FLEET / SAFETY LETTER 07088.GEN

Over the past year, 2006:

• PSC detentions of Vanuatu vessels remained low (3 for 2006), but higher than we like.
• The number of safety inspections completed was about the same as 2005.
• VMSL has again been audited to IS0 9001-2000 standards with no non-conformities.
• Personal injuries have significantly increased over previous years. Managers and supervisors need to review "job hazard analysis/assessments."
• Poor seamanship/navigation accounted for about 27% of all casualties, a rate much too high! This rate can be reduced by proper training.
• False EPlRB alerts declined but still averaged about two (2) per month.
• Working in conjunction with another ship registry, VMSL conducted a successful "sting" operation against the holder of a fraudulent West African nation's seafarer license.
• Captain Art Bjorkner has joined VMSL as Senior Manager, Safety, Quality and Security.
  

2006 Casualty Highlights:

There were a record number of casualty reports submitted in 2006. A few of the more significant incidents are highlighted here:

• Offshore supply vessel:fire in a storeroom spread rapidly: vessel had to be abandoned. None of the SCBA's functioned properly. Housekeeping & preventative maintenance!
• Log carrier: while the crew was attempting to tighten lashings in heavy seas, a wave washed a young cadet overboard. He was never found. He was not wearing proper lifesaving equipment. Supervision!
• Cable layer: during personnel transfer with a "Billy Pugh" basket in heavy seas, one man fell 10 meters into the sea and died. Job hazard analysis/assessment and communications!
• Fishing vessel: a fisherman was crushed when a winch failed and the boom fell. Lack of maintenance and poor supervision!
• Dive support vessel: on completion of a dive, a diver suffered symptoms of the bends and died during decompression. An autopsy revealed drug use.
• MODUs: in 2 separate incidents lifeboats dropped from their stowed positions, one resulting in injury to an AB. Supervision and seamanship!
  

Looking ahead to 2007 : Registry News and Reminders:

• Vanuatu will be exhibiting at the Connecticut Maritime Association's "Shipping 2007" in March and the International Workboat show in New Orleans this December.
• Annual tonnage taxes are due no later than March 31, 2007.
• Report of Ship's Officers (Form - A7) must be submitted immediately. For non-OSVs and non-fishing vessels, these reports are also due for each officer billet change.
• Vanuatu vessels may be boarded at any time by any port state authority or Vanuatu representative.
• Owners must notify VMSL immediately if vessels are detained or are alleged to have violated IMO Routeing Schemes, Collision Regulations, ITU Radio Regulations, or fishing treaties or conventions.
• Casualties, injuries, deaths, groundings, oil spills and near misses must be reported in accordance with Chapter 7 of the Maritime Regulations.
• Each vessel must have a Minimum Safe Manning Certificate. For self-propelled vessels these must be updated if they do not already address GMDSS or STCW 95 requirements. All deck officers on GMDSS equipped vessels must have GOCs (or higher).
• All ISPS "mandatory" vessels must hold valid lSSCs and have CSRs. lnterim scheme vessels must comply with this requirement by July 1, 2008.
• CRAs will not be sent out unless seafarer applications are complete in all details. We do not process emailed or faxed applications and will not issue CRAs for them.
• The VMSL website now contains a section on the home page entitled "Document Processing Time" which will be updated at least weekly and which provides the current estimated time for processing seafarer document applications among other documents.
  

SOLAS Chapter V, Regulation 20. Voyage Data Recorders (VDR): (Previous provided information is repeated here)

The phase-in carriage requirements for a simplified VDR (SVDR) entered into force on 1 July 2006 as follows: cargo ships of 20,000 gt and above constructed before 1 July 2002, must be fitted with SVDR by the first scheduled dry-docking after 1 July 2006, but no later than 2009. Cargo ships of 3,000 gt or above but less than 20,000 gt constructed before 1 July 2002 must be fitted with SVDR by the first scheduled dry-docking after 1 July 2007 but not later than 1 July 2010.

Alcohol Test Kits:

Ships calling at US ports face a civil fine of up to $5,000 a day if they are involved in marine casualties and do not have federally approved alcohol test kits onboard. The civil fine is prescribed in a new US law that took effect in June 2006 that makes it mandatory for ship owners/operators to ensure that any person onboard involved in "serious marine incidents" be tested witlhin two (2) hours of the episode for alcohol, and within 32 hours for drugs.

BIMCO releases guide to prepare for port state control in the US

To enhance compliance with MARPOL and SOLAS requirements and reduce the frequency of related violations at US ports, BIMCO has made its Guide to Prepare for Port Stale Control Inspections in the USA available at www.bimco.org

IMO Ship Number (all Vanuatu vessels including fishing vessels must have these!):

The IMO ship identification number scheme was introduced in 1987 through IMO re!solution A.600(15), as a measure to enhance ship safety and security. Its aim was to assign a permanent number to each ship for identification purposes. The number remains unchanged upon transfer of a ship to other flag(s) and is inserted in the ship's certificates. It became mandatory for all ships as of 1 January 1996. Shipbuilders/shipowners are encouraged to provide details of all new orders to Lloyd's Register-Fairplay (LRF) for assignment of the IMO number. Requests can be submitted at www.imonumbers.lrfairplav.com.

OPRC - HNS Protocol:

The Protocol on Preparedness, Response and Co-operation to Pollution Incidents by Hazardous and Noxious Substances (HNS), 2000, enters into force 14 June 2007. Ships will be required to carry a shipboard pollution emergency plan to deal with incidents involving HNS.

ISM Code and marine accidents:

Dr. Phil Anderson was invited by the UK Marine Accident Investigation Branch to write an article for their Safety Digest - "Lessons From Marine Accident Reports1". In a section of the, article Dr. Anderson wrote "that accidents or incidents cannot be investigated or analyzed in isolation from the requirements of the IMS Code". When reviewing an incident/casualty Dr. Anderson suggests considering the following questions be asked:

• "Do you think the incident was a result of a non-compliance with some specific section of the ISM Code?"
• "Which specific section(s) of the Code did you identify?"
• "To what extend was the accident a result of a failure of a typical SMS?" "What failures of SMS can you identify?"
• "What procedure should have been in place in the SMS which might have helped prevent the particular incident from happening?"
• "What could be done by way of corrective action to tighten up the SMS to ensure that the chances of the incident being repeated are reduced to a minimum."
  

These questions should be considered when analyzing an incident and in keeping with ISM and SMS by managing safety aboard vessels.

MARPOL Annex IV - Sewage:

Annex IV requirements entered into force on 27 September 2003 and has an immediate effect on all new ships of 400 gt and above and new ships of less than 400 gt which are certified to carry more than 15 persons. It applies to existing ships of 400 gt and above and to ships of less than 400 gt and above but certified to carry more than 15 persons five years after the date of entry into force. A revision to Annex IV entered into force 1 August 2005. The discharge of sewage into the sea is prohibited, except when the ship has an approved sewage treatment plant in operation or is discharging comminuted and disinfected sewage using an approved system at a distance of more than three nautical miles from the nearest land; or is discharging sewage which is not comminuted or disinfected at a distance of more than 12 nautical miles from the nearest land. It applies to new ships of 400 gt and above or which are certified to carry more than 15 persons. Existing ships are required to comply with the provisions of the revised Annex IV by 1 August 2010. The Annex requires ships to be equipped with either a sewage treatment plant or a sewage comminuting and disinfecting system or a sewage holding tank. In addition there shall be a pipeline and relevant shore connection flanges for discharging sewage to port reception facilities.

Lifeboat Inspections:

The IMO MSC.1/Circ.1206 on measures to prevent accidents with lifeboats has been made non-mandatory. MSC has agreed to refer the circular to the Design and Equipment (DE) Sub-Committee for detailed consideration and advice, in order that the final decision of the MSC can be come effective by 2010 at the latest.

Other:

I've included the following as annexes: a complete list of EPlRB alerts in the year; a list of the vessels detained during 2006; a comparison of our fleet safety statistics for the last several years; and an analysis of the 2006 casualties by specific category.

Please review these attachments and note where improvements need to be made.

Best regards,


Donald J Sheetz
Executive Vice President