Open Forum for Exchanging Views with Industry Association of Asian Classification Societies (ACS) Open Forum for Exchanging Views with Industry Consideration of provision of more comprehensive and transparent PSC data and statistics Tokyo MOU Open Forum Singapore 24 January 2013

Open Forum for Exchanging Views with Industry - Submitted by ACS Provision of more comprehensive data and statistics on detainable deficiencies. Provision of more comprehensive and transparent information on the detention list. Improvement of transparency in the detention of the ship by immediate notification to flag state/RO. Improvement of communication between PSC authority and RO in the appeal processes for RO responsible deficiencies. 1

I. More comprehensive data and statistics on detainable deficiencies Tokyo MOU Annual Reports provides PSC data/statistics for “Deficiencies by main categories” (Fig.6) and “Most frequent detainable deficiencies” (Fig.7). ACS considers that it will be a great help to industry: 1. If a new database “Detainable deficiencies by main categories” (Fig. 6 bis) may be provided. [Reason] Fig. 6 alone will be a useful data for statistics, but is limited in use to take specific counter-measures to prevent recurrence of similar detention. The database of “Detainable deficiencies by main categories”, if provided, will helps Flag authority and RO: to identify priority items in their development of the checklists/ guidance, and in a concentrated inspection of target ship, considering a short time available for inspection during the ship in port/dockyard, inspectors can make their inspection in a more concentrated manner by focusing on the items of detainable deficiencies as priority check item. 1

I. More comprehensive data and statistics on detainable deficiencies (cont.) 2. Also more items (at least 5 more) could be added to the present 10 “Most frequent detainable deficiencies” in Fig.7. [Reason] Development of plans for shipboard operations (ISM related deficiencies - 15106) ranked 7th in 2011 Report, but was not appeared in Fig.7 in 2010 Report as it might have appeared (ranked 12 or 13th) if more items were added to Fig.7. Earlier warning could have been given on this sharp increasing item in 2010 Report (sharply increased from 2009 ). 1

Date of detention Date of release Nature of deficiencies II. Provision of more comprehensive and transparent information on detention list Currently, some information given in the “Nature of deficiencies” column of the “Detention list” in Tokyo-MOU website is very limited, as shown below. It is our belief that full description of the detainable deficiencies (include a cause of detention) in the “Nature of deficiencies” column will greatly help the flag State/RO to examine/investigate and develop their own guidance/check-lists to prevent recurrence of the similar detentions. Date of detention Date of release Nature of deficiencies 02.01.2013 13102 - PROPULSION AND AUXILIARY MACHINERY - Auxiliary engine (no responsibility of RO) 07115 - FIRE SAFETY - Fire-dampers (no responsibility of RO) 04.01.2013 04113 - EMERGENCY SYSTEMS - Water level indicator (no responsibility of RO) 02131 - STRUCTURAL CONDITIONS - Other (Bulk carriers) (no responsibility of RO) 1 1

III. Improvement of transparency in the detention of the ship by immediate notification to flag state/RO It is true to say that not all masters of the ship have expertise to decide the extent of rectification of the deficiencies that caused the detention of the ship. Immediate notification to flag state, especially to RO (regardless of RO responsibility), will be a very effective means to improve the transparency in the final judgment to detain the ship and/or begin the process for the proper rectification of the deficiencies. Involvement of the flag state/RO by correspondence or by attendance will surely help the ship’s master as well as the port state inspector to correct the root of deficiencies promptly and effectively, and will eventually reduce both the complaints of the ship owners about a detention decision and appeals against detention. Accordingly in case the inspected ship is found with detainable deficiencies, we recommend that PSC inspectors be kindly requested to notify/let the master notify immediately to RO for possible attendance on board the ship. 1

It will be of great help to RO if detention list is uploaded VI. Improvement of communication between PSC authority and RO in the appeal processes for RO responsible deficiencies PSC report Form A recommends that PSC authority may notify to the RO on the RO responsible deficiencies In practice, however, it is not uncommon that there is no response from the PSC authority regarding RO’s repeated requests It will be of great help to RO if detention list is uploaded within 5 days and if RO are automatically notified by clicking on the RO responsible column when PSC authority uploads the data. This may be taken in APCIS. 1

Thank you for your attention!