Technical Notices

Substantial amendments of PMA MMC-380 “Measurements to Reduce PSC Detentions and improve the performance on Panamanian vessels” 

PMA has amended substantially the MMC-380 “Measurements to Reduce PSC Detentions and improve the performance on Panamanian vessels”, attached herewith.

Major amendments are as follows:

1. Measurements to be applied as preventive-corrective actions to reduce PSC detentions

1.1 Owners/operators responsibilities

• Establish on board a pre-arrival verification, which must be verified at least 24 hours before arrival at ports in order to avoid detentions and deficiencies
• Equipment failures or any others situations that cannot be resolve on board of the vessel immediately, shall be notified/coordinated with RO and PMA, while local PSC Authority shall be notified as well
• All PSC inspection reports to be sent to PSC Section of PMA (psc@amp.gob.pa)
• Corrective actions taken in relation with PSC deficiencies shall be sent asap to PMA PSC Section

1.2. RO responsibilities related to the detention

• Permanent verification of MoU´s websites to determine the status of vessels under its supervision
• Handling of detentions, including the investigation, analysis and determination of deficiencies root-cause, recommendations including preventive/corrective actions and follow actions
• Established procedures for the cases where, as a result of PSC inspection, there are deficiencies relating to RO responsibility for statutory certificates issued by the organization
• RO’s surveyors shall pay attention to the following main items including on the “Top Deficiencies” (most frequent detainable deficiencies) on MoU´s annual reports, but not limited to:

1. Validity of all Statutory Certificates (including annual/intermediate endorsements).
2. Life-Saving Appliances (LSA) in general.
3. Lifeboat falls (including renewal and reversal dates).
4. Liferafts servicing (dates).
5. Fire Fighting Systems & Equipment (in general).
6. Emergency Fire Pumps (last test).
7. Fire detection & alarm system (last service).
8. Pyrotechnics (expiry date or expiration date).
9. Records of weekly/monthly drills and equipment inspections (log book’s entries, SMS records).
10. Nautical Publications & Charts (up to date).
11. Oil Record Book + Oil Filtering Equipment (MARPOL 73/78 Annex I).
12. Any outstanding statutory items and/or conditions of class (verify last class survey).
13. Personnel Familiarization & Responsibility (ISM Code – Section 6).
14. Maintenance of the Ship and Equipment (ISM Code – Section 10).
15. Working & Living Conditions (MLC, 2006).

2. Additional Measurements adopted to reduce PSC detentions (shall be implemented by the RO´s as off April 15th., 2023):

2.1 Preventive Measures:

2.1.1   Each ship that is at risk of being detained, due to its history of Port State Control inspections in the last twenty-four (24) months, may undergo an Occasional Survey carried out by the RO that issued the SMC Certificate, if it is required by the General Directorate of Merchant Marine.

2.1.2   Each ship older than fifteen (15) years of construction and considered with a high risk factor by the USCG, Paris MOU and the Tokyo MOU, shall be subject to an Occasional Survey, carried out by the RO that issued the SMC Certificate.

2.1.3   When the Occasional Survey is completed, the RO must issue a Declaration of Compliance of the Occasional Survey, valid for six (6) months.

2.1.4   The inspection report will include the following specifications, but not limited to:

1. Ship Particulars
2. Minimum Manning on board is in compliance with Minimum Safe Manning Certificate issued by the Administration.
3. Certificate of Competence of the crew.
4. Technical Certification
5. Applicable Plans and Records
6. Condition of: Hull & Deck, Cargo Holds & Hatch Covers, Engine, Navigation Bridge, Mooring and anchoring equipment.
7. Rescue, Fire Fighting & Life Saving Appliance Equipment ready for use.
8. Safety Management System: compliance with maintenance plans and inspections, familiarization and crew drill training and its entries, internal audits, closure of Non-Conformities (including previous PSC deficiencies), declaration of the designated person and declaration of the company, etc.
9. ISPS: vessel access control, updated CSR updated.
10. MLC: on-board contracts properly signed, payment of wages, hours of rest and work, insurance according to rule 4.2 and 2.5 of this convention, maintenance and cleaning in accommodations, corridors, cabins, decks, cold room, dining rooms, galley, fans and air conditioners.
11. Conclusions: comments on the general condition of the ship.
12. Annex: photos and supporting evidence of the inspection

2.2 Correctives Measures:

2.2.1. All detained vessels that, by virtue of the result of the technical evaluation of the General Directorate of Merchant Marine, the following may be required:

i. Additional ISM vessel audit, with an initial scope. In the event of non-conformities, they will be followed and if a follow-up audit is required, they must be done within a period of no more than three (3) months from the date of the last Additional audit and/or,

ii. Additional company Audit. This Additional Audit will be carried out on companies that register three (3) or more detentions in the history of their fleet in a period of twenty four (24) months.

2.2.2   Vessels detained by USCG or by the Member States of the Paris MOU, AMSA and by China Maritime Safety Administration must do the following:

i. Submit evidence that demonstrates the corrections of the deficiencies indicated in the inspection reports of the Port State Control, in the last twelve (12) months.

ii. Carry out an additional SMC audit, with an initial scope.

iii. If required, an Additional Company Audit with an initial scope.

iv. A flag inspection may be carried out to verify the general conditions of the ship

v. Any other measure that the General Directorate of Merchant Marine deems necessary depending on the case.

2.2.3   When a Panama flag vessel is detained within the United States Coast Guard (USCG), the Recognized Organization must perform the corresponding audits and inspections together with a Flag State Inspector.

2.2.4   These Additional Audits shall be performed by the RO that issued the SMC and shall be coordinated with no more than fifteen (15) days, from the written notification.

For exact requirements and details you should refer to the MMC-380 “Measurements to Reduce PSC Detentions and improve the performance on Panamanian Vessels”