Implementation of IMO Regulations: Where Do We Stand?

Since its inception, IMO has carved out various conventions by enlisting co-operation from its member states, which in turn, have mostly converted these conventions into national regulations. The implementation of these conventions has been good so far through various flag states and PSC regimes such as Tokyo MOU, Paris MOU etc., though standards of PSC inspections by various states have not been uniform.

As a seafarer, I have no hesitation in saying, by personal experience, that I have never been afraid of PSC inspections by Japanese authorities or by United States Coast Guard (USCG), but have always been concerned in facing Australian Maritime Safety Authority (AMSA) and Indian PSC. With the former ones, you could deal with on equal terms and they do get convinced when matters have been explained to them properly. However, in the latter case, the approach of the inspectors has been like that of a rigid policeman, unwilling to listen and reason. (This article is not intended to cast any aspersion on PSC officers but merely states the facts, as perceived.)

Some years back, while at Zeebrugge, Belgium, the PSC inspector asked me how to manually operate a foam fixed system valve. I was new on board the ship so I said, “Let’s find out together! “, to which, the inspector sportingly agreed and jointly we learnt how to operate the valve manually. Once a USCG inspector asked me, “How will you take out this spare tail end shaft (kept in the steering gear room)?” When I explained the process to him, he thanked me and was very reasonable with us throughout the inspection. Unfortunately, not all PSC officers are cooperative. In many ports, unfortunately, PSC inspection means either showing off power or trying to extract benefits (Including cash) which is extremely disturbing. (I will refrain from naming the ports because I am not preparing this text for that purpose. Those who have sailed long know the names well.)

IMO
Credits: flikr.com/IMO

Now coming to the International Safety Management (ISM) code, I like two things about it – Familiarization and Safety meetings. In earlier days, we familiarized with the ship and her safety equipment as we spent time on board and participated in the drills. There are many areas of the ship we might not know even until the date of signing off. But now, the situation is completely different. When you join a ship, someone familiarizes you with the LSA/ FFA equipment and your duties during emergency situations. (How much you learn depends who is familiarizing you and the interest you show. In many cases, familiarization cannot be completed in one go and we should agree to continue it later, may be on next day or the coming week. Moreover, the officer familiarizing you, might be busy with other duties and so it can be mutually agreed to find out details later and sign the checklist completion then.) This is a great step towards safety of ship and its crew. Safety committee meetings provide us with a platform to express our concerns, to report any unsafe equipment, area or practice. Good senior officers encourage communication and do not finish off this important meeting in half an hour; it is important to discuss for, say, one hour in a constructive manner. Any outstanding deficiencies and non-compliance (NC) must be recorded and taken note of at that time and it is to be made sure that the Designated Person Ashore (DPA) is informed in detail about the deliberations. If any urgent spare is needed, it can be highlighted during this meet.

Several things have changed in the ship’s engine room. It is nice to see development on the marine engines in the matter of sheathing the fuel high pressure pipes and making arrangements for the leakages so that it leads to a tank below with fuel leak off tank high level alarm. How beautiful and safe it is to use Anti-Flash tapes on relevant piping connections to prevent oil from splashing. I was always concerned about leaked oil falling on exposed indicator cocks until I saw on some modern engines, a push type cover for the same. In earlier days, we had lagging but we did not bother much about keeping them intact and oil free, but now because of the awareness created by IMO conventions, we do pay more attention to this, especially on generator engine exhaust piping and on turbocharger connections.

Now there are specialized contractors in the market to affix bigger lagging more proficiently and clearly. Earlier we did not have alarms for water ingress in cargo holds but now we have two. However, it is seen that the ship’s crew expect them to be kept in order by the electrical officer alone. (I will take this opportunity to request organizations and the flag states to include learning of electro- technique and electronics for the navigating officers as well.)The time has already passed when we officers said, “This is the job of engineers and not our job (or vice-versa)”. With reduced manning and with increased automation, it is necessary that deck officers also improve upon their capabilities and this must be provided for under STCW latest prescriptions.

Another area where this deficiency is noted is in regards to fire alarm systems. Here also the crew expects electrical officer to do the needful and the duty officers are not familiar with the system, while a majority of them are not even interested. To deal witch such situations, more practical training on such systems is to be mandated for all officers on ships.

The quality of training for maritime professionals has been a major issue. IMO has prescribed training in good faith but forgot to consider, who will provide the training? In present scenario, in general, there are trainers who themselves do not know several things and yet speaking away to glory. They have not acquired any sailing experience in the last 20-30 years and this is patently wrong when it comes to imparting knowledge to others. This I feel, is a serious deficiency in implementation of STCW convention, which needs to be addressed at the earliest. (I must confess that till this moment I really do not know what the World Maritime University (WMU) does, instead of trying to comment on it, it is safest to say that I have learnt nothing from WMU. IMO is probably wasting money on this, which could be used for on-board training by equipment manufacturers either personally or through computer based training (CBT) (like we have CDs on purifiers etc).

Some PSC inspectors have become very diplomatic and they play safe by not writing any recommendation that may be necessary, but instead ask for acquiring so and so publications from the next port. This may be cheapest and best, but the point made is that hardly anyone reads these publications. A study may be conducted to check as to how many crew members have read these books. As far as I know, no one reads these books and this is a deficiency in PSC implementation.  They should ask the officers, please show me which book did you read. Same is the story with the training manuals. It remains the least read book on the ship. PSC should start with top 4 to check if they have read it, if not, give an non-compliance (NC) ( i.e. so and so officer must read this and submit proof by e-mail specifying the topics read). There is also another major deficiency in PSC inspection. Has any inspector till date gone to check funnel uptakes for close-up examination?  Forget inspection, have they checked if it forms a part of the PMS or not? Close-up examination of main engine, generator, boiler, incinerator uptakes must form a part of PMS ( annual checks).

Ballast water exchange and ballast water treatment are also one of the major issues that are being neglected. We have been doing ballast water exchange for many years. I remember when we used to go to Vancouver in late 1980s, an inspector used to come and stand near ballast pump overboard discharge and judged the cleanliness of the water by looking for any kind of discoloration. In Russian ports they used to come and take samples from sewage treatment plant. Regarding ballast water, it was the same story, if no muddy water was found, it was good. However, biological research takes place and technical up gradation is natural. We can see and read some effective systems have been designed and installed on many ships, though they are reportedly expensive, with time better solutions will be found. It is hoped that the latest ballast water regulations would bring in some much-needed change in the industry.

Coming to fire extinguishing systems, high-pressure water spray system has now been installed on many ships, in addition to good old Co2 total flooding system but in majority of the cases the crew does not know anything of the former. High pressure (HP) water spray system is a neglected item on most ships and very few officers test it or know enough of the same. PSC inspectors must question top 4 on this.

These days the situation is such that if there is a problem with the main engines and if the generators are not running satisfactorily, officers ignore them to give preference to the 15ppm of OWS. But actually there is no need to be scared or making a big deal about it, if you use it regularly and keep bilge holding tank free of too much oil. (I read with amusement, the IMO prescription in regards to economizer wash water discharge  which had so many ifs and buts included, clearly showing that Maritime Environmental Pollution Committee (MEPC) members involved in this have never washed an economizer (Exhaust gas boiler) with their own hands. Once, we were on a car carrier and about 4 hrs before entering the bay in Japan, we stopped, washed the economizer and when the washings came to the soot tank, we pumped out en route with one man stirring and diluting the soot tank contents through a fire hose to prevent solid remnants in the tank and in the pipes and the whole process was quite satisfactory as it only contained soot and no oil at all.)

Shore reception facilities have improved a lot, notably at Mugga port, Barcelona, Itajai, Chinese ports, Kandla port , Paradeep Port etc., but Marpol implementation will never be fully satisfactory if we do not provide this facility in many more ports. IMO needs to work on this as to where their performance is poor. Similarly, garbage collection, segregation and disposal has improved no doubt but there is scope for betterment by involving more crew in this work. Deck cadet, engine cadet, trainee seaman, wiper, trainee cook must be involved with effective supervision.

A very wrong expression has found it’s way in our SMS and that is “minimum manning”. It means that we should have at least these many crew on board but owners have twisted it to mean, if we have these much minimum then we don’t require more. Trainees have traditionally been there on ships and most of the things they have learned on board. Let’s not curtail this.

Annex VI implementation has been okay so far in ECAs but has been guided more by fear and lack of understanding than actual satisfactory switching over of fuel to low suphur gas oil (LSGO)Last year I was on board a ship which came to Bourgas port and later at Constanta port ,and the managers in the office were not clear ( no honest discussion) if the generators, boiler, and main engine will run on LSGO while approaching and leaving the berth. If you think clearly, the generators and the boiler are going to run while vessel is berthed and it is these two machinery that have to run on Low sulphur gas oil while ship is berthed. There is a lot of policing going on in this respect-  is it written in log book, is it written in ORB, are the ROB’s written or not in both books. However, nobody ever comes down to check it’s actual usage.

While implementing various IMO conventions, officers should pay attention to practicalities and check with the crew as to what is going on and how the things are being done rather than confining to paper entries. Authorities should refrain from scaring the crew, and instead should go with them and find out the issue, if there is any. They shouldn’t randomly penalize, but convince or get convinced on the matter. Teach them or learn from them.  That is the way to bring about improvements and progress.

Engine manufacturers are constantly working on Exhaust gas recirculation systems and Selective Catalyst reduction methods and we must familiarize , master and improve upon these techniques , as and when we get an opportunity  to work on board such ships. Tier III compliance on low speed engines by MAN Diesel and Turbo and Dual fuel usage technology being implemented by WARTSILA  and other very competent engineers  merit consideration . It is various conventions of IMO which have caused technical advancement and up gradation in maritime technology and these are worthy of working on and gaining experience with to reduce fuel consumption and enhance energy saving. One single bad habit of not reducing speed in rough weather increases fuel consumption, creates vibrations, and increases stress on the hull. This is something every engineer must have knowledge on.

SOLAS is one book which I must have read many a times ( of course, in parts) but very recently I read about ship structure access manual. This clearly indicates that maritime technology is such that you can never say that you have learnt it all. That will be wrong. Even if you provide the best access manual, if the concerned officers are unwilling to access any area for close up examination, such manuals will be of no use. With due respect to many Masters, I must say that they only know access to the bridge, to their cabin, to the mess room and to their private pantry (if provided). This may be a bit exaggeration (please, take it sportingly) but the point being made here is that senior officers do not enter the holds . Yes sir! That is largely true!

There is another prescription, security training for seafarers with designated security duties, which I feel is a waste of money. Some years back, we were trained by our Croatian Chief Officer on IMDG Code and we were also issued certificates signed by him and the master. And trust me that it was the best training. No college could have taught better. Thus, pay attention to on board training in preference to bogus training being imparted by many so called approved colleges, which even do not have faculty.

Earlier, we had only 3 documents, COC, CDC and PP, but now numerous certificates have to be carried , all this must be reversed in the interest of simplification and to eliminate corruption involved. The drills on board should also be diversified to include casualty handling, studying the equipments in detail, concentrating on speedy donning of SCBA, discussing the bridge equipment ( 90% of Bridge watch keepers know very little of the equipment they use) etc. Provision should be made such that an experienced officer can join a ship from one port to the next ( about 7 days or so) and in the mornings can carry out audit and in afternoons, after tea time, the training.

Steering gear room is one place where we normally do not go. A standard practice by PSC is to say, “Show me emergency steering!”, but they hardly ever ask the officers, what tests do you carry out on this system. They must check on the main gear and associated equipment and linkages because the trouble takes place there, emergency steering is hardly ever resorted to.

The generators are the most important machinery on board and the implementation of IMO conventions will never be complete without the PSC devoting substantial time in this area. Lift up the floor plates and check underneath. Ask one generator to be stopped, start again, check paralleling and crew familiarization.

BIMCO and other shipping organizations are engaged in calling for more professional and responsible approach while carrying hazardous cargo in containers (accuracy in description of the cargo included) and the ship staff must be trained and motivated to check and re-check. Now the time has come for consolidation of various IMO conventions instead of their proliferation. This requires courage of conviction.

Having spoken good about IMO, let us also learn about the irresponsibility of the IMO. Nobody has thought about the time to be given to a ship to carry out maintenance. Immediately as one charter finishes, another one starts and the time in port has drastically reduced. When to carry out work on main engine and the generators? For this purpose, if the ship chandler has to bring some thing or the workshop has to supply something, it takes lot of time (especially in an Indian Port) at the port gate to complete the formalities. How will they make any profit or why will they take interest if they need to shell out substantial cash in completing or bypassing these formalities? These are the real difficulties on the ground about which something needs to be done as soon as possible. Singapore remains the most user friendly ports in these matters. IMO must insist flag states to simplify and speed up procedures in their ports to better serve the vessels in port. Lack of maintenance affects safety. Let various PSC regimes check up the performance of the generator engines and not confine to testing of 15ppm alarm, running of the emergency generator and emergency fire pump only.

The role of PSC inspector and Class Surveyor is not only to confine to checking a few equipment but also to engage ship’s personnel ( both senior and junior officers) in discussing performance of various machinery, difficulties faced and action planned, and assist the ship staff in writing out useful recommendations (not detention orders), for example, if I find that a particular generator engine is overdue towards maintenance and operating in unsatisfactory manner then I will write, No: X Generator to be overhauled and photographic evidence and maintenance report  submitted by a particular date. There is no point in simply printing the rules and not keeping track if they are being followed or not and neglecting the difficulties involved.

To sum it up, I would say that there is a massive gap between introduction of conventions and implementation of the same on ships. Unless some concrete measures are not taken to streamline processes and workflow, the conventions would remain just on papers. A collective effort by the authorities and the seafarers is the need of the hour.

Disclaimer: The views, opinions and positions expressed within this post are those of the author alone and do not represent those of Marine Insight. The accuracy, completeness and validity of any statements made within this article are not guaranteed. We accept no liability for any errors, omissions or representations. The copyright of this content belongs to the author and any liability with regards to infringement of intellectual property rights remains with him.

2 Comments

  1. Quite amusing to see Mr.Mahendra Singh’s wishful thinking.Its not lack of knowledge but the companies’ SMS’s that mandate engineers to handle equipments appropriately as designated by the same.Shamefully (not for me being a deck officer) i’ve had engineers working with me who were just button-pressers rather than showing any interest in the principle of the machinery.The popular belief ,sadly even among chief engineers who’ve sailed quite long is that deck side is non-technical.On the flip side.i’d like to mention the skepticism engineers show when captains man the engine room in High risk areas or any SMS stipulated conditions for that matter and talking of Masters, with due respect to Chief engineers, i’ve known chief engineers who’ve rarely go to the engine room in their tenure,might sound exagerrated but true.well it aint an indian company either .Its a high profile japanese company.well the nationality is to blame not the company.so careful before u pull senior officers.And about deck officers doing machinery maintenance, we sure would be happy to do that provided i get one engineer to keep look out while i take half-nap at my night watch.well am sure hawk-eyed engineers could do my job keeping in mind 38 Rules of the road and 6 annexes of Marpol ofcourse (well in any case it’d apply if the collision causes the spill).Anyways kudos to the author.Good work!

  2. Dear Friend
    I always had good relations with my deck officers and i have sailed with masters of many nationalities
    and enjoyed their goodwill. I have no intention of criticizing them, no, that has never been the intention.
    If you read my previous articles you will know it. At my age, i will say only what will benefit future officers .We need to get over this feeling that i am a deck officer and i am an engineer. Times are changing. We should learn more about bridge equipment and some small participation in deck machinery ( like making sure that deck water is open during mooring stations in hot areas.
    during port watches.
    Cheerup No disrespect meant

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