On 15 April 2025, Tianjin Port PSC conducted a PSC inspection on a bulk carrier flying the Liberian flag and issued two deficiencies. The vessel was built by Zhoushan COSCO Heavy Industry, with its keel laid in March 2024 and launched less than a year ago.

For relatively rigorous PSC inspections, two deficiencies are within an acceptable range and will not raise the vessel’s risk level, but certain details identified during the inspection merit industry-wide learning.

01Both deficiencies are pre-sailing rectification (Code 17) deficiencies:

07109 Fixed fire extinguishing installation One third area for paint drum not covered by water sprinkler system in paint room.

This deficiency means one-third of the area in the paint room (where paint drums are stored) is not covered by the water sprinkler system.

We have covered this deficiency multiple times.

This is a frequent target for PSC inspections. Experienced PSCOs will first tap the pipes to let rust and debris settle before testing the paint room sprinkler system—otherwise, the nozzles might get clogged during the test, or the spray angle may fail to cover the entire paint storage area.

Subsequently, PSC will ask the crew to place a bucket underneath to catch the water and observe the spray pattern. For instance, a straight spray like the one shown in the figure below is definitely unacceptable.

Standard deficiency description: Paint store fixed fire fighting system – nozzle missing/malfunction.

Of the two figures below, one shows sprinkler nozzles obstructed by ventilation pipes, and the other shows paint drums stacked too high for the sprinklers to reach, which fails to achieve effective fire extinguishing. Both situations are unacceptable.

This case inspected by Tianjin MSA is somewhat special as it involves deficiencies on a newly built vessel.

Newly built vessels generally do not have issues with failed water spray; PSC will only check if the spray coverage is sufficient. However, the paint racks on this new vessel were installed too high, and a section of the water sprinkler pipeline was left unconnected, resulting in a deficiency issued by PSC.

Obviously, this is a shipbuilding defect and has nothing to do with the crew. Logically, the classification society should be held accountable, but it remains unclear how it was actually handled.

The basis for this deficiency is found in Regulation 10.6.3 of Chapter II-2 of the SOLAS Convention, the original text reads:

3 Spaces containing flammable liquid

6.3.1 Paint lockers shall be protected by:

1 a carbon dioxide system, designed to give a minimum volume of free gas equal to 40% of the gross volume of the protected space;

2 a dry powder system, designed for at least 0.5 kg powder/m2;

3 a water spraying or sprinkler system, designed for 5 litres/m2 min. Water spraying systems may be connected to the fire main of the ship; or

4 a system providing equivalent protection, as determined by the Administration.

In any case, the system shall be operable from outside the protected space.

6.3.2 Flammable liquid lockers shall be protected by an appropriate fire-extinguishing arrangement approved by the Administration.

6.3.3 For lockers of a deck area of less than 4 m2 , which do not give access to accommodation spaces, a carbon dioxide portable fire extinguisher sized to provide a minimum volume of free gas equal to 40% of the gross volume of the space may be accepted in lieu of a fixed system. A discharge port shall be arranged in the locker to allow the discharge of the extinguisher without having to enter into the protected space. The required portable fire extinguisher shall be stowed adjacent to the port. Alternatively, a port or hose connection may be provided to facilitate the use of fire main water.

To put this long paragraph simply:

For paint rooms under 4 square meters, the requirements are less stringent. Portable CO₂ fire extinguishers are acceptable. A discharge outlet should be installed outside the paint room; in case of fire, just discharge the extinguisher into the room.

For paint rooms over 4 square meters, an independent fixed fire-extinguishing system shall be installed, which can be CO₂, dry powder or water sprinkler system. A control valve must be fitted outside the paint room for direct external discharge.

022. 18203 Wages 10 hours extra overtime bonus for chief cook in Jan 2025 not paid as per S.E.A.

This deficiency means the chief cook worked 10 hours of overtime in January 2025 but was not paid the corresponding overtime pay.

In practice, PSC identifies deficiencies by checking documents including S.E.A., crew working and rest hours records, drill records, oil record books and garbage record books, and such checks are generally targeted at newly built vessels.

For aging vessels, PSCOs are already swamped with handling detention deficiencies and have no time for such checks. However, it is hard to find hardware deficiencies on new ships, so checking documents always yields a few findings to meet inspection quotas.

The crew of this vessel are Filipinos. As a common practice, Filipino and Indian crews are quite skilled at paperwork, yet they still couldn’t escape the scrutiny of our experienced PSCOs. I guess the Tianjin PSCO in this case is probably an expatriate naturalized officer, who is well-versed in the tricks of fake wage records.

First, the PSCO asked the crew to produce the S.E.A.. The agreement stipulated that Filipino crew shall have days off on the festivals shown below (New Year’s Day, Independence Day, Seafarers’ Day, etc.). But crew need to eat, so the chief cook had to work on these days—which counts as overtime and entitles him to overtime pay. Then the PSCO cross-checked the working and rest hours records and found the chief cook had 10 unpaid overtime hours, which was recorded as a deficiency.

In fact, overtime pay is the easiest area to spot irregularities, as SEA requirements vary from country to country.

China's SEA stipulates that the standard working hours shall be 8 hours per day, excluding statutory holidays and 2.5 days of rest per month.

For example, there are 31 days in May, including one public holiday for Labor Day. The standard working hours for this month shall be calculated as: (31 days - 2.5 days of monthly rest - 1 Labor Day public holiday) × 8 hours = 220 hours. Any working hours recorded beyond this threshold shall be deemed overtime.

However, the provisions of the MLC are somewhat different.

Under the requirements of MLC Convention Regulation A2.3, like other workers, the standard normal working hours for seafarers shall be based on 8 hours per day, one rest day per week and rest on public holidays.

Under Regulation B2.2.1, the term "overtime" means work performed in excess of normal working hours.

Therefore, 6 days a week × 8 hours a day = 48 hours shall be the weekly working hours; any work beyond this limit, as well as work on statutory public holidays, shall be regarded as overtime.

Regarding overtime pay, the MLC recommends that it should not be less than the basic hourly rate plus a supplement of at least 25% (i.e. 1.25 times the basic hourly wage).

Given that the chief cook has to prepare meals every day, he is usually the one who works the most overtime.

Time spent on berthing/departure operations and accommodating various inspections, if falling outside the 8-hour working day, shall be counted as overtime.

For the chief officer, time spent on anchor preparation, anchoring, weighing anchor, arranging cargo handling and draft survey shall also be regarded as overtime.

As for the chief engineer, time spent on bunkering, engine readiness and other duties beyond 8 hours shall also qualify as overtime.

Yet if such overtime is recorded truthfully, shipowners will likely refuse to pay the overtime wages, in which case PSC may issue a deficiency just like in this case.

If the overtime is falsely recorded as rest time, but the working and rest hours records are inconsistent with the actual situation documented in the deck logbook, engine logbook or other records, PSC may also issue a deficiency.

Seafarers are caught between a rock and a hard place—it’s truly tough being a seafarer.

In reality, those idiots at the MLC just engage in empty talk. They introduced the working and rest hours recording system with good intentions perhaps, but it has only landed seafarers in great trouble.

What seafarer wouldn’t want more rest and more pay?

But it’s a buyer’s market for shipowners now—there are far too many seafarers and jobs are hard to come by. Even cadets have to pay ten to twenty thousand RMB to agencies for shipboard placements. Who would dare to make a fuss about this issue?

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