Effective SIRE reponses
There are some fundamental facts and principles we should refresh and which every operator should keep in mind while responding to SIRE observations. I’m sure we are all aware of these things already, however it is of utmost importance to keep them in mind while writing owner’s responses. This will probably be especially helpful to newer superintendents…
- SIRE RESPONSES NEED TO SATISFY ALL OIL COMPANIES. I think the reasons are obvious, as anyone looking to charter your ship is going to pull it up and risk assess the report. If they don’t understand it fully, they will reject the vessel and you will probably get a call from your time charterer (in case of TC vessels)! So from an operator’s response perspective, which company conducted the SIRE inspection should have little bearing when it comes to the actual responses. Also many of these companies may not appreciate each other to the fullest extent (for lack of a better expression) and don’t like their names mentioned in public without solid reason. Hence I would advise to keep lines like ‘A (oil company) advised to install ISF Watchkeeper’ out as it takes on a whole new meaning when B (oil company) or C (oil company) is looking at it to clear the vessel.
- NO OTHER ORGANIZATION, EXCEPT PROBABLY THE INSPECTING OIL COMPANY, HAS ANY EXTRA KNOWLEDGE OR SEPARATE DETAILED REPORT ABOUT THE INSPECTION, APART FROM THE SIRE REPORT. This is especially important and hence every effort should be made to clarify the inspector’s observation accurately. An incorrect observation should be politely refuted. For others the exact detailed circumstances of the observation should be presented. Please note all examples used are actual cases.
VIQ: 4.36: Port side ECDIS was not operational
Service engineer has attended the vessel and was unable to rectify the problem due to time limitation. Service engineer will return in next port to complete the service. Port ECDIS still operational, Port ECDIS has limitations in functionality.
Looking at the response it is not clear if ECDIS is the primary mode of navigation on the vessel. If it is then the port ECDIS being out of order becomes a big deal. Secondly, inspector has been refuted saying it is operational with limitations, however not stated what the limitations are. The more detailed information provided helps immensely with the risk assessment of the clearance department of any oil company as they get a clear picture of what’s going on. If your vessel is the only one presented for that particular business, then they will come back with clarification requests. However if 8 vessels were presented for the same business and they are not clear on your responses, they might simply reject the vessel as that is the easy route as there are lots of other options for that voyage.
- IF PERTINENT PRESENT A BRIEF REASON FOR WHY THE OBSERVATION TOOK PLACE. This can totally help an oil company assessor with understanding what’s going on.
VIQ: 4.35: Inspector Observations: The navtex receiver was observed to be switched off. Same was switched on, on same being pointed out by the inspector. In addition there was no evidence to indicate that the warnings received had been initialled by the OOW’s since a considerable period of time till date.
Master instructed to keep Navtex on at all times. Label “Do not switch off” has been posted above unit. Company procedures “COMPANY GUIDELINES FOR
MAINTAINING AND FILING NAVIGATIONAL MESSAGES” clearly state all navtex messages are to be signed, master instructed to comply with this procedure.
Why was the navtex switched off? Was it forgetfulness? If it was, does it say on any checklist (passage planning checklist) to ensure these things? If the checklist is adequate then why is it not being followed? Is it too lengthy or are people unaware of the importance and benefits of checklists? Of course looking at the response, I do not know the exact reasons and hence speculating. The point I’m trying to get across is an oil company vessel assessor might have similar questions as he/she probably has the same amount of information we have right now. Hence the importance of explaining everything.
- FEW IMPORTANT RISK ASSESSMENT POINTS SHOULD BE INCLUDED IN A RESPONSE WHERE THERE IS A TEMPORARILY UNACCEPTABLE SITUATION. The vessel assessor is actually conducting a risk assessment of your vessel to safely and timely carry their cargo based on the SIRE report. So your risk assessment of any temporary abnormality greatly assists and gives confidence to them to clear the vessel.
VIQ: 8.087: The pump room gas detection system was out of order.
2 sensors (HC and H2S) are failing. New sensors has been received on board Final adjustment will be done by service engineer of the makers at next port. Atmosphere in pump room is monitored presently manualy by crew by means of portable multigas meter on board.
What additional steps are being taken while the pump room gas detector is out of order? As mentioned, manual checking of gas, is probably standard procedure even with the gas detection system working. So what extra procedure is being done to mitigate the risk posed by a fixed gas detection system out of order. Even if you don’t think anything else is required (I’m not saying that should be the case here), do try to present a brief risk assessment as it is better than a vessel rejection.
- CLEARLY STATE A LONG TERM PREVENTIVE ACTION –
VIQ: 12.20: The clothes drying room has plastic buckets and mops stored in it.
Buckets and mops have been removed. Crew explained and instructed that drying room should not be used as storage. Will be shared in vetting bulletin to the other vessels in the fleet.
How will the next lot of personnel be aware, not to put plastic mops in the drying room (this is just an illustrative example)? Would a poster or a fleet wide safety campaign be a good idea encouraging near miss reports on such issues? Is this safety item mentioned in the initial ship safety familiarization training checklist? A vetting bulletin has been mentioned – as an outsider I am not sure if all personnel (on board and on leave) are required to read and discuss this (although I’m sure that is the case). Mentioning this fact will make it absolutely clear.
- BE VERY AWARE OF YOUR TMSA RESPONSES AS OCIMF MEMBERS TRACK VETTING OBSERVATIONS AND RESPONSES IN CORELATION TO YOUR TMSA RESPONSES – I know you’re aware that this was a new things OCIMF started last year and it is their way of cross-checking your TMSA responses and stages as compared to your fleet vetting performances. So it is another reason to probably be conservative on your TMSA responses.