18/03/2011

Understanding Oil Company vetting systems, Self- inspections

and managing SIRE report comments to reduce inspector
observations and deliver continuous improvement.

Presenter.
David Savage
wingfieldmarine@gmail.com

Domestic and General Information

Domestic Arrangements

Emergency fire escape

Toilets

Smoking

Mobil phones

Lunch and coffee breaks

Materials

Assessment

Self-introductions

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Objectives and scope of this course

Why do Oil Companies inspect tankers?

A brief history of why SIRE was introduced.

Risk Management and spot chartering

How oil companies look at the risks involved with spot

chartering

The self- inspection walk round.

Thinking like an inspector.

Dealing with inspectors.

How to get the outcome you want

Additional Materials (1)

ABS Guide for IGS for ballast tanks

OCIMF Annual Report (2010)

OCIMF 2011 VIQ Rev 0

OCIMF Paper on Entry into Enclosed Spaces

OCIMF/LR Study re Emergency Towing Off Pennants

OCIMF paper Hazards associated with use of additional

moorings
OCIMF SIRE Brochure (2004)
OCIMF and Industry paper on Oily Water Separators
BP High Risk Observations List
ExxonMobil Marine Environment Quality and Safety
Criteria Booklet (2010)
ConocoPhillips Marine Vetting and Audit Criteria

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Additional Materials (2)

IMO Guidelines on Seafarers Working Hours re MLC

2006
IMO MEPC.1/Circ 736 (Nov 2010) Oil Record Book
Guidance
IMO Current Awareness Bulletin (Nov/Dec 2010 Eds)
IMO Annual Testing requirements for AIS (MSC Circ
1252)
Danish Government Mooring accident report
Draeger Tubes Handbook
LR MSC88 Report
IMO Near-Miss reporting
IOPPC Form B
OCIMF On-line Crew Matrix Guidance

Additional Materials (3)

Intertanko Inspector Performance feedback

AMSA Marine Notice on MSDS
On-load release gear video clip
Lifeboat premature release video clip
UKMCA Human Element
Aide Memoire on Paris MOU 2011 Inspection
Regime
UK MAIB Report on CFL Performer Grounding
(ECDIS assisted grounding)

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1. Knowing the Rules

Remember
Knowledge is Power!

Documents you
must be familiar
with..

SOLAS
Fire Safety Systems Code
Life Saving Appliance Code
MARPOL
STCW
ISGOTT
The OCIMF SIRE VIQ

How much do YOU know?

Lets find out with a short quiz...

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2.

The history of OCIMF, why SIRE

was needed, Risk Management and
Spot Chartering

A Voice for Safety

Awareness of the threat of massive oil

pollution from tankers

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March 1978

Major Oil Spills since 1967

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The impact of OPA 90

Liability and Compensation Applying the Polluter Pays
Principle
OPA 90 is based on a polluter pays principle holding the
owner/operator strictly liable. It establishes limitations of
liability at higher levels than international conventions and
removes limitation protection if the incident was caused
by gross negligence, wilful misconduct or violations of
Federal safety, construction or operating regulations by
the responsible party. In normal circumstances the owner
will respond to the spill and his insurance ($1 billion cover for
pollution is typical) will fund the response. This framework
ensures that the shipowner takes on the major proportion
of the liability risk and this structure has been instrumental in
discouraging low quality operators from trading in the
US.

The immediate aftermath following

the introduction of OPA 90
1. Introduction of Oil Co Vetting and Inspection
Departments
2. Excessive inspections of the same tanker by
different Oil Cos at the same time
3. Inability of individual Oil Cos to inspect ALL
tankers of potential interest
4. Inability to maintain inspection intervals within
a reasonable time frame
5. Excessive burden on tanker officers and
ratings

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1991-1993 Timeline
1991

Full scale Oil Co Inspections commence

1991-2

Severe shortcomings in the Go it alone

approach recognised at OCIMF

1992

Report sharing concept agreed among

OCIMF Members. Development of SIRE
commenced

1993

17 Nov. First inspection report submitted

to SIRE

The Demise of The Grey Fleet

Tanker Industry Total:

Approx 8,500 vessels
8000
SIRE
inspections
NOT
conducted

7000

7000

6000

6000

5000

5000

4000
4000
3000
3000
2000
2000

2002

2003

2004

2005

2006

2007

2008

2010

1000

0
SIRE Database

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So you think that oil company

vetting superintendents are too
demanding. Consider this...
For a Vetting Superintendent
every vetting decision
is a
career decision!
For this reason, Oil Company Charterers are extremely
careful to ensure that all aspects of potential vessels are
carefully reviewed

Some of the OCIMF Members

who Submit SIRE Reports

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The Oil Company Vetting Dept

Risk Assessment Teams
Mathematical models
Automated Computer Systems

What do they look at?

The Three Categories of Shipping Risk

1. Owned Vessels
Least risk
Greatest control
2. Time Chartered Vessels
Better than Spot but falls short of owning
3. Voyage Spot Chartered Vessels
Most Voyages
Greatest risk
Least knowledge of quality by charterer

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Spot-Chartering and Risk Management

All oil majors have their own quality
assurance schemes
Schemes vary due to company size, scope &
diversity of activities, attitude to marine risk
and use of real time information and the
quality of analysis. Some use 3rd party
vetting.
All companies input/extract factual ship
inspection reports (SIRE) from Oil Companies
International Maritime Forum (OCIMF)
database
Determination of vessel utilisation is solely at
each companys discretion.
Liability concerns dictate how individual
companies approach the vetting issue
Increasing use of auto-vetting. Auto-vetting
counts the number of observations,
regardless as to how trivial the observation
might be.

Considerations by the Vetting Dept

Will it fit?
Class Changes?
Name of Operator

Age

Operational History

TMSA

Current
Class?

Change
of

Inspection History

Operator

Overall Fleet
Profile

Flag Changes?
Structural Analysis

Voyage Risk
Assessment

Can it load
nominated
cargo?

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The Function of the Oil Company Charterer

Charter most cost effective (aka Cheapest) freight

where the vessel meets all criteria i.e. vetting, marine

assurance, credit, etc.

The Charterer will:
Make freight calls about the forward market (when traders
are doing spot deals & in anticipation of system cargoes)

Provide shipping market intelligence for traders, monitor
what competitors are doing

Provide alternative freighting solutions

Provide chartering expertise and guidance to other parts
of the company

Chartering as the Oil Co Charterer sees it

Traders
Ship owners

Shipbrokers
Charterer

Oil Cos own Ship

Operations

Oil Supply
Operations
Vetting
Dept

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Typical oil company charterers vetting enquiry

to the internal vetting system

Vetting system requires :

Vessels name / IMO number

date of loading
cargo type
load port
discharge port
account / costs centre

Typical Oil Company Spot Charter Process

Input Ship for Vetting :

No

laycan, load port, cargo type, For

whose account is vl to be chartered

YES

Find other
ship

Clear for charter

No Other Ship

Fix for voyage

Voyage
Performance
Monitored

Vetting &
Assurance
Dept
Issues resolved
OK?

Maybe

Check for new

SIRE
Resolve Issues
with Owners

Initiate own SIRE

Inspection

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3. The OCIMF SIRE Programme

Oil Companies International Marine Forum

Ship Inspection Report (SIRE) Programme

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SIRE Principles
Reports are submitted to SIRE on a
voluntary basis by OCIMF Members
Payment for the inspections on a Who
asks, pays policy
Ship operator can make two sets of
comments relating to each report and
submit these to SIRE
Comments become part of the report

The SIRE Principles

Uniform inspection protocols for all vessels are

provided by Vessel Inspection and Barge
Questionnaires (VIQs and BIQs)

The reports are delivered in standard format

Vessel particulars, certification and on-board

inventory details are provided by Vessel
Particulars Questionnaires (VPQs) and Barge
Particulars Questionnaires (BPQs)

All SIRE Components are electronic

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SIRE Objectives
Obtain information of the vessels condition
and standards of operations to permit an
assessment to be made
Make inspection reports more widely available
Reduce the duplication of effort by inspecting
companies
Reduce the inspection burden on Operators
and crews

The Scope of OCIMFs Responsibilities

Provide software to create and submit inspection

reports
Review for compliance, reports submitted by
participating Oil Companies
Facilitate the submission of Operator Comments to
SIRE
Storage of reports and attachment off Operator
Comments
Software to create and submit HVPQs by
Operators
Delivery of SIRE reports to Programme Recipients
Training, Accreditation and Administration of SIRE
Inspectors
OCIMF HAS NO ROLE IN THE SELECTION OF
INSPECTORS

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SIRE Report
Recipients

How Reports are

Accessed

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The Delivered Report: Inspector Observations,

Other Comments and Additional Comments

Observations provide negative information to the

reader. They are printed in red.

Other Comments are value added. They are provided

to separate Observations, from positive comments.

They re printed in blue.

Additional Comments at the end of each VIQ Chapter

may be used to record Observations that are not

covered under any of the questions that are listed in
the Chapter.

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The SIRE Report Contents

Sect 1

General Information

Sect 2

All Questions answered

Y without comments

Sect 3

All Questions answered N with

Observations, or answered Y
WITH Other comments

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Section 3 Contains all

questions answered
No
or if
the answer contains
Other Comment

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Accessing the HVPQ

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Using the SIRE VIQ for Self-inspections

Many Operators use SIRE as a
KPI. It is therefore essential to
keep the number of
observations to an absolute
minimum.
Conduct regular self
inspections using the SIRE VIQ
Allocate responsibilities among
department heads and officers
responsible

Ensure that the VIQ is provided to all

controlled vessels

Instruct Masters to distribute the appropriate
VIQ chapters to those officers who are
responsible for the operations/roles covered in
the various chapters

Ensure that these officers perform joint
REGULAR self-Inspections using the VIQ
Chapters not just before the actual inspections

Act to fix defects under the your companys SMS
and Defect Management System

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4. SIRE Inspections - Key Issues

Overall Safety of the inspection

How the inspection will be conducted

Duration of the inspection

What the inspector can and cannot

do

Refer to the Introductory Sections of

the VIQ particularly Sect 4.

Lets look at Section 4...

Conduct of the inspection

Understand the guidance contained in the VIQ
introduction, Section 4 and ensure that the
inspector follows this

4.1 Deals with Dos and Donts

4.2 deals with Permitted Actions

4.3 deals with inspection suggestions.

Ensure that the inspector does not remain on
the vessel longer than is absolutely necessary

Remember that the intro twice refers to the
inspection duration as 8-10 hours

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The Use of Additional Comments

The SIRE VIQ cannot ask questions about each and

every situation encountered or piece of equipment that

might be fitted.

The Additional Comments feature permits inspectors

to make comments relating to any situation, or

equipment that is fitted.

If the inspector makes observations in Additional

Comments ensure that he points out exactly the IMO

or other recognised publication that relates to the
observation.

The good news is that inspectors vary rarely use the

Additional Comments feature

Overall Safety

1.

2.

3.

4.

Ensure full PPE is worn at all times when

outside accommodation or in machinery
spaces.
If H2S or Benzene is present in the cargo,
make this known to the inspector
immediately on boarding.
Ensure ISGOTT Ch 10 and OCIMF guidance on
entering enclosed spaces is followed TO THE
LETTER.
Ensure that if any unusual situation exists,
this is fully explained PRIOR to the
commencement of the inspection

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The New Officers Matrix (VIQ 3.10)

Inspectors must download the officers matrix

prior to boarding.

This is intended to save time and reduce the

overall time on board.

Ensure, however that the officers certificates and

time-served records are kept ready for the

inspectors review.

Ensure that the person responsible to keep the

matrix up to date, does so.

Getting ready and staying ready

1. Conduct regular self inspections
2. Correct all shortcomings
3. If shortcomings are noted but not fixed ensure

that proof of corrective actions are available

4. Ensure personnel are aware of the inspectors
expectations responsible officers must be able
to respond to inspectors questions
5. Ensure all documents and equipment that the
inspector wants to see, is set out and ready for
inspection

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5.

The Inspection - First Impressions

What is the inspector looking for?

The problem areas relating to oil spills...

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Approaching the vessel

Mooring
Sufficient mooring lines?
Any mixed moorings?
Condition of the mooring lines?
Are synthetic tails are properly attached to
wires?
If required, are Emergency Towing Off
Pennants (ETOPs) correctly rigged?

Boarding
Access to the vessel is it safe?

What does it comprise?

Is it safe enough to permit the inspector to
proceed?
Unless a shore gangway is used, a safety net
should be fitted
Will the method of using the safety net prevent
injury?
Are a heaving line, lifebuoy and light available?
Is the No Visitors notice posted where it can be
seen from the shore?

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Code of Safe Working Practices for

Merchant Seamen
18.2.2
When the inboard end of the gangway or accommodation
ladder rests on or is flush with the top of the bulwark, a
bulwark ladder should be provided.
Any gap between the bulwark ladder and the gangway or
accommodation ladder should be adequately fenced to a
height of at least 1 metre.
18.2.3
Gangways and other access equipment should not be
rigged on ships rails unless the rail has been reinforced for
that purpose. They should comply with the guidance in
Annex 18.1.

MSC.1/Circ.1331
11 June 2009
GUIDELINES FOR CONSTRUCTION, INSTALLATION, MAINTENANCE
AND INSPECTION/SURVEY OF MEANS OF EMBARKATION AND
DISEMBARKATION
2 CONSTRUCTION
2.1 Accommodation ladders and gangways for means of embarkation and
disembarkation which are provided on board ships constructed on or
after 1 January 2010 should meet applicable international standards such
as ISO 5488:1979, Shipbuilding accommodation ladders, ISO
7061:1993, Shipbuilding aluminium shore gangways for seagoing
vessels and/or national standards and/or other requirements recognized
by the Administration. Such accommodation ladders and gangways fitted
on ships constructed before 1 January 2010, which are replaced after
that date, should, in so far as is reasonable and practicable, comply with
these Guidelines.
3.3 Lifebuoy
A lifebuoy equipped with a self-igniting light and a buoyant lifeline
should be available for immediate use in the vicinity of the embarkation
and disembarkation arrangement when in use.

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VIQ 2011
5.80 Are accommodation ladders, gangways, pilot ladders
and pilot hoists, where fitted, in good order?
Means of embarkation on and disembarkation from ships.
1. Ships constructed on or after 1 January 2010 shall be provided
with means of embarkation on and disembarkation from ships for
use in port and in port related operations, such as gangways and
accommodation ladders, in accordance with paragraph 2.
2 .The means of embarkation and disembarkation required in
paragraph 1 shall be constructed and installed based on the
guidelines developed by the Organization (MSC.1/Circ 1196)
(SOLAS II-1/3-9)
Marking
Each accommodation ladder or gangway should be clearly marked
at each end with a plate showing the restrictions on the safe
operation and loading, including the maximum and minimum
permitted design angles of inclination, design load, maximum load
on bottom end plate, etc. Where the maximum operational load is
less than the design load, it should also be shown on the marking
plate. (MSC.1/Circ.1331/3.5)

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Boarding by Pilot Ladder?

The self igniting light must be

intrinsically safe if deployed in a
gas hazardous area

Critical moments - Coming on board

Security
Is the gangway manned?
Is the gangway watchman
provided with a walkie-talkie?
Does the gangway watchman
challenge the inspector?
Does he: Ask for SIRE ID?
Ask the inspector to sign a
Visitors Book
Provide the inspector with an
Emergency Stations Card
Ask to see inside the
inspectors bag
Ask to check mobile phone
is switched off

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Critical moments Meeting the

Inspector

ACCREDITED SHIP INSPECTOR

PHOTO

Michael D Billet
is accredited to inspect

Oil/Chemical/Gas
Vessels
Inspector No.
1003
AUDITOR
Expires:
20/09/2003
SHIP INSPECTION REPORT (SIRE) PROGRAMME

First Impressions - The walk to the

accommodation

Are all dipping/sampling points closed?

Is small spill clean-up equipment provided near
manifold?
Are fire hoses rigged in vicinity of manifold?
Are bolts inserted into all the manifold flanges?
Are all unused manifolds blanked/fully bolted?
Are pressure gauges fitted outboard of the manifold
valves?
Are all scupper plugs in place and tight?
Are scuppers free of rain water?
Are portable pumps rigged for immediate use at aft end
of main deck?

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...first impressions

The inspector has been on board for only a few

minutes

He has not yet met the Master, but

...what he has already seen is important

and...
...the initial and very important impression has
been gained

Entering the Accommodation

Are all accommodation doors shut?

Is the watertight door seal packing sound?

Is the accommodation under positive pressure

(Can you feel a draft in your face?)

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Air pressure inside the accommodation

block

ISGOTT
5th Edition
Chapter 4.1

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ISGOTT
24.2 Central Air Conditioning and Ventilation Systems

On ships with central air conditioning units, it is essential that the

accommodation is kept under positive pressure to prevent the
entry of hydrocarbon vapours. Intakes for air conditioning units are
usually positioned in a safe area and vapours will not be drawn into the
accommodation under normal conditions. A positive pressure will be
maintained only if the air conditioning system is operating with its air
intakes open and if all access doors are kept closed, except for
momentary entry or exit. The system should not be operated with the
intakes fully closed, that is in 100% recirculation mode, because the
operation of extraction fans in galley and sanitary spaces will reduce
the atmospheric pressure in the accommodation to less than that of the
ambient pressure outside.

Are the alleyways brightly lit, free of

clutter and clean?

Are the posted fire and safety signs

clearly legible?

Are the Station Bills (Boat Lists) up to

date?

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The pre-inspection meeting

Why it is useful if the C/E and the C/O are present at
the opening meeting.
Topics for discussion
1. The order of the inspection.
2. What equipment the inspector wants to see operating.
3. Confirmation that the access hatches to the ballast
tanks to be sighted from the deck are ready to open
4. Any unusual conditions on board that need to be
pointed out
5. Any defects that exist and which will be seen by the
inspector
6. The timing of the inspection will be 8-10 hours
7. The inspector must be considerate of the work
demands on ships staff

Certificates and Documentation

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VIQ 2.1
Are all the statutory certificates listed below, where applicable, valid and have the
annual and intermediate surveys been carried out within the required range dates?
2.1.1

Certificate of Registry

2.1.2

Continuous Synopsis Record

2.1.3

Document of Compliance (DoC)

2.1.4

Safety Management Certificate (SMC)

2.1.5

Safety Equipment Certificate, supplemented by Form E

2.1.6

Safety Radio Certificate, supplemented by Form R

2.1.7

Safety Construction Certificate

2.1.8

IOPP Certificate, supplemented by Form A or B

Statement of Compliance supplement

2.1.9

What is the vessels designation as recorded in the IOPP Certificate, Form

B, Question 1.11?

2.1.10 Minimum Safe Manning Document

2.1.11 Certificate of Fitness for the Carriage of Chemicals or Gas
2.1.12 Noxious Liquid Substances (NLS) Certificate
2.1.13 Civil Liability Convention (1992) Certificate
2.1.14 Name of P and I Club:

Set out certificates in exactly

the same as in 2.1 of the VIQ

Certification and documentation (1)

General information for Chapter 1 of the VIQ

Operators Operating Procedures Manuals
Class Condition Survey files
Enhanced Survey Programme (ESP)
Condition Assessment Scheme (CAP)
IOPPC with Part B
Oil Record Books (both Pt 1 and Pt 2 together)
Hours of Rest records
Garbage Management Books

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Certification and documentation (2)

Publications
Crew management
Crew licences and records of sea service
Drug and alcohol policy
Safety management
Minutes of meetings,
Records of drills, training and familiarisation
Record of Visits by Operators Superintendent

(Do Not Provide Superintendents Audits)

Certification and Documentation (3)

Ship security
Enclosed space, and pump room entry procedures
Hot work procedures and certificates. Remember the
more Hot Work Certificates there are, the more
concerned the inspector will be
Life-saving equipment from the LSC and Form E

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Certification and Documentation (4)

Shipboard oil and marine pollution

emergency plans
Ballast water management plans
Garbage management plans and logs
Crane and Cargo lifting equipment records
Ship to ship transfer operations
VOC Plan
Mooring equipment records

Hours of Rest Be very careful

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Watchkeeping Schedules
STCW Code Section A-VIII/1.5 of the
STCW requires watch schedules to be
posted in an easily accessible
location on the ship.
These schedules should relate to the
actual watch keeping arrangement at
sea and in port.

STCW Hours of rest

Compliance is either difficult or impossible
The actual Manning level aboard and trading pattern of
the vessel is key

Accuracy in the completion of the hours of Rest Log

Documents that may be reviewed to check the
accuracy of the Hrs of Rest Log:

Oil Record Book ( Deck & Engine)

Enclosed Space Permits & Entry Logs

Tanks Washing details of wash times

Purging, Gas freeing and re-inerting

Records of Drills if outside normal work hours,
are they logged?

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Hours of rest compliance (2)

Manning Levels

Two or Three deck officers will arouse suspicion

Manning is at, or close to, the minimum as

stated in the Minimum Manning Document

Vessels Operating under UMS

Work Schedules in port

Both deck and engineering officers are subject

to non-compliance

Chief Officer and Chief Engineer are key
candidates

Hours of rest compliance (3)

Is the Hours of Rest Log completed in accordance

with Company instructions?

Does the SMS have clear instructions to prevent
fatigue?

Is the Comments section completed?

Are the total daily and weekly hours recorded?

Will inconsistencies between the recorded hours

of rest versus actual evidence be uncovered?

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Hours of Rest Practical checks (1)

Oil Record Books

Part 2

Cargo loading or discharging

COW operations
Tank Washing
Slop tank decanting

Part 1

Bunkering
OWS operations
Transfer of residues to slop tanks
Incineration of waste

Hours of Rest Practical checks (2)

Enclosed Space Permits & Enclosed Space Entry

Logs

Dates and Times when permits were opened

and closed

Who was in the spaces

Comparisons between purging and gas freeing

times

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Some examples of inspector observations

seen in SIRE Reports

The vessel maintained work rest logs as

required.
However, when the current months log (May
08) was checked in the computer it was noted
that the entire month for both deck and engine
departments had already been filled out.
The inspection was conducted 11 of May.

Some examples of inspector observations

seen in SIRE Reports

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Some examples of inspector observations

seen in SIRE Reports

The engine oil record book showed that the

vessel conducted bunkering operations on 2 of

Jan between 0100 and 1000.
The Chief Engineer and 2nd Engineers Hours of
Rest logs were reviewed and both were shown
to have been working a normal day ( 08001700) on 2 Jan. The vessel operated UMS at
sea and manned in port.

If the Inspector is wrong, do not accept an

Observation

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Signatures in the ORB Part 1

Signatures to be
by the officers in
charge of the
operation

If the C/E signs the
ORB Part 1 it is a
simple matter to
cross check with
the Hours of Rest
Records

Some examples of inspector observations

seen in SIRE Reports

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General PSC Findings

Hours of rest not being complied with in port
resulting in watch keepers on duty for
departures and first sea watches not being
adequately rested;

Records of hours of work/rest are not being
maintained;

Records of hours of work/rest do not reflect
the actual working arrangements; and

The Safety Management System of the ship is
deficient in ensuring compliance.

Hours of Rest - conclusions

Logs are being completed by a single person not

by the individuals concerned

Logs are not completed on a daily basis without

delay Marpol Annex I 36.5

Many people assume a 00-24hr day is used this is

not the case. STCW uses the term, In any 24 hour

period

Most entries are simply fictitious!!!!!

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Cargo and ballast tank conditions

Major concerns for Oil Cos, but ballast
tank entry during cargo transfer is not
encouraged.

A review of the ESP Report File is

essential.

Review of the ESP File

A planned inspection programme must be in place

Important:
Review the Condition Evaluation
Report/Executive Summary
The bad words

Substantial corrosion
cracks
Serious incidents

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ESP Requirements
IMO Resolution A.744(18): Annex B: Guidelines on the
enhanced programme of inspection during surveys of oil
tankers.
Enforced by:
MARPOL 73/78 Resolution A744(18)
IACS Unified Requirements, IACS UR Z10.1 (Hull Surveys
of Oil Tankers) specifies the minimum overall and close-up
surveys for:
plate thickness measurements
tank testing
survey planning and reporting

ESP Requirements Important

Definitions
Overall Survey: A survey intended to report on the overall
condition of the hull structure and determine the extent of
additional Close-up Surveys.
Close-up Survey: A survey where the details of structural
components are within the close visual inspection range of
the surveyor, i.e.. Normally within reach of hand.
Suspect areas: Locations showing substantial corrosion
and/or are considered by the surveyor to be prone to rapid
wastage.
Substantial corrosion: An extent of corrosion such that
assessment of corrosion pattern indicate a wastage in excess
of 75% of allowable margins, but within acceptable limits.

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Thickness measurement reports

To include:

item and location of where measurements taken;

measured thickness and original (and minimum) thickness;

date when carried out;

type of measurement equipment;

name of the Operator and whether Class approved;

Class surveyors verification and countersignature.

(The inspector will check details in the Condition
Evaluation Report)

Hot work certificates

General The bigger the file, the more concerned the

inspector will be.

ISGOTT Guidance must be followed.

Consideration of alternatives,(such as cold work).

Planning.

Execution.

What is the notification and agreement process

between vessel and shore management?

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ISGOTT 4th Edition

Hot Work the ISGOTT 5 position

ISGOTT 4th Edition had box

requiring consultation with
office

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This assumes that the SMS insists on notification

and agreement by shore management to ALL hot
work within gas-hazardous areas

The OCIMF Guidelines relating to SMS

and Hot work

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OCIMF GUIDELINES ON SAFETY MANAGEMENT SYSTEMS FOR

HOT WORK AND ENTRY INTO ENCLOSED SPACES . Sep 2008
Principles for an Effective Safety Management System for the Control
of Hot Work. 2.1 General:
The SMS should ensure that: (i)

Any Hot Work to be carried out is necessary for:-

(a)

the safety, and / or,

(b)

the immediate operation of the ship, and that all viable

alternatives have been considered and reasons for rejection are
documented.

(ii)

Full consideration has been given to performing the Hot Work in

a designated space such as the engine room workshop where
conditions are deemed safe.

(iii)

Full consideration has been given to all hazards associated with

the Hot Work process, as identified within a formalised Risk
assessment.

OCIMF GUIDELINES ON SAFETY MANAGEMENT SYSTEMS FOR

HOT WORK AND ENTRY INTO ENCLOSED SPACES . Sep 2008

2.2 Pre agreement: The requirement for Hot

Work outside the designated space should be
agreed between the Shipboard Management
Team and the Company (office). The discussion
may include: evaluation of alternatives
(including Cold Work), duration of job,
scheduling, ships staff and/or contractors,
materials and logistics, stability and stress and
weather forecasts.

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The ISGOTT position relating to entry into

enclosed spaces
10.4-Control of entry into enclosed spaces
Restricting the issue of approvals, such as entry permits, so
that all cargo tanks which are safe to enter are shown on one
document, may be found to simplify the paper administration,
avoid overlapping and reduce the possibility of confusion as to
which approval applies to which tank. However, if such a
system is used, there must be rigorous control to ensure
cancellation of existing permits, and that the atmospheres of
all named tanks are correctly tested at the time of issue so
that an effective extension of a period of validity does not
occur by default. It will be particularly important to ensure
that the permit process is supplemented by the marking of
tank lids with notices indicating which tanks are safe to enter.

The OCIMF Position Relating to SMS and

Enclosed Space Entry

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OCIMF GUIDELINES ON SAFETY MANAGEMENT SYSTEMS FOR

HOT WORK AND ENTRY INTO ENCLOSED SPACES . Sep 2008

3.2 List of principles for Entry into Enclosed Spaces:

The SMS should consider the following:(i) That best practice examples consistently show the
benefit of Single Permit use for individual spaces.
However, in certain limited cases it might be
appropriate to utilise a single permit covering
multiple enclosed spaces.

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Garbage Management

Common documentation Observations

Certificates folder is disorganised

Ships management manuals not updated
Ships manuals not signed by personnel
SOPEP manual not revised
Mooring records not maintained
Personnel unfamiliar with SOPEP contents
Unsatisfactory winch testing records
Certificates for mooring lines do not indicate the winch
on which they are stored
Inadequate Hot Work and Enclosed Space Entry
Permits
Physical evidence not in conformity with records
Fire plans do not reflect actual equipment
Unfamiliarity with contents of management manuals
Hours of Rest Records

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6.

Oil Record Book Exercise

Please review the excerpts from the Oil Record

Books from the vessel Caledonia

Please look for irregularities in these and

record your findings

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Annex I Reg 17
4 Each operation described in paragraph 2 of this regulation shall be
fully recorded without delay in the Oil Record Book Part I, so that all
entries in the book appropriate to that operation are completed. Each
completed operation shall be signed by the officer or officers in charge of
the operations concerned and each completed page shall be signed by
the master of ship. The entries in the Oil Record Book Part I, for ships
holding an International Oil Pollution Prevention Certificate, shall be at
least in English, French or Spanish. Where entries in an official national
language of the State whose flag the ship is entitled to fly are also used,
this shall prevail in case of a dispute or discrepancy.

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ORB Part I
4 Apr 1999
C12
10t should be m3
C12.1
No receipt issued
H27.2
1230 no start or finish time
recorded

6 Apr 1999
D13
Tonnes recorded and not M3
D15.4
Tonnes recorded and not M3

C 11.1

Sludge tank Its actual ID is not

mentioned
3 t should be M3

C12.1

No record of the receiver of the sludge

no receipt issued
2.5t in a 20 day voyage is too little

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23 Apr 1999

Code D No mention as to whether an

automatic stopping device is fitted. (Special

Area)

28 Apr 1999
H27.3

Individual quantities loaded to

Foredeep tanks is not recorded
No entry is made in the ORB Part 1
for bunker spill but it is recorded
in Part II

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Part II

4 Apr 99

A3
3C Tank overloaded 5190m3/5155

6 Apr 99

Transfer from ER 3t to Slop Tank not
recorded

24.4.99

D16
Use of Eductor suction gauges to
measure tank is empty is not a
satisfactory method

E18
G31.2

Ballasted 3C but this tank was not

COWd
1140M3 washing water (plus 60mt from
slop tank ROB) = 1200m3, but total
recorded = 1387m3 (discrepancy
137m3)

26 Apr 99
H32
De-ballasted 3C in special area

I42
Settling time records 26 hours within
one day?

I 47/48 Bulk rate is lower than the final rate
of discharge.

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