One of the most important roles a flag State can play is to support owners and operators in their efforts to comply with national and international rules and regulations. Since March 2020, maintaining a regular inspection regime has been challenging. Many stakeholders, including owners and operators, flag States, Classification Societies, and even PSC authorities have had to adapt to ever changing global conditions and restrictions. The Republic of the Marshall Islands (RMI) Registry has worked alongside these other stakeholders, including PSC authorities, with the common goals of safety, security, environmental stewardship, and crew welfare. In fact, the RMI remains the only quality registry of the three major flags holding positive indicators in every category, with no exceptions, on the International Chamber of Shipping 2021/2022 Shipping Industry Flag State Performance Table.
“Identifying potential risks before a vessel comes into port and ensuring the owner/operator safety net remains intact is a key to reducing the risk of unnecessary and costly deficiencies or detentions,” said Brian Poskaitis, Senior Vice President, Fleet Operations of International Registries, Inc. (IRI) which provides administrative and technical support to the RMI Registry. He continued,
In many cases, the pandemic disrupted the layers of risk reduction – such as normal inspection regimes, standard crew change schedules, the ability to get spare parts, and general oversight of vessel operations. Vessel crews are doing the best they can to ensure the ship and its cargo gets safely to its destination. However, often the common safety items such as firefighting equipment and systems and/or lifesaving appliances go unchecked. Absent this layered approach to risk management, many items that are not part of the normal process to navigate the vessel or handle the cargo, go unchecked and may pose a risk to vessel and crew safety. In our experience, strict compliance with the Critical Items Checklist (CIC), which reviews the most common areas for deficiencies, and addressing and reporting any areas of concern before a vessel reaches port helps to supplement this gap in the layered approach to vessel safety. Vessels and crews that treat the CIC as a paper drill or “gun-deck” it, are faced with deficiencies, delays, and even detentions. Those that physically perform the checks prior to arrival, sail smoothly through inspections when arriving in port.
To further support vessels in preparation for PSC inspections in the United States, the RMI Maritime Administrator issued Marine Safety Advisory (MSA) 05-22 Preparation for United States Coast Guard Port State Control Exams in February 2022 as a reminder of the importance of verifying the checklist. Increased stressors on crew during the pandemic have made it difficult to always physically verify items from the checklist and there have been instances of crew simply signing off. The MSA reiterates that resources and support are available from the flag State and its experienced inspection team.
Registry representatives have been meeting in-person with PSC authorities around the world over the last several months to get a PSC perspective on trends and high-risk areas they are seeing, as well as to share how the RMI is supporting compliance of its fleet. Brian Poskaitis, Heath Hartley, and Guy Theriault met with the United States Coast Guard’s (USCG’s) Marine Safety Unit, Portland Oregon; Rear Admiral (RADM) Kevin S. Cook, USCG (Retired), met with USCG District 8 (New Orleans); James Maupin and his team in Houston regularly meet with local USCG Prevention Departments within their region; and IRI President Bill Gallagher, recently met with RADM John Mauger at USCG Headquarters in Washington, DC, to facilitate discussions, learning, and awareness between the RMI Registry and the USCG.
“Learning directly from PSC authorities about what they are seeing on board and engaging in an active dialogue with them on what we are seeing on board fosters positive working relationships that are collaborative, and result in improved compliance,” said Brian. He continued:
In a perfect world crews and ship management companies would identify and address any critical deficiencies and make every attempt to resolve those deficiencies in a timely manner not seeking dispensations or extensions for service intervals. However, at the moment we’re dealing with very challenging circumstances as a result of the inability to board vessels at port, for crews to change in a timely fashion, or to get the necessary spares to ships. We want to do everything we can do to support our vessels and their crews, to assist with managing risk, and fostering safe vessel operations.
Hans Krijger, General Manager, IRI Roosendaal, agrees that the challenges of the pandemic continue to create operational challenges. “The crew change crisis has led to a mental health crisis among the seafarers of the world. That, coupled with the inability to maintain normal inspection regimes, means that owners, operators, PSC authorities, and flag States need to go the extra mile to monitor vessels right now and make sure everyone is on track.”
The long-term impacts of the pandemic may not be fully realized for years to come. What is clear now however, is that the condition of the tonnage entering the world’s ports is not what it was before the pandemic, and that seafarers remain in crisis. To provide the highest quality support for RMI flagged vessels and the crews that operate them as they continue to work tirelessly in challenging conditions, the Fleet Operations team will continue to not only inspect its fleet, but also promote the proactive behavior of crew, owners, and operators in an effort to bolster quality operations and smooth sailing.
