What are the reporting obligations for ships due for an expanded inspection?
A ship has to report 24 hours (24 ETA) before arriving at a port or anchorage of the Paris MoU region or before leaving the previous port or anchorage if the voyage is expected to take less than 24 hours. Thus, this pre-arrival notification has to be reported to all ports in the Paris MoU region the ship calls.The 72 hours reporting obligation (72 ETA) is only required when the ship is due for an expanded inspection.
Reporting Obligations for ships due for an expanded inspection (72 ETA)
Ships due for an expanded inspection have to report 72 hours (72 ETA) before arriving at a port or anchorage of the Paris MoU region or before leaving the previous port or anchorage if the voyage is expected to take less than 72 hours
The following information must be provided to the port authority:
(a) ship identification (name, flag, call sign IMO or MMSI number);
(b) port of destination;
(c) estimated time of arrival (ETA);
(d) estimated time of departure (ETD);
(e) planned duration of the call;
(f) for tankers
i. configuration: single hull, single hull with SBT, double hull;
ii. condition of the cargo and ballast tanks: full, empty, inerted;
iii. volume and nature of cargo;
(g) planned operations at the port or anchorage of destination (loading, unloading, other)
(h) planned statutory survey inspections and substantial maintenance and repair work to be carried out whilst in the port of destination;
(i) date of last expanded inspection in the Paris MoU region.
Be aware that there are other reporting obligations for all ships.
Do High Risk Ships or ships being subject to an Expanded Inspection by ship type and age have to sent the 72 hour's message only if a vessel is due for the inspection?
Each ship eligible for an Expanded inspection shall report its arrival at least three days in advance and shall provide the necessary details. Depending on its Risk Profile and/or ship type and age, the ship has to report when the time window for inspection is open e.g. either from the 5th, 10th or the 24th month onwards.
Should the reporting message be entered into the SafeSeaNet (SSN) data system?
Information shall be provided by the ship or its representative to the competent authorities, who then may provide the information to SSN.
Do all vessels have to announce their arrival 24 hours in advance for PSC purposes throughout the year or only if the time frame (according to the present risk category) is open for an inspection?
The 24 hour requirement is a general requirement. Each ship has to report its arrival at least 24 hours in advance at any time.
Does a vessel have to report ETA72/24 to all ports when calling more than one port consecutively in the Paris MoU or is the report to be made only to the first port in the Paris MoU region?
A vessel has to report 24 hours (24 ETA) before arriving at a port or anchorage of the Paris MoU region or before leaving the previous port or anchorage if the voyage is expected to take less than 24 hours. Thus, this pre-arrival notification has to be reported to all ports in the Paris MoU region the vessel calls.The 72 hours reporting obligation (72 ETA) is only required when the vessel is due for an expanded inspection. Ships due for an expanded inspection are High Risk Ships (HRS) and Risk Ship Type (Oil tanker, Bulk carrier, Passenger ship, Gas carrier and Chemical tanker, which are more than 12 years old). The operator, agent or Master of a vessel shall notify it's arrival at least 72 hoursbefore the expected time of arrival or before leaving the previous port or anchorage if the voyage is expected to take less than 72 hours. Once the vessel has been through the expanded inspection, the 72 ETA is offcourse no longer an obligation.
To whom and in what way do the pre-arrival notification have to be sent?
The final destination of the 72 and 24 hour pre-arrival notifications is the port authority of the respective port. The master could chose to send the information directly, or through the agent, company or any other entity considered appropriate. The contact details of the port authorities to whom pre-arrival notifications have to be sent can be found in the respective Nautical Publications, Almanacs, port guides, webpages and through local agents. The means of communicating the pre-arrival notification depends on the local situation.
Are ships penalized if notices for expanded inspections are sent without being due for an expanded inspection?
No, these ships are not penalized. The reporting obligations for ships are described in Annex 12 of the Paris Memorandum. These obligations are not stopping ships to report more often than required. Although no penalties are issued, the advice is not to report in case the reporting is not required, to prevent unnecessary administrative burden.
How do the risk factors affect Priority I and II?
The risk factors affect on how often a ship will be periodically inspected. Periodic inspections are determined by a time window. Each ship will be classified as High Risk Ships (HRS), Standard Risk Ships (SRS) or Low Risk Ships (LRS) using details of inspections in the PMoU area in the last 3 years.
What are the main differences between Priority I and Priority II?
Each ship will be attributed with a ship risk profile. Depending on the time since the last inspection in combination with the ship risk profile applicable, the ship will be prioritized for inspection. A Priority II ship may be inspected; a Priority I must be inspected. These are no obligations for the ship but for the PMoU member where the ship calls. Priority I status may also be invoked if there is an event triggering an overriding inspection such as when the ship has been reported to be manoeuvring erratically.
In case a Recognized Organisation is not listed in the table “Recognized Organization Performance” how will this affect the Ship Risk Profile (SRP)?
Ships with a Recognized Organisation which is not listed in the table “Recognized Organization Performance” can not be a Low Risk Ship (LRS). The following criteria are not fulfilled:
- Recognized Organization to be high performance, and
- recognized by one or more Paris MoU members.
Furthermore, for the calculation of the High Risk Ship (HRS) profile, the ship will not gain any points for the criterion Recognized Organization performance as the RO does not appear on the Paris MoU list.
Will it be possible to see on the public website of the Paris MoU a list of States which have undergone the Voluntary IMO Member State Audit Scheme (VIMSAS)?
There will be no information on the Paris MoU public website to indicate which State has undergone the VIMSAS.This information is distributed by an internal IMO Circular which is not publicly available. Individual States may decide to make the information publicly available, but there is no requirement to do so.States are invited to inform the Paris MoU Secretariat as soon as an audit has been concluded. However, according to paragraph 12 in Annex 7 of the amended memorandum, the Paris MoU Secretariat will maintain on the Paris MoU public website an up-to-date list of flag States which meet the flag criteria for a low risk ship. Accordingly flag States figuring on this list will all have been through the voluntary IMO Audit and will be a white listed flag.
What will be the Ship Risk Profile and the Priority of a new building not inspected in the Paris MoU region?
The Ship Risk Profile of a new building not inspected in the Paris MoU region will be either Standard Risk or High Risk depending on the generic Factors (Flag, RO, Company performance and ship type). A new building can never be Low Risk since one of the criteria for Low Risk Ships (inspected within the last 36 months) is not fulfilled. New buildings will be Priority I (PI) and subject for inspection when arriving to the Paris MoU region for the first time.
Will the PSC history of a ship stay with the ship in case it is changing the company?
The PSC history of a ship will not be deleted in case it changes the company. For the calculation of the historic parameters "Number of deficiencies recorded in each inspection within the previous 36 months" and "Number of detentions within the previous 36 months" a change of company has no effect. The ship's PSC history will not affect a purchaser's company profile, but will remain to affect the seller's company profile for a period of 3 years.
In case of a badly hand written report can the company request a printed report?
PSC inspection reports can be printed or hand written. In case the handwritten report is not legible, the master may request a printed report from the port State. However, there is no legal requirement for the port State to issue a printed report.