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MEO CLASS 1 · ORAL QUESTION 8

OWS during trying out in front of surveyor giving errartic response and cannot functional, and PSC inspector want to detain the vessel on basis of that , what will be your action as C/E

Answer

If the OWS displays erratic alarms or fails to function during a Port State Control (PSC) or Class survey, it represents an immediate detainable deficiency because it compromises the vessel's capability to comply with MARPOL Annex I.

Your management actions must focus on transparency, regulatory containment, and immediate risk mitigation to avoid an official detention:

  1. Acknowledge and Halt: Immediately acknowledge the technical failure to the PSC inspector and the Class surveyor. Order the crew to cease all testing to prevent further damage or an accidental overboard discharge.

  2. Mitigate the Legal Detainability (The Key Strategy): Under the Procedures for Port State Control (IMO Res. A.1185(31)), a vessel should generally not be detained if a system breakdown is voluntarily declared by the ship, logged correctly, and has an approved contingency plan.

    • Show the inspector the Oil Record Book (ORB) Part I and make an immediate entry detailing the exact time and nature of the OWS failure.

    • Demonstrate that the vessel has ample remaining volume in the Bilge Holding Tank and Slop Tanks to retain all oily bilge water on board for the next intended voyage without any need for overboard discharge.

  3. Mobilize Technical Intervention: Issue a critical defect report to your company's DPA and Technical Superintendent. Request urgent technical assistance, troubleshooting guidelines from the OEM, and formal arrangement for a shore technician and spare parts at the next port.

  4. Apply for a Flag State Dispensation: Work with your company to submit a formal application to the Flag State Administration requesting a short-term Dispensation or Letter of Authority to sail to the next repair port with the OWS out of service, under the condition of zero-discharge and bilge retention.

  5. Present the Plan to PSC: Present this comprehensive mitigation package (ORB entries, tank capacities, OEM communication, and the official Flag State dispensation request) to the PSC inspector. Request that the deficiency be downgraded from an Action Code 30 (Detention) to an Action Code 17 (Rectify before departure) or Action Code 45 (Rectify at next port).