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Port State Control in the USA Checklist and ships preparation

For vessels trading to the United States of America, PSC inspections are carried out by the United States Coast Guard (USCG). Additionally, tankers, gas and chemical carriers are subjected to annual inspections. The USCG vigorously applies the requirements of the U.S. Codes of Legislation regarding the condition operation of ships within U.S Territorial waters. All of these requirements are laid out clearly within the appropriate legislation contained in the Code of Federal Regulations (CFR’s). The USCG stated goal is to ensure that no substandard ship enters US waters or threatens their coastline or waters.



chemical tanker navigation at sea
Notice of hazardous conditions

Whenever there is a hazardous condition either aboard a vessel or caused by a vessel or its operation, the owner, agent, master, operator, or person in charge shall immediately notify the nearest Coast Guard Sector Office or Group Office. (Compliance with this section does not relieve responsibility for the written report required by 46 CFR 4.05-10

Hazardous condition means any condition that may adversely affect the safety of any vessel, bridge, structure, or shore area or the environmental quality of any port, harbour, or navigable waterway of the United States. It may, but need not, involve collision, allision, fire, explosion, grounding, leaking, damage, injury or illness of a person aboard, or manning-shortage. 33 CFR 160.204

This regulation can be used to make a citation for virtually any item of non-operational / defective equipment or condition required by the CFRs and mandates that all failures and conditions on board have to be reported to the relevant CGMSO at once. In these circumstances, wherever possible, prior consultation should be carried out with the appropriate management office first. Any communications to USCG should be made directly to the appropriate Coast Guard Marine Safety Office (CGMSO) by the Master and copied to the local Agent and Management office.

Non-reported defects and repeat violations discovered during a TVE or PSC inspection are normally dealt with severely. When information on the condition of the vessel is reported to the CGMSO prior to arrival or during port call, the CGMSO may impose conditions on the movement into and within the port until the conditions are normalised. Breach of these conditions is a violation, which can result in substantial fines. The company will provide all required support to normalise the deficiency and accepts any conditions impose on the movement of the vessel by the CGMSO.

The USCG operates a system, which results in persistent sub-standard vessels or companies being targeted for inspection. This can result in delays.


Port State Control in the USA Checklist

ALL VESSELS

  1. Manoeuvring data is to be posted on the bridge in USCG format. This must include the required warning notice (33 CFR 164.35{g})
  2. The following tests are to be carried out not more than 12 hours before entering US coastal waters (33 CFR 164.25):
    • Steering gear and systems including alarms and indicators
    • Internal communications and alarm systems
    • Emergency generator and emergency fire pump with simultaneous charging of two fire hoses, one at the bow and one on the bridge wing
    • Storage batteries for emergency lighting and power systems
    • Main engine ahead and astern
    • Engine room and pumproom (if applicable) bilge alarms
    • Bunker tank overflow alarms
    The above tests are to be entered in the deck logbook
  3. Vessel must have appropriate charts and publications for the area to be transited and the port and these must be the latest editions and corrected to the most recent Notices to Mariners (In some ports, UK charts are not permitted and it is necessary to obtain the US charts for the area.
  4. Clear instructions accompanied by a block diagram are to be posted in the bridge and steering flat for operation of the steering gear with instructions for change over to emergency steering operation (33 CFR 164.35)
  5. Oil Transfer Operations (Bunker and Oil Cargo (if applicable))
    a) Oil transfer procedure notice is to be posted (in English and a working language used onboard as required) and permanently displayed on the bridge, in the engine room and by the cargo/bunker control station The oil transfer procedure is to include (CFR 155.750):
    i) List of persons involved in each operation and their duties
    ii) A list of actual names / ranks of those crew members responsible for oil transfer procedures.
    iii) The person in charge (PIC) for transfers of fuel oil bunkers ), and for transfers of liquid cargo in bulk and for cargo tank cleaning (bulk liquid carriers only) must be nominated. For foreign vessels, the PIC of a transfer of liquid cargo or a tank cleaning operation has to have: (33 CFR 155.170(c))

    1) Sufficient training and experience in the relevant characteristics of the vessel.
    2) The correct STCW license for rank issued by flag state
    3) The relevant dangerous cargo endorsement if applicable
    4) The capability of reading, speaking and understanding English
    5) The capacity of communicating with all crewmembers onboard

    iv) Description of each operation giving schematic diagram of pumps, lines, valves etc
    v) Description / location of each shutdown device on relevant pumps / valves
    vi) Procedure for topping off the tanks
    vii) Procedure for ensuring all valves used during the transfer closed on completion of transfer
    viii) Description of deck discharge containment system
    ix) Procedure for emptying deck discharge containment system
    x) Procedure for reporting accidental oil discharge overboard
    xi) Procedure for tending vessels mooring ropes during oil transfer
    xii) Procedure for operating emergency shutdown devices
    xiiv) An appropriate Material Safety Data Sheet (MSDS) for each fuel and grade of cargo being carried. Contact the office if it is not available onboard.

    c) Records which are to be available for inspection by the USCG are:
    i) Remote operation equipment tests
    ii) Internal oil transfer records
    iii) Bunker / cargo lines are to be tested to 1.5 times working pressure and the pressure and test date to be marked clearly on each line. (Annually)

  6. Other records which are required are:
    a) Safety equipment: check all firefighting equipment has been tested and is valid up to date. Have completed records ready for inspection.
    b) Oil Record Books, class certificates and the most recent classification society survey report.
    c) Ensure that a Discharge of Oil Prohibited notice is fixed in a conspicuous place in each machinery space, the bilge and ballast pump control station, OWS, Cargo control room and bridge.
    d) Operational test of the oily water separator, bilge alarm, and the 15 ppm overboard discharge alarm will be made and check on the approval certificate. The marine sanitation device will be examined.
    e) Ballast Water Management Plan and Log and relevant forms
    f) Garbage Log and records including receipts of disposed garbage.
  7. The Master is to ensure that all staff are familiar with the requirements of the ISM Code since the U.S.C.G. inspectors may at any time, ask questions regarding the main elements of the code to ensure the vessel’s compliance. Ensure officer’s are aware of who the DPA is and the DPA’s responsibilities.
  8. In the event of an Oil Spill:
    Ensure that the vessel’s SOPEP or Vessel Response Plan (if applicable) is strictly followed:
    The SOPEP must be approved by Flag State or Classification Society. The VRP (tankers only) must have a valid USCG approval letter.
  9. The vessel must have a copy of the USA Code of Federal Regulations as follows: 33 CFR 1-124, 125-199 (2 volumes) *
    35 CFR (1 volume) Panama Canal vessels only
    46 CFR 1-40, 41-69, 90-139, 140-155, 156-176 (5 volumes) *
    49 CFR 100-177 (1 volume) - for vessels carrying packaged DG only. CFR volumes retained onboard should be current editions and not more than 2 years old
    * Alternatively a vessel may carry US Coastguard #515 (published by Marine Education Textbooks) Vols 1 and 2. These must be current editions.
  10. All SOLAS certificates must be valid with all annual inspections up-to-date. All Officers must have original licences as required by the Flag State onboard and be all ready for inspection. All officers and crew, as applicable, must have required special qualifications, e.g. dangerous cargo endorsements, hazmat, VEC training certificates etc. (if applicable)
  11. Working hours pre-plan for all persons onboard has been prepared which complies with the Code of Federal Regulations governing working hour limitation. Records of working hours shall be available for inspection (VMS/CRW/001 4.1) 0
  12. In addition to the above, we bring to your attention the following:

    a) That bunker save-alls are fitted with steel plugs and all deck scuppers are mechanically plugged during bunkering and oil transfer onboard.
    b) Make up procedure for enclosed entry procedure and post in prominent positions.
    c) Ensure that all port and Company smoking regulations are in force.
    d) Ensure all trading and type approved certificates are valid and ready for inspection.
    e) Ensure means of safe access is rigged in a seaman-like and safe manner and that lifesaving appliance is ready.
    f) Ensure that all officers are immediately identifiable to shore personnel.
    g) That all alcohol is forbidden, REPEAT FORBIDDEN, in US waters. All alcohol is to be removed and placed under lock and key.
    h) Place warning signs. (No visitors / unauthorised personnel / no smoking)
    i) Sewage unit (MSD) or tank functioning correctly and certificate available.
    Ensure that no hotwork is carried out.
  13. Garbage management must strictly be in compliance with Company regulations. Large fines can be levied for incorrect storage and disposal of garbage and in particular plastics. (FORM SAF14) 0
  14. Be aware that the USCG inspectors are carrying out strict emergency drills, fire drills and full abandon ship drills and are picking crew members at random to start emergency fire pump, emergency generator and lifeboat engines. They will require one boat to be lowered into the water if safe and practical. The drills must be carried out promptly and in a satisfactory manner. Unsatisfactory drills account for in excess of 25% of detentions. 0


  15. Additionally , for chemical tankers

  16. The following tests are to be carried out not more than 12 hours before entering US coastal waters.

    a) Cargo pump trips (including manifold, if fitted)
    b) IG plant shutdowns, alarms, 02 analyser and pressure recorder
    c) High level/overfill alarms and audio/visual alarms
  17. Additional records which are to be available for inspection by the USCG are:

    a) Pump tests
    b) Pressure gauge test calibration and certification
    c) Relief valve tests
    d) Internal oil transfer records
    e) Cargo pipe lines are to be tested to 1.5 times working pressure and the pressure and test date to be marked clearly on each line (Annual)
    f) Confirm that VRP is onboard and valid USCG approval letter is at the front.
    g) The Master must ensure that all Senior Officers are familiar with the contents of the VRP. All Junior Deck Officers and watch personnel must be aware of the action to take in the event of a spill. An oil spill training session on the VRP should be held and a log entry made.
    h) The vessel must have logged records of carrying out QI notification drills.
  18. In addition to the above, we bring to your attention the following:

    a) All manifold spill trays are fitted with steel plugs and all deck scuppers are mechanically plugged, including poop scuppers.
    b) Calibrated pressure gauges are fitted to all manifolds
    c) Ensure that all accommodation doors remain closed during cargo operations except for entry / exit.
    d) All sea valves are locked / sealed before entry into USA waters.
    e) Cargo tank oxygen levels must be below 8%.
  19. If a single hulled tanker, then the requirements of 33 CFR 157.455 have been met.
  20. OPA 90 Notification Procedures for Arrival in the United States. Ensure that all relevant organisations are informed of the vessel’s ETAS at the EEZ (200 nautical miles from coast).


    Additionally for Gas Tankers
  21. ESD system tested and operational. Records of test dates maintained. Manifold valves closing times correct.
  22. Cargo tank dome fittings in good condition. Relief valve seals intact. Operating pressures marked.
  23. Deck eyewash’s and showers operational and clearly marked.
  24. High level alarms working and date of last test available.
  25. Fixed Gas Detection System operating. Calibration records and gas available.
  26. Deck Spray system tested. Records of test available.





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