Purpose
This marine notice draws the attention of vessel operators to the importance of planned maintenance in ensuring safe operation of ships, and highlights AMSA’s focus on planned maintenance during port State control (PSC) inspections.
Recent incidents have demonstrated the potentially serious consequences of a lack of effective maintenance of main engines and power generation systems that pose serious risks to the safe and pollution-free operation of ships. In response, AMSA has increased its focus on planned maintenance during routine PSC inspections to protect the safety of the crew, the ship and the environment.
The International Safety Management Code (ISM Code)
The ISM Code is implemented in Australia through the Navigation Act 2012 and Marine Order 58 (Safe Management of Vessels).
The ISM Code requires maintenance of the ship and equipment, including that:
- maintenance inspections are held at appropriate intervals
- any non-conformity is reported, with its possible cause, if known
- appropriate corrective action is taken, and
- records of these activities are maintained.
In relation to maintenance, the ISM Code specifies that the ship’s safety management system (SMS) should:
- identify equipment and technical systems that would cause hazardous situations if they were to suddenly fail, and
- provide for specific measures (i.e. regular testing of all equipment including stand-by equipment or systems that are not in continuous use) to ensure the continued reliability of such equipment or systems
Maintenance activities need to be properly resourced, and procedures must be documented.
Global supply chain issues
Given the potentially serious consequences when effective maintenance has not been completed, AMSA has increased focus on planned maintenance during routine port State control inspections to protect the safety of the crew, the vessel and the environment. AMSA recognises there are supply chain challenges post the COVID-19 pandemic, and that these are exacerbated by additional regional challenges. AMSA expects operators to anticipate these challenges and to make provision to address them in planning maintenance to minimise impact. Specific measures already implemented by a Company as required by the ISM Code may need to be reviewed to ensure that those specific measures remain effective. This includes the ability to obtain spare parts expediently for equipment and technical systems that would cause hazardous situations if they failed.
In circumstances where spare parts cannot be provided, AMSA expects the ship operator will have consulted with equipment manufacturers, classification society and flag State in preparing appropriate measures to ensure the continued safe operation of equipment and the vessel. This could include for example the reduction in maximum continuous rating of an engine, or provision for towage services in coastal waters.
Inspections
During PSC inspections, AMSA will place a greater focus on planned maintenance of propulsion and auxiliary equipment and associated systems and will take necessary compliance actions to address any identified areas of concern. This may include requiring the physical attendance of classification society surveyors to verify the condition of critical equipment and its suitability to continue to function under all voyage conditions to maintain safe operations.
Operators should note that this is not a Focused Inspection Campaign (FIC) or Concentrated Inspection Campaign (CIC) of limited duration. It is a sustained focus on an identified area of concern that is part of AMSA’s data driven and risk-based approach to our PSC inspection regime.
Further reading
Recommendation 74 A Guide to managing maintenance in accordance with the requirements of the ISM Code- Rev.2 Aug 2018 (International Association of Classification Societies). Accessed https://iacs.org.uk/resolutions/recommendations