Marshall Islands: Additional requirements and new checklist (MSD340) for vessels calling United States ports

During the last months, the United States Coast Guard (USCG) has increased the focus on PSC inspections. This has resulted in an increased number of vessels being detained. For vessels under the Marshall Islands (MHL) flag, the number of detentions has doubled in 2015 compared to the previous years. Therefore, MHL has initiated preventive actions.

To inform and raise awareness, the Republic of the Marshall Islands has issued a marine notice (MN No. 5-034-5) to owners, managers, operators, masters and ROs with information about the increased number of detentions of vessels sailing under the MHL flag and calling at US ports. The notice also aims to reinforce performance and compliance measures as provided for in the RMI Maritime Act (MI-107) and RMI Regulations (MI-108).

In order to prevent detention, MHL has prepared a checklist of 29 items that has to be filled in and submitted to the MHL flag state administrator prior to the vessel’s arrival at a US port. This checklist is in addition to the requested copy of Notice of Arrival (NOA). According to the MHL circular, any failure to follow the checklist could lead to the vessels being detained by the administrator.

To summarise – prior to arrival at a US port, all MHL vessels are requested to:
■ Forward a copy of the Notice of Arrival (NOA), as required by the USCG, to NOA@register-iri.com
■ List any non-operational equipment or systems on the NOA
■ Complete, sign and submit the newly required Critical Items Checklist (MSD 340)

When MHL-flagged vessels are detained in US ports:
■ MHL will carry out an immediate Special Inspection prior to sailing
■ An additional survey by the RO has to be carried out (PSC rectification survey)
■ In case of detainable ISM deficiency, an ISM audit will be required prior to sailing, the scope of which is stipulated by the administrator.

According to MHL, the increase in PSC detentions appears to be due to a number of factors, including:
■ Non-reporting of inoperable equipment or systems
■ An overall lack of maintenance of critical shipboard systems
■ A lack of preparedness for a PSC examination, including a lack of knowledge of the crew to successfully demonstrate normal shipboard equipment and procedures
■ Increased scrutiny of vessel compliance and crew performance by PSC officials
Source: DNV GL