Every three months Inserve Yachts sends out a safety and compliance bulletin to each of its yachts to inform them of changes to legislation or safety related issues which have a direct impact on the operations of the yacht. Below is an abbrievated version of the latest safety and compliance bulletin:

Safety & Compliance Bulletin 36 - May 2017

STCW / MLC / Certification Information

1. Sea Service Verification on Large Yachts

The MCA have issued MIN 543 Seafarer Service Notification on Large Yachts which came into force from 24th May 2017.  After this date, all yacht crew applying for a Notice of Eligibility (NoE) or for the renewal of a Certificate of Competency, must provide evidence of their qualifying sea service in the form of correctly completed Sea Service Testimonials, which is verified by the Professional Yachting Association (PYA) or Nautilus International.  The MCA will continue to provide direct verification of sea service on individual applications but the MCA may take up to 160 days to process applications that do not include a completed PYA or Nautilus Record Book. 

LSA / FFE equipment information

Nil

MARPOL

1. Sludge Piping

The Marshall Islands have issued MN 2-013-3 Oil Filtering Equipment and Control of Operational Discharge of Oil which supersedes Rev 12/10.  It reflects amendments to the sludge piping requirements under MARPOL which has been in force since 1st January 2017.  

The amendments require the sludge piping of ships 400GT and above constructed before 1st January 2017 to be arranged to comply with paragraph 3.3 of the revised MARPOL Regulation I/12 not later than the first renewal survey on or after 1st January 2017.

Sludge may be disposed of directly from the oil residue (sludge) tank to reception facilities through the standard discharge connection referred to in MARPOL Regulation I/13, or to any other approved means of disposal of oil residue (sludge), such as an incinerator, an auxiliary boiler suitable for burning oil residues (sludge), or other acceptable means, which shall be annotated in the Supplement to International Oil Pollution Prevention (IOPP) Certificate.

The MARPOL interpretation allows the use of a screw-down non-return valve in lines connecting to common piping leading to the standard discharge connection required by MARPOL Regulation I/13, for the prevention of sludge being transferred or discharged to the bilge system, oily bilge water holding tanks, tank top, or oily water separators.

Technical / Engineering information

1. Changeover from High to Low Sulphur under the IAPP Certificate

At a recent Class survey, the surveyor requested to see the yacht’s Standard Operation Procedure for changing over from high to low sulphur oil.  This was after the yacht confirmed that high sulphur (e.g. 3.5%) has never been taken.

General Regulatory and Safety information

1. MAIB Safety Digest

The MAIB have recently issued Safety Digest Volume 1, 2017.  This contains short accounts of accidents describing what happened and lessons to be learned.

2. Radio Regulations Amendments and GMDSS Radio Equipment Updates

The MCA have issued MGN 562 which draws attention to the changes made in the Radio Regulations which came into force 1st January 2017 affecting VHF and HF radio communications and equipment.  Extensive changes have been made to appendices 17 and 18 of the Radio Regulations.  Whilst these changes do not affect the GMDSS, they do affect the use of other frequencies that would be used by services such as Port Operations and VTS.  In accordance with MSC.1/Circ. 1460/Rev 1, HF radiocommunication installations should meet the channelling arrangements reflected in part B of appendix 17 to the Radio Regulations by the first radio survey after 01/01/2024.

3. Fatigue

AMSA has published the fifth issue of the Maritime Safety Awareness Bulletin – Shaping Shipping for People.  This issue focuses on fatigue as a safety hazard.  The nature of vessel operations means seafarers are exposed to conditions which lead to fatigue.  Insufficient sleep, night work, irregular and long working hours, monotonous tasks and high work demands are all frequently present in seafaring jobs.  The need to manage the risk of fatigue - both at the individual and management level - is critical.  The Bulletin provides information on the causes and consequences, and strategies to help reduce the associated risks of fatigue.

4. COSWOP

At a recent Cayman Island survey, it was confirmed that E-copies of COSWOP are acceptable onboard provided they are available to the crew.  After further clarification on this it is seen that the Regs4Ships or internet access would meet this requirement.

5. Port State Control Detentions

Class Society ABS have issued Guidance for Reducing Port State Detentions, Pre-PORT Arrival Quick Reference, which identifies the categories and items which have been identified as top Port State detention items on board ABS classed vessels.  This guide serves as an extremely useful tool for any yachts expecting a PSC inspection and we recommend it is used in pre-port arrival preparation, especially for those visiting US ports.

6. Vessels Entering US Ports

The USCG have issued Port Security Advisory (1-17).  This advisory provides guidance for vessels and US Ports as it relates to vessels that arrive in the US upon or after 14th April 2017 after visiting the ports in the countries listed in the advisory, that have been determined to not maintain effective anti-terrorism measures.  There are actions that vessels must take if they have visiting one of the countries listed during their last five port calls.

7. Cyber Attack

After the recent worldwide ransomware attack on Windows-based computer systems a cybercrime specialist working for a mobile device company demonstrated the vulnerabilities of a superyacht's IT systems.  Using a yacht's WiFi connection they were able to gain control of many vital functions including navigation and the onboard CCTV.  According to the report the key vulnerability was the high-power WiFi router.

There have also been reminders of the dangers of using USB sticks that have not been virus checked or charging mobile phones on the USB port of a computer or even the ECDIS server.

8. Pilot Transfer Arrangements

The Republic of Marshall Islands (RMI) Registry issued a circular informing on means of ship embarkation/ disembarkation and pilot transfer arrangements, as regulated by SOLAS.  Inspections and tests to confirm proper construction, installation, operation, and maintenance of equipment shall be conducted in accordance with SOLAS Regulations and ISO Standards.

Any pilot embarkation arrangements onboard the yacht should meet the equivalent standards of the circular with respect to inspection and test.

It is recommended where means of embarkation and disembarkation other than those specifically covered by IMO Circular MSC.1/Circ.1331 are fitted, an equivalent level of safety must be provided.

9. Ship Sanitation Control/ Exemption Certificates

The USGC has issued a Marine Safety Information Bulletin 005-17 providing details on obtaining Ship Sanitation Control/ Exemption Certificates (SSEC).  It is important to note that currently ships cannot obtain an SSEC in any US port.  Port authorities, public agencies and private organisations in the US are prohibited from issuing SSECs for vessels in US ports.  With this in mind, yachts visiting the US should ensure the vessel’s SSEC is valid before entry and for the period that the yacht is likely to be in US waters when possible.