SURVEYS & AUDITS

Difference between Audit, inspection and survey? Are they mandatory?

Survey is a broad concept wherein a particular area or system is examined to check if it is in the right order as required. In many Conventions of the IMO, the words „survey‟ and „inspection‟ are used together. A survey is an overall inspection of various items falling in a particular category. For example, SEQ surveys include inspection of safety equipment’s related to LSA, FFA, navigational equipment’s, etc. The surveys are statutory (or mandatory if not ratified by the Flag) and are to be conducted as per the relevant Convention by the Flag State or RO on behalf of the Flag state.

Inspection is not as broad a term as survey. It is used for particular piece of equipment or item or group of items that need to be inspected. It can be visual general inspection or testing or open-up inspection. For example, inspection of lifting appliances, loose gear, inspection of accommodation, food and water, etc. Some inspections such as PSC inspections can be of a broader nature. Inspections are mandatory if so specified in the relevant conventions.

Audit refers more towards checking the working or functioning of an organization or its system. That is why „audit‟ word is used for ISM and ISPS certification. It refers less to the working of equipment’s but more towards procedures and documentation. Examples of audits are ISM internal audit, DOC audit of the Company, ISPS audit, etc. These are mandatory as per various Conventions unless stated otherwise.
Surveys are conducted or supervised by surveyors of the Flag State or organizations recognized by them. Inspections are conducted by inspectors such as PSCO, responsible person, etc. Audits are conducted by independent third-party auditors.

Difference between Statutory and Mandatory

Statutory means something that is made legal by the Flag State by incorporating it in the National laws and is required to be complied with by statute.

Mandatory means something that may not be part of the Flag State’s National law but required for trading in other States.

Difference between intermediate and periodic? Where is it used?

Intermediate: Intermediate surveys to be carried out in the case of Cargo Ship Safety Construction Certificate, IOPP certificate, IAPP Certificate, surveys required by IBC Code and IGC Code, BWM convention, Class intermediate survey, intermediate verification as per ISPS and ISM Code, etc.

Periodic: Periodic survey to be carried out in the case of Cargo ship safety equipment certificate, cargo ship safety radio certificate (annually) and International Load line certificate.

Periodic survey and renewal survey have the same scope as given in SOLAS. However, intermediate survey does not have such a wide scope as renewal survey. This is the only difference between the two.

Observation and deficiency

As per ISM Code, observation means a statement of fact made during a safety management audit and substantiated by objective evidence.

As per IMO Resolution A. 1138(31) – Procedures for Port State Control, deficiency is defined as a condition found not to be in compliance with the requirements of the relevant convention.

Audit

Audit means a systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled.

As per ISM, who is most important in implementation?

ISM Code does not specify who is most important. It provides an international standard for the safe management and operation of ships and for pollution prevention. In doing so, it requires many things to be done by the Company, mainly establishing procedures, providing resources and conducting internal audits. It requires many things to be done by Master and the ship’s crew, mainly implementing the policies of the Company, complying with the SMS and reviewing it from time-to-time. However, the procedures can be drawn up by the company and audited, however, the implementation part is the responsibility of the Master. Hence, I feel, it is the Master who is the most important in implementing the SMS onboard.

Difference between internal and external audit of ISM

Internal audit is one of the functional requirements for a SMS. ISM Code Element 12.1 requires the internal audit to be carried out onboard and ashore at intervals not exceeding 12 months. In exceptional circumstances, the interval may be exceeded by not more than 3 months. The internal audit can be carried out by a Company representative suitably qualified to carry out the audit or by a third-party company.

External audits are initial audits for obtaining SMC and intermediate and renewal safety management audits that are required to maintain the validity or renewal of the SMC. The purpose of these audits is to verify the effective functioning of the SMS and that any modifications made to the SMS comply with the requirements of the ISM Code. If only one intermediate audit is to be conducted in the 5-year period, it must be conducted between the 2nd and 3rd anniversary date of the SMC. The audit is conducted by Flag State or RO.

Can ship staff conduct Internal Audit?

No, ship staff cannot conduct Internal audits. ISM Code Element 12.5 states that „Personnel carrying out audits should be independent of the areas being audited‟.

During an audit, vessel has got a Major NC. How to go about it?

• Request the auditor to down-grade it to a NC so that vessel has some time in hand to rectify it.
• Immediately inform Company and ask for assistance / spares / stores as required.
• Take it up on a priority basis as the major NC needs to be corrected immediately.
• Fill up the NC form of the Company and forward it to the Company with evidence of the corrective action.

Docking survey

SOLAS I/10 requires a minimum of two inspections of the outside of the ship’s bottom during any five-year period. This is done during the docking survey at a dry dock. It is carried out together with the Class Special survey and other surveys that are part of the HSSC.

Refloating survey

It is the survey that is carried out usually by H&M Surveyors after a grounding incident, which involves supervising the refloating of the vessel to ensure costs are not unnecessarily exceeded and also to later survey the bottom of the vessel along with the Class surveyor when the vessel is moved to a dry dock.

SIRE audit

• One of the most significant safety initiatives introduced by OCIMF is the Ship Inspection Report Programme (SIRE). This programme was originally launched in 1993 to specifically address concerns about sub-standard shipping.
• The SIRE Programme is a unique tanker risk assessment tool of value to charterers, ship operators, terminal operators and government bodies concerned with ship safety.
• The SIRE inspection is conducted by the vetting inspectors of Oil Majors usually once every 6 months or when a shipper (oil major) so requires before chartering the vessel.
• The SIRE programme requires a uniform inspection protocol for which various questionnaires are developed. For example, Vessel Inspection Questionnaire (VIQ), Vessels Particulars Questionnaire (VPQ), etc.
• The inspection scope is very wide concerning safety, security, pollution prevention, operational health, standard of living, cargo equipment’s, etc. as provided in the VIQ.
• The SIRE Inspection reports are maintained on the index for a period of 12 months from the date of receipt and are maintained on the database for 2 years.
• SIRE access is available, at a nominal cost, to OCIMF members, bulk oil terminal operators, port authorities, etc. It is available free of charge to Governmental bodies such as PSC, PSC Mou’s, etc.
• SIRE is a commercial requirement for tankers as charterers or shippers would want to do business with a ship that has a good SIRE inspection report.

Prepare vessel for a load line survey

• Check the load line certificate and condition of assignment of load line and carry checks of all items in that list.
• Ensure no unauthorized modifications are done to any LL item.
• Check the position and markings of all load lines both sides and get it painted if required.
• Check all draft marks and get it painted if required.
• Check hatch covers, booby hatches, hatch vents, weathertight doors, etc. for weathertightness, condition of packing and O/S marks.
• Check all watertight doors for local and remote operation and indications.
• Check all accommodation vents, store vents, mushroom vents, goose neck vents for operation, marking and condition. Greasing to be done as required.
• Inspect all the air pipes of ballast tanks, void spaces, freshwater tanks, etc. for proper operation and condition.
• Check all the storm valves, bilge valves, FPK valves, screw down valves, educator systems and sea chest valves for proper operation.
• Check that scuppers and freeing ports are clear.
• Check that all sounding pipes have cover and adequately greased.
• Ensure lifeline on deck / catwalk is in good condition.
• Ensure guard rails, chains, bulwarks, etc. are in good condition.
• Ensure testing and operation of bilge, FPK and other water ingress alarms.
• If having multiple load line, ensure that only the present applicable LL certificate is in the main file and others are kept in locker.

Prepare for SEQ Survey

• Check all necessary safety certificates are available, including maintenance certificates and service reports of all LSA and FFA.
• Ensure all LSA / FFA manuals are available.
• Check the records of drills, muster and all training records.
• Check all the LSA and FFA maintenance records including their PMS.
• Ensure proper working of lifeboat, life raft, rescue boat, launching appliances, etc.
• Check condition of the davits, wires, blocks, FPD, embarkation ladders, etc.
• Check condition and working of SART, EPIRB and Two-way VHF including expiry dates as applicable.
• Check all LSA and FFA for proper location, working, marking, condition, etc. This includes all lifebuoys, life jackets, immersion suits, EEBD‟s, TPA, LTA, Pyrotechnique’s, isolation v/vs, fire hydrants, fire hoses, foam monitors, fire and foam main, emergency fire pump, fire plans, ISC, fireman’s outfit, fire extinguishers, fire dampers, etc.
• Ensure all fire detectors are working, and fire detection system is in satisfactory condition.
• Check the operation of fire dampers, vents, fire doors, etc.
• Ensure proper working of foam system, Hyper mist system, sprinkler system, etc. and appropriate instructions are posted for the CO2 system operation.
• Check all navigational equipment’s and ensure it is available in good working condition as per Form E.
• Check proper working of the IG system and alarms, trips, NRV‟s, deck seal, O2 calibration, etc.

Prepare for SAFCON survey

• Check if all the required certificates are in order and available.
• Visually examine the hull and note the defects in any.
• Check condition of the deck and de-rust as required.
• Ensure all closing appliances on deck are in good working condition.
• Check all W/T doors for remote and local operation.
• Check all fire doors and ensure that they are in good condition.
• Check that no structural changes are made that will affect the SAFCON certificate.
• Ask the C/E to confirm the M/E, A/E, boilers, pumps, purifiers, FFA in E/R, etc. are in good working order.
• Ensure all escape routes are clear and properly marked.
• Ask the C/E to ensure that M/E, A/E, steering gear, emergency steering, etc. are in good working condition.
• Ensure bilge pumping arrangements and bilge piping is in good condition, bilge wells are clean, and level alarms are working.
• Ask ETO to check all electrical machinery, emergency source of power, emergency lighting, etc.
• Check the condition of the ballast tanks, cargo tanks, vents, P/V valves, flame screens, pipelines for cargo, COW, ballast, bunker, pumproom arrangements, etc.

What is ESP and various documents associated with it.

• ESP stands for Enhanced Survey programme. It is made mandatory under SOLAS XI- 1 Regulation 2 which requires Bulk carriers and oil tankers to be subject to an enhanced programme of inspections in accordance with the ESP Code.
• The ESP came into force in response to the large number of losses of bulk carriers and pollution caused by accidents on tankers. In order to prevent this, enhanced (more stringent) hull surveys were required, for which the IACS has developed the ESP.
• ESP contains unified requirements to be adopted by all Classification Societies while surveying tankers and bulk carriers. The Continuous Hull Survey (CHS) is replaced by the ESP for ships to which it is applicable.
• ESP requires annual, intermediate and renewal surveys that are conducted along with the surveys required by SOLAS I/10 (SAFCON).
• A „survey programme‟ has to be prepared by the Owner and submitted to the RO six months prior to the survey.
• The ESP may be commenced at the 4th Annual Survey and be progressed during the succeeding year with a view to completion by the 5th Anniversary date.
• IMO gives guidelines for preparation for the ESP survey in the form of two annexes –
  • one for bulk carrier and one for oil tankers.

Documents associated with ESP:

1. Survey programme
2. Main structural plans of holds and tanks.
3. Previous repair history.
4. Cargo and ballast history.
5. Records of inspection of these spaces by ship’s personnel.
6. Survey report file containing
   • Condition Evaluation Report
   • Thickness measurement reports
   • Reports of structural surveys
   • Survey planning document

What are the corrosion standards and who defines these standards?

ESP Code defines following corrosion standards:

• Substantial corrosion is an extent of corrosion such that assessment of corrosion pattern indicates wastage in excess of 75% of allowable margins, but within acceptable limits. If substantial corrosion is found, extended thickness measurements will be required.
• Pitting corrosion is defined as scattered corrosion spots/areas with local material reductions which are greater than the general corrosion in the surrounding area.
• Edge corrosion is defined as local corrosion at the free edges of plates, stiffeners, primary support members and around openings.
• Grooving corrosion is typically local material loss adjacent to weld joints.
• The corrosion standards are defined by IMO in the ESP Code and further developed by IACS in their IACS Common Structural Rules.

Close up survey

Close-up survey is a survey where the details of structural components are within the close visual inspection range of the surveyor, i.e. normally within reach of hand.

What is thickness measurement? When and how often is it carried out? How is it carried out?

Thickness measurement is a requirement under ESP Code whereby depending on the age of the vessel, thickness measurements of critical areas are carried out to determine the corrosion levels and the level of constructional safety. All cargo holds, ballast tanks, pipe tunnels, cofferdams & void spaces bounding cargo holds, decks & outer hull are subject to thickness measurements. Minimum requirements for thickness measurements at renewal surveys & extent of additional thickness measurements are given in the ESP Code.

It is carried out during the renewal survey i.e. from the fourth annual survey till the renewal survey. It should not be held before the fourth annual inspection. It is carried out once in five-year period and is required for the renewal survey. It may be required more frequently depending on the age, type, condition of the vessel and previous thickness measurement reports.

Thickness measurements are carried out by qualified firms certified by the Administration according to the principles set out in the ESP Code.

The persons carrying out thickness measurement shall measure the thickness at the forward and aft areas of all plates and the single measurements recorded will represent the average of multiple measurements. Measurements for P & S side with the Gauge corrections, as applicable, are recorded in the Report Forms given in the ESP Code.

The thickness measurement reports are prepared and submitted to the Administration. The reports shall give the location of measurements, the thickness measured as well as the corresponding original thickness. Furthermore, the report shall give the date when the measurements were carried out, type of measuring equipment, names of personnel and their qualifications and be signed by the operator. The surveyor shall review the final thickness measurement report and countersign the cover page.

After grounding, vessel will go for which survey

Vessel will go for an under-water survey or a docking survey to determine the extent of damage.

As per SOLAS I/11, whenever an accident occurs to a ship which affects the safety of the ship, the master or owner of the ship shall report at the earliest opportunity to the Administration, the nominated surveyor or recognized organization responsible for issuing the relevant certificate, who shall cause investigations to be initiated to determine whether a survey, as required by regulations 7, 8, 9 or 10, (10 in this case) is necessary. lf the ship is in a foreign port, reporting must also be done to port State.

As per SOLAS I/10, additional survey for the Safety Construction certificate will be required after the repairs.

[An additional survey either general or partial, according to the circumstances, shall be made after a repair resulting from an accident, or whenever any important renewals are made. The survey shall be such as to ensure that the necessary repairs or renewals have been effectively made, that the material and workmanship of such repairs or renewals are in all respects satisfactory, and that the ship complies in all respects with the regulations.]