Analysis between IGF Code and IGC Code 2017-07-31

5 ACS Guideline for SOX Emissions Compliance Plan (SECP) 2017-05-02

4 Updated Common MD, SDoc Format 2016-01-28

3ACS Guidelines on Procurement and Installation of Ballast Water Management System

2018-10-12

2 Guidelines for Control and Measurement of Noises on Board Ships 2014-12-31

1 Guidance on Energy Efficiency Operational Indicator (EEOI) 2014-10-10


Tokyo MOU and Indian Ocean MOU

Active participation in the PSC MOU Open

forums, i.e. Tokyo MOU and Indian Ocean MOU,

to provide support and contribution to the MOU’s

work for promoting maritime safety, and

eliminating sub-standard ships in the world, in

particular in the Asian region.

ACS Activities


A-3(ASA, ASEF, ACS) Activities

ACS maintains good & close relations with:

⚫ ASA (Asian shipowners Association ) and

⚫ ASEF (Active Shipbuilding Experts’ Federation) by

▪ Participating in each other’s annual meetings since

2010.

▪ Providing technical presentation and exchanging

communications on the international regulatory and

technical matters.

ACS Activities


⚫ A-3 Experts Meeting

Annual experts meeting to discuss on the marine

technical field issues on the following areas;

i) IMO and other international topics concerned with

Asian maritime industry organizations; and,

ii) Topics and issues raised in any meeting of the

ACS/ASA/ASEF that may require Asian maritime

industries’ common understanding.

⚫ A-3 Executive Meeting

Annual A-3 Executive Meeting is being held together at

the ACS Executive Committee Meeting.

ACS Activities


Way Forward

⚫ To enhance the ACS Activities towards better

Regulations to be developed at IMO in

collaboration with Asian partners, i.e. ASA and

ASEF.

⚫ To provide better technical support to Asian flag

states and governmental bodies with a view to

promoting ship safety, marine environment

friendliness and sustainability.

ACS Activities


PSC Related Activities

PSC Report (http://asiancs.org/html/dh/views/310)

- To collect and compile the PSC records of the

ACS member societies in a common format and

upload it on the ACS website to build

awareness of the PSC deficiencies as well as to

improve the PSC performance of the Asian

classification Societies’ registered vessels.

- The third part of this Report contains various

example pictures of categorized PSC

deficiencies for easy reference of the users of

this Report.



PSC Guidelines for Detention Prevention

➢ACS Guidelines No.10 “Guidelines for Port State

Control Detention Prevention”

▪ Good Practices by Seafarers, by Companies

▪ Sample Checklist

▪ Frequently Observed Detainable Deficiencies

➢ACS Guidelines no 12: Questionnaire to Address the

Top 5 Detainable Deficiencies in the ACS Fleet

▪ Deficiencies related to Fire Safety, Life Saving Appliance, ISM

Code, Safe of navigation, Emergency systems

▪ Questionnaire from Previous CIC


Discussion on Issues raised by ACS at previous forums

1. Providing/publishing details of deficiencies found during inspections

- See TMOU Website and also EQUASIS Website

ACS Comments

– Attribution of deficiency to the correct/responsible/applicable RO and not the Classification society

– Prompt display of such deficiency attributable to RO on the Tokyo MoU website (if possible, date of publication of the PSC inspection also can be provided)

– Upload of Scan copy of the Forms by PSCO in case of detention of the Ship so that the RO can find out the exact issue and undertake prompt action

– More options to search for PSC inspections (e.g. by GT, DWT, Date of Build etc.)

– Options to download the PSC Inspection data in excel format for statistical analysis

Issues and concerns on PSC inspections



2. Providing information on new items being added in the

PSC database on the web-site

- If any such information is added, it will be informed on the public

website

ACS Comments

- No further comments. ACS thanks Tokyo MoU for the information



3. Maintaining up-to-date list of contact for ROs (ACS

societies) for notification of detention

- Updated as current procedures

ACS Comments

- No further comments. ACS thanks Tokyo MoU for the information



4. Making guidelines for inspection of ships below convention size available for ACS societies

- Guidance is currently in development at IMO and is continuing to be progressed

ACS Comments

Para. 1.6 of the Procedures for Port State Control 2017 provides some idea of how the PSCO should undertake inspection of such ships. Para. 1.6.2 quotes:

Quote

To the extent a relevant instrument is not applicable to a ship below convention size, the PSCO's task should be to assess whether the ship is of an acceptable standard in regard to safety and the environment. In making that assessment, the PSCO should take due account of such factors as the length and nature of the intended voyage or service, the size and type of the ship, the equipment provided and the nature of the cargo

Unquote:

The above marked statement is subject to interpretation and it would be useful if the MoU can provide some more guidance. Any discussion on the above topic at III 6 could not be identified by ACS.

Note for TMG: It would be beneficial if ACS members can share any particular cases related to the above issue. Otherwise, the above may not be very effective.

(No such cases were shared by members within WG/Safety)



5. Treatment of cases where additional number of

equipment/ appliances over and above the convention/

flag state requirements may be not in operative condition

but, if such equipment is identified and marked as not to

be used and the crew is made aware that the equipment

is inoperative, it should not be considered as a

deficiency

- This matter is implemented in the Procedures of PSC 2017 (A.1119

(30), Appendix 6.11), and Tokyo MOU already follows this procedure

Note for TMG: ACS members could share relevant cases. It may then be more fruitful to discuss with Tokyo MoU.(No such cases were shared by members within WG/Safety)



6. Development of guidance for dealing with cases of

unsatisfactory drills caused by language/communication

problem between PSCO and crew

- Please provide specific examples to enable investigation to take place

Note for TMG: ACS members could share relevant cases. It may then be more fruitful to discuss with Tokyo MoU. (No such cases were shared by members within WG/Safety)



Opinions and Issues for Discussion at the 2019 Open ForumACS Comments

• It will be helpful if the MoU can share information as to how many “Letters of Warning” have been issued so far on early checks it has conducted for the 2020 Sulphur Cap? Also what are the common deficiencies observed with respect to these inspections so that ACS members can inform their respective shipowners. Any other noteworthy experiences/observations can also be shared preferably on the MoU website for the benefit of the Shipping community.

• As per BWM.2/Circ.62 - Guidance on contingency measures under the BWM Convention; Port state reports the information on the use of contingency measures in accordance with the Experience Building Phase (EBP) of the BWM Convention. It may be useful to share this information the MoU website

• The recent guidance regarding EGCS failures (MEPC.1/Circ.883) requires that any EGCS malfunction that lasts more than one hour or repetitive malfunctions should be reported to the flag and port state authority along with an explanation of the steps the ship operator is taking to address the failure. Such information along with cause and actions taken can be share by the MoU for the guidance and knowledge of shipping companies.

• ACS observes that sometimes a specific deficiency is pointed by a PSCO only in specific ports repeatedly, although the same matter is not treated as deficiency by PSCO in other ports. e.g. compliance of fire detectors with distance requirements in FSS code in machinery space is not treated as deficiency in other ports, but some PSCOs of a particular port point out this matter as deficiency repeatedly (Note for TMG: the MoU may request such cases to be presented by ACS)ACS requests that consistency be maintained by PSCOs in such matters for which guidance/training should be provided to them.



Opinions and Issues for Discussion at the 2019 Open

Forum



Opinions and Issues for Discussion at the 2019 Open

Forum

To be filled…

Dedicated to safe ships and clean seasDedicated to safe ships and clean seas 27

Thank you for your kind

attention !

ACS website:

http://www.asiancs.org

introduction to acs and the issues and concerns on psc

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