According to this deficiency alert, the detention rate of FSC inspections in Qingdao area has remained high recently, mainly targeting oil tankers completed between 2011 and 2014. Moreover, some detention deficiencies have recurred repeatedly. There are 20 major types of detention-triggering non-compliances in total, among which 3 are relatively uncommon. Specific detention-triggering items are listed as follows:

Detention Item 1: The two independent release control devices of the fixed CO₂ fire-extinguishing system are not equipped with feasible devices and measures to ensure sequential operation.

This deficiency is quite common, and the relevant requirements are similar under both domestic regulations and SOLAS, its corresponding provision in SOLAS is Regulation 5.2.2.2 of the FSS Code:

1. two separate controls shall be provided for releasing carbon dioxide into a protected space and to ensure the activation of the alarm. One control shall be used for opening the valve of the piping which conveys the gas into the protected space and a second control shall be used to discharge the gas from its storage containers. Positive means shall be provided so they can only be operated in that order; and

Detention Item 2: Malfunction of the automatic audible alarm prior to the discharge of the fixed carbon dioxide fire-extinguishing system.

Functional failure; a standard detention item.

Detention Item 3: Incorrect location of the fire isolation valve on the fire main.

Inspection of isolation valves on the main fire pipeline has been extended from PSC to FSC. Domestic trade vessels shall raise standards to keep up with international practices. Refer to the editor’s article: 27 Deficiencies & 7 Detentions: Failure to Open Fire Isolation Valves Also Results in Detention – Check It Now!

Detention Item 4: Two generator engines share the same fuel supply source, and the isolation valve of the engine fuel supply pipeline is installed adjacent to the motor, failing to meet the requirement of "operable from a location that remains accessible in the event of any engine fire".

The issue of shared fuel line isolation valves for auxiliary engines has been fully explained by the editor. Refer to: Trivial Yet Critical: Attention to Singapore Detentions – New Detention Trigger for Isolation Valves!

Domestic maritime regulations added requirements (5m away from the diesel engine, with shielding protection or remote control) after the 2016 Amendment. Inspectors shall verify the applicability based on the vessel’s construction year, as there is no retroactive requirement.

Detention Item 5: Malfunction of the engine room oily water separator, unable to start.

Standard detention item; no further explanation.

Detention Item 6: Malfunction of the 15PPM oil content meter of the engine room oily water separator.

Standard detention item. Inspectors may poke the detector or check the sample water pipeline. The editor has covered numerous such detention cases in previous PSCReady articles.

Detention Item 7: Incorrect installation of the recirculation device on the overboard discharge pipeline of the oily water separator (installed before the three-way valve).

This is not just a deficiency; disassembling the pipeline and finding evidence of oily discharge will result in a fine!

Detention Item 8: The ventilation cowl (starboard) of the cargo pump room cannot be fully closed (the cargo pump room is protected by a fixed carbon dioxide fire-extinguishing system).

Standard detention item. Inspectors (PSCO/FSCO) generally check all fire dampers of fans thoroughly.

Detention Item 9: No thermal insulation material laid on the deck separating the area under the wheelhouse console from accommodation spaces, failing to meet the A-60 class fire-resisting division requirement.

The wheelhouse is a control station with stringent fire protection ratings. As the editor recalls in PSCReady content: For the horizontal sides of a control station, the division adjacent to the open deck shall be steel-structured; adjacent to stairwells/corridors shall be Class A0; adjacent to other spaces shall be Class A15 or A60. For the vertical sides, divisions adjacent to accommodation spaces, Category A machinery spaces or ro-ro spaces shall be Class A60; adjacent to other spaces shall be Class A0.

Experienced PSCOs/FSCOs tend to check all kinds of openings thoroughly when inspecting control stations.

Detention Item 10: Observation hole of the small hatch cover of the main deck cargo oil tank rusted through, with obvious air leakage during loading operations.

Detention Item 11: Failure of the launching davit for the rescue boat and davit-launched life raft, rendering the rescue boat and life raft unable to be released.

Common detention item.

Detention Item 12: Failure of the quick-closing valve of the engine room oil tank or emergency generator oil tank.

Common detention item.

Detention Item 13: The mechanical ventilation fan in the cargo pump room incorrectly adopts suction-type instead of extraction-type ventilation.

Both IBC Code and domestic regulations require that cargo pump room ventilation fans shall meet the criteria: mechanical ventilation + extraction-type + spark-proof fan + 20 air changes per hour. This can be confirmed by checking the type approval certificate.

Detention Item 14: Malfunction of the power failure alarm on the fire alarm panel

Standard detention deficiency

Detention Item 15: Seizure of the starting air motor of the emergency generator in the emergency generator room, unable to start with compressed air

Standard detention deficiency

Detention Item 16: The engine room sludge tank is fitted with a discharge connection to the bilge water system

Uncommon detention item; few inspectors would check for this deficiency. FSCOs/PSCOs must have a good knowledge of pipelines – first check the piping arrangement diagram, then verify the on-site layout.

The bilge water system is required by SOLAS while the sludge tank is governed by MARPOL; the two systems are strictly prohibited from unauthorized interconnection.

In principle, bilge water may be discharged into the sludge system, but sludge oil is strictly forbidden to enter the bilge water system. The sludge oil system must not have open connections for hose attachment; discharge to shore shall only be conducted via standard connections.

For ships built prior to 2014, some are not equipped with a dedicated daily bilge pump; instead, they use the sludge pump as a dual-purpose daily bilge pump.

The figure above shows such a vessel in its original design. This ship is fitted with a bilge water tank (which is not mandatory), but there is no dedicated bilge pump connected to this tank. Instead, the sludge pump is used for dual purposes. The two main pumps in the bilge and fire-fighting system—the general service bilge pump and general service fire pump—cannot discharge bilge water from the engine room bilge wells into the bilge water tank. Bilge water can only be transferred from the bilge wells to the bilge water tank via the sludge pump, which inherently allows the sludge pump to directly discharge sludge oil into the bilge water tank—a practice that is strictly prohibited.

Such a system also brings great operational inconvenience. The ship management company shall arrange in advance the submission of design drawings for approval and on-site modification.

Detention Item 17: No pressure relief valve installed on the closed pipe section of the fixed carbon dioxide system.

This is also a new type of detention trigger. The requirement for pressure relief valves on pipelines is specified in FSS Code Regulation 5.2.1.2.4: For parts of the pipeline where valves are connected to closed piping, these parts shall be fitted with pressure relief valves, with the outer ends of the valves leading to the open deck.

There are two types of such valves: diaphragm type and spring type. There are industry rumors that diaphragm-type valves are prohibited. The alleged reason is that the diaphragm is damaged after pressure relief and cannot reset, impairing functionality. However, these are only rumors—no such deficiencies have been issued by PSC so far, so they are unreliable.

A conventional CO₂ system generally has two pipelines routed to the deck for pressure relief: one for relieving pressure from the CO₂ cylinders and the other for pipeline pressure relief. The figure below shows the layout of the CO₂ system discharge pipelines on a vessel, which experienced inspectors will check at first glance.

This vessel was subject to detention due to the absence of pressure relief valves on the pipelines. The diagram below depicts the configuration after rectification.

Detention Item 18: No audible and visual alarm for steering gear control power failure in the wheelhouse.

Standard detention deficiency.

On some vessels, the power failure alarm for the control system and that for the power system of the steering gear alarm panel share a single alarm light. If crew members are not sufficiently familiar with the equipment, they may fail to conduct the control system power failure test correctly. China’s domestic maritime regulations do not explicitly specify whether alarm lights can be shared. IMO Resolution Res.A.1021(26) requires that separate visual alarms for these two types of power failures shall be installed on the wheelhouse, yet domestic regulations do not reference this resolution.

Detention Item 19: An additional bypass pipeline connection is installed at the outlet of the sludge pump, which is inconsistent with the approved survey drawings.

This deficiency has recurred repeatedly. The reason for adding an extra pipeline connection at the sludge pump outlet may be that crew members intend to steal oil using this pump. In the FSC report, the regulatory provision cited for this deficiency does not fall under the pollution prevention chapter, but rather pertains to the consistency between the vessel's actual condition and approved drawings.

Detention Item 20: The wheelhouse door of the chemical/oil tanker cannot maintain airtightness. SOLAS, IGC Code and IBC Code all require airtightness for wheelhouse doors of chemical/oil tankers. Since the wheelhouse is not a hazardous area, these doors are only closed to prevent gas ingress when large amounts of gas are emitted during cargo operations such as loading and unloading.

Such doors are generally side-sliding. After closing, the rubber gasket around the door frame inflates and bulges to fit tightly against the door, thereby achieving airtightness. As compressed air is used to inflate the rubber gasket, damage or loss of the gasket and leakage in the compressed air pipeline will both cause the door to fail to maintain airtightness.

Under domestic regulations, this requirement applied to oil tankers of 500 gross tons and above in the 1992 Technical Rules for Statutory Survey of Sea-going Ships, and has applied to liquid cargo ships of 2,000 gross tons and above since the 1999 Technical Rules for Statutory Survey of Non-International Voyaging Ships.

-------------------------------------Reprinted from PSCReady