Let’s add just one more set of questions… This latest “downgrade” of US Flag Vessels on the Paris MOU for PSC raises some serious questions…
Remember, as part of the “new way” that things are being reported in the USCG PSIX effectively counts No-Sail 835’s as Detentions… This is one reason that we’re going to be under increased scrutiny by International PSC Inspections- it effectively raises the points in the Inspection Matrix…
This needs to change soonest. What are our union and elected representatives doing about this in Washington? When are we going to sit down with the USCG and change the way these 835’s are being recorded?
Has the fact that US is not a signatory to MLC’06 been a factor here??
I know that US ships in foreign trade are supposed to be in voluntary compliance and carry some sort of statement from USCG to that effect, but does all PSC Inspectors accept that?
Is it possible to comply with everything in MLC and yet be in compliance with all US rules and regulation? (Refr.; 2.5 d. holiday pay per month of service etc.)
Could be… But yet EVERY action of the PSIX is immediately available to the various PSC entities. This is NOT a question about oversight by the USCG, or us being signatory to anything… It’s a question of how certain 835’s are being recorded in the database- THIS is the problem. I believe it paints a totally unfair picture regarding the diligence of our crews, the condition of our vessels…
To harmonize the Coast Guard’s deficiency data with globally accepted Port State Control (PSC) methodologies, the CG-835V includes deficiency codes and vessel control actions similar to those found on the PSC Form B. For example, the CG-835V includes the addition of Code 30 – Ship Detained as well as Code 17 – Rectify deficiencies prior to departure, which will replace the traditional “No-Sail” control action. A Code 30 – Ship Detained constitutes a Flag State Detention and will be reserved for those serious deficiencies that indicate a serious failure, or lack of effectiveness, of the implementation of the Safety Management System (SMS) or Towing Safety Management System (TSMS). For vessels that are not required to have an SMS or TSMS, a Code 30 – Ship Detained may be used when a substandard condition exists that is not being proactively managed by the company, vessel owner, or operator. Other serious deficiencies that must be rectified prior to the vessel sailing but are not serious enough to warrant a detention may be assigned a Code 17 – Rectify deficiencies prior to departure.
More on the 835 subject- the USCG is changing their form…
On 6/6/18 a US Flag ship was detained in Norway. Detained. Why? An “expired” Cargo Ship Radio Cert- expired my butt- the full force was issued (five year cert) 5/2017- so that means that it was within the Survey Window for Annual. But the PSC Inspectors obviously thought otherwise…
Hopefully this form makes it out there quickly- I wonder what bearing the 835 recording played in this…
I believe that the cert is good for 5 years and the annual survey has a three month window. So seems like they should have had about 60 days. The ship can be detained if the annual is going to come due at sea.
Another possible issue is Form R. In my experience the FCC in the U.S. will not necessary issue a Form R. Also PSC does not like FCC’s forms as they don’t look like the other SOLAS forms.
It’s simpler if the annual is done foreign as the SOLAS cert looks OK to PSC and the Form R is issued without a fight.
Well the Mariner’s Employment Agreements my company has the MLC compliant crews sign says that our day rate is a combined rate that includes OT, vacation, and holiday pays. That what you mean? Because if you mean getting a pay check while we’re on vacation, then nope.
Nope. They stopped doing holiday pay a couple years ago when the bottom fell out of the oil industry. Or at least according to the memo emailed out to the boats by upper management that I have a copy of.
I once worked for a man who had previously been in charge of the service division of National Cash Register – had something like 18,000 working for him I think.
Came the electronics revolution and NCR wanted to sack them all and hire electronics techs. My boss said no, these are clever people and they can learn the electronics – and they did, and he was their hero.
I feel as though there’s a lesson there somewhere for the boom-and-bust types.
As to payment during leave; it is common for most European companies to hire at least the officers on permanent employment to retain them.(Full payment 365d/yr.)
In fact it is compulsory by law in many countries, and/or part of the collective agreement between unions and employers organizations.
The Owners/Managers can’t just say “byby” at will. Labour laws give the employee protection from being fired w/o cause and compensation if laid off due to market situation etc.
Strange I know, but that is how it has been since at least the 1970’s in Europe and other OECD countries.
That’s a great plan, I intend to implement it immediately. Just need to know which line and who’s toes?
The great thing about threads like this is there’s one tantalizing piece of information (U.S. flag ships getting worse!) but no details. This allows everyone to drag out their favorite hobby horse.
I call dibs on excess PC culture. U.S. crews are so busy watching diversity videos and other training demanded by the PC police there is no time to run the ship. If that was done away with the U.S. would soar to the top of the list.