MSD255 Nautical Inspector Guidelines
MSD255 Nautical Inspector Guidelines
MSD255 Nautical Inspector Guidelines
MARINE SAFETY
TABLE OF CONTENTS
1.0 INTRODUCTION................................................................................................................1
1.0 INTRODUCTION
This document represents guidelines for use by Nautical Inspectors in carrying out their
duties as flag state representatives onboard Republic of the Marshall Islands (RMI) flagged
vessels. The procedures contained in this document are intended to ensure that vessel
inspections are conducted in a uniform manner consistent with the RMI Maritime
Administrator’s (the “Administrator”) goals of Marine Safety, Security, and Environmental
Protection.
1.1 OBJECTIVES
The Marine Safety and Vessel Inspections program has three major objectives. First and
foremost is to ensure that vessels operating under the RMI flag are in substantial compliance
with the RMI Maritime Regulations as well as all applicable requirements of the international
conventions to which the RMI is a party. Second is to assess the performance of the
Recognized Organizations (ROs) and Recognized Security Organizations (RSOs) that issue
statutory certificates on the Administrator’s behalf. Third is to identify gaps in the
operational management of vessels flying the RMI flag and alert vessel owners and operators,
Classification Societies, ROs, and RSOs of a degradation in performance of vessels under
their purview. Pursuit of these objectives will serve to eliminate or identify problems or
substandard conditions before they reach a critical level and thus improve safe and quality
operation of RMI flagged vessels. In addition, these objectives directly contribute to the
registry’s goals and responsibility for maritime safety and security of RMI flagged vessels,
their crews, passengers and cargo, as well as protection of the marine environment.
1.2 DEFINITIONS
1.2.3 COMPANY: the entity which has been designated by the shipowner as responsible for the
management of a vessel under the ISM Code.
1.2.4 CONTRACT: the terms agreed between the Administrator and the Inspection Company or
individual Nautical Inspector under which inspection services are provided on behalf of the
Administrator.
1.2.5 DESIGNATED PERSON ASHORE (DPA): the Company point of contact as defined by the
ISM Code.
1.2.6 DISPENSATION: a short term acknowledgement by the Administrator that a vessel is not in
compliance with a specific requirement of SOLAS, MARPOL or other International
Convention or RMI regulation.
1.2.9 PORT STATE CONTROL (PSC): a local authority empowered by a National Administration
to conduct inspections of, and otherwise ensure the safety of, foreign flagged vessels
operating in its national waters.
1.2.11 SHIPDESK: Location where all scheduling of inspections related activities occurs.
SHIPDESKs are located in a number of regional offices and all attendance of RMI flagged
vessels by Nautical Inspectors are scheduled and coordinated by regional SHIPDESKs.
1.3 ORGANIZATION
The Administrator’s headquarters are located in Reston, Virginia. The Senior Vice President
of Fleet Operations, located in Baltimore, Maryland, has overall responsibility for the vessel
inspection program. To facilitate its global operations, Fleet Operations is divided into three
basic geographic regions. Each of the Regional Offices and some sub-regions have Regional
Fleet Operations Managers acting as the senior Nautical Inspector in that Region and report
directly to the Senior Vice President of Fleet Operations on vessel inspection issues and
activities.
The Worldwide structure consists of three (3) principle regions as outlined in the below
diagram.
REGION III REGION II REGION I
REGION IIA – NORTHERN EUROPE & AFRICA: Northern and Eastern Europe,
Eastern Russia, West and South Africa, and Madagascar. Region IIA Shipdesk and Fleet
Operations Manager are located in the Roosendaal, Netherlands office. Additional
offices are shown for reference only. All inspections related activities for this region are
managed and assigned from the Roosendaal office.
REGION IIB – MEDITERRANEAN: The Mediterranean, Black Sea, and North and
West Africa. Region IIB Shipdesk and Fleet Operations Manager are located in the
Piraeus, Greece office. Additional offices are shown for reference only. All inspections
related activities for this region are managed and assigned from the Piraeus office.
REGION IIC – MIDDLE EAST & INDIA: Middle East, India, and Pakistan. Region IIC
Shipdesk is located in the Dubai office. This region is further supported by the Fleet
Operations Managers from Region IIA and IIB, and regional managers located in the
Dubai and Mumbai offices. All inspections related activities are assigned from the
Shipdesk in the Dubai office.
Offshore Industry inspections are scheduled and managed from the Shipdesk in the Houston,
Texas office.
AKauchhur@register-iri.com
Asia: India and Pakistan Mumbai, India
Capt. Sanjay Maini +91-22-4064-1111
+91-99675-18494 (mobile)
SMaini@register-iri.com
MManning@register-iri.com
Duty Officer World Wide Reston, Virginia +1 (703) 476-3762
EMERGENCIES ONLY! dutyofficer@register-iri.com
1.4 RESPONSIBILITIES
1.4.1 Nautical Inspectors are responsible for carrying out activities such as inspections, audits, or
investigations as directed by the Administrator. Their responsibilities include, but are not
limited to, the following tasks:
1.4.2 Nautical Inspectors receive their instructions from the Regional Office covering the area in
which they are based and report to the Regional Fleet Operations Manager. In the event of
questions or concerns, Nautical Inspectors should contact their Regional Fleet Operations
Manager.
1.4.3 Nautical Inspectors are responsible for providing the Regional Office with their current
contact information including telephone number, mobile phone number, facsimile number (if
available) and email address. Nautical Inspectors are responsible for maintaining computer
capability and Internet access necessary for the transfer of information.
1.5 QUALIFICATIONS
1.5.1 To be designated as a Nautical Inspector an individual must meet the minimum professional
qualifications contained in Section 5.34.1 of the RMI Maritime Regulations. These
qualifications are those necessary to inspect most types of vessels. In order to inspect vessels
that may require more specific inspection qualifications such as LNG carriers or to conduct
oversight of ISM/ISPS audits, an individual must have documented experience in these areas.
1.5.2 Individuals applying to be an RMI Nautical Inspector should submit a letter with either a
résumé or curriculum vitae to one of the Administrator’s Regional Offices (see Table A
above). The Regional Office will coordinate submission of the appropriate supporting
documentation needed to evaluate whether an applicant meets the minimum professional
qualifications. In some cases a trial period may be imposed where a number of safety
inspections must be carried out under supervision.
1.5.3 Nautical Inspectors performance will be assessed periodically. The primary means for
assessing Nautical Inspectors will be a review of completed inspection reports. This review
will include a determination whether these guidelines were followed, with particular
emphasis on whether the appropriate Regional Fleet Operations Manager was notified when
required. The Administrator may also periodically assign an exclusive flag State inspector to
accompany Nautical Inspectors during a safety inspection in order to review the inspector’s
performance. Nautical Inspectors whose performance is considered to be below the expected
standard by the Administrator will be informed directly by the Administrator.
1.6 AUTHORITY
Nautical Inspectors are acting on behalf of the RMI Administrator. As such, a Nautical
Inspector may be authorized to board an RMI flagged vessel at any time as directed by a
Deputy Commissioner of Maritime Affairs. Nautical Inspectors, themselves, are not
authorized to board an RMI flagged vessel without the permission of a Deputy
Commissioner of Maritime Affairs. Regional Fleet Operations Managers are all Deputy
Commissioners of Maritime Affairs. In addition, SHIPDESK schedulers are directly
authorized by Regional Fleet Operations Managers to schedule Nautical Inspectors for
inspections. A Nautical Inspector is not authorized to approach a Company in anticipation
Rev. 3/13 8 MSD 255
that an inspection may be due, or to board a vessel without instruction from the Regional
Fleet Operations Manager. A Nautical Inspector is also not authorized to issue Exemptions
or Dispensations of regulations or unduly delay or detain a vessel without permission from
the Regional Fleet Operations Manager.
1.7.1 The Administrator will issue an identification (ID) card to all RMI Nautical Inspectors. This
ID card is to be used only as evidence that the individual to whom it was issued is duly
authorized by the RMI to carry out the duties of a Nautical Inspector pursuant to the
provisions of the RMI Maritime Law and Regulations. The ID card is non-transferable. In
the event that the ID card is lost or destroyed, the Regional Office should be notified
immediately so that a replacement can be issued. The ID card is the property of the
Administrator, and as such, can be revoked without notice. If revoked it must be surrendered
to the Regional Office.
1.7.2 When entering a port facility to attend a vessel, Nautical Inspectors should be aware that
some port authorities may not accept the ID card issued by the Administrator as adequate
personal identification. Nautical Inspectors should be familiar with local personal
identification requirements and ensure they have the appropriate identification.
1.8 CONTRACTS
1.8.1 Contracts will be offered to individuals who meet the professional training qualifications and
who are in ports or areas where Nautical Inspectors are needed. Contracts may also be
offered to Inspection Companies who employ multiple inspectors. When this occurs, only
the individuals issued an RMI Nautical Inspector ID card may conduct inspections on behalf
of the Administrator. An Inspection Company wanting additional inspectors added must
provide the documentation required in Section 1.5 above.
1.8.2 An individual or Inspection Company entering into a contract with the Administrator agrees
to fulfill the responsibilities outlined in the contract as well as all of the duties of a Nautical
Inspector outlined in RMI Maritime Regulation 5.34 and Marine Notice No 5-034-1, these
Guidelines, and any directions from the Administrator, its designee, or the Regional Fleet
Operations Manager. Supervisors of Inspection Companies are expected to provide adequate
oversight of their employees to ensure individual inspectors meet these responsibilities.
2.0 INSPECTIONS
2.1 GOALS
to confirm compliance with the applicable international and RMI safety, security and
environmental protection standards;
to audit the performance of the RO and/or RSO authorized to act on behalf of the
Administrator; and
2.1.2 To achieve these goals, Nautical Inspectors are assigned to carry out inspections and/or
audits, and to conduct casualty investigations as necessary that may also provide additional
feedback on inspection and compliance activities.
2.2.2 Initial Safety Inspection (ISI): An inspection conducted within 60 days following registration
of a vessel, to check that it meets, and is being operated in accordance with, all national and
international rules and regulations.
2.2.3 Annual Safety Inspection (ASI): An inspection conducted annually to verify a vessel is being
maintained to the Administrator’s standards of quality and is in substantial compliance with
all applicable national and international rules and regulations.
2.3 SCHEDULING
2.3.1 The ship owners/operators and ship Masters are required to make their vessels available for
inspection by the Administrator. All inspections are arranged by the Administrator. Nautical
Inspectors shall not try to arrange inspections with RMI flagged vessels without the
Administrator’s authorization.
Rev. 3/13 10 MSD 255
2.3.2 A notice of inspection due is forwarded to the DPA of the vessel when the vessel comes in
the window for an inspection. The windows for vessel inspections are as follows:
2.3.3 When the DPA receives the notice of inspection due, he/she should follow the instructions in
the letter for scheduling the inspection.
A notice is sent to the DPA of a vessel via the Administrator’s automated notification
system that the vessel is due for inspection.
The DPA replies and indicates the vessel will be available for inspection on certain dates
and locations.
The regional SHIPDESK for the proposed location will further coordinate the dates and
times of the inspection with the DPA and the Nautical Inspector, specifically:
2.4.1 Upon receipt of an inspection assignment, the Nautical Inspector should have available an
electronic and hard copy of the most recent version of the following inspection forms
available from the website at http://www.register-iri.com/index.cfm?action=page&page=254:
2.4.2 The regional SHIPDESK sends an electronic version of the MSD 252SUPP to the DPA via
email, requesting that the Master have an officer from his crew complete this form and have
it available for review/auditing during the inspection.
2.4.3 Prior to the inspection, the Nautical Inspector must review any vessel information or
instructions provided by the SHIPDESK. The Nautical Inspector is encouraged to contact
the regional SHIPDESK should there be questions or concerns regarding the assignment.
2.5 PROCESS
2.5.1 A typical initial or annual safety inspection is expected to require a minimum of seven (7) or
eight (8) hours onboard the vessel to complete. Due to the number of items to be confirmed,
most inspections are expected to require a minimum of eight (8) hours to complete. The time
to complete an inspection depends on the ship type/size and any additional instructions that
may have been provided by the regional SHIPDESK. Special Safety Inspections may require
less time as their scope may be limited to certain areas of the ship or to verification that all
critical systems and equipment are being maintained and functional. Follow-up inspections
may also require less time as they are intended to verify that deficiencies issued during a
prior inspection have been rectified.
2.5.2 The Nautical Inspector should explain to the Master the purpose, scope and schedule for the
inspection and request the Master’s cooperation in scheduling muster, fire and boat drills at a
convenient time. The Master should confirm if the DPA, Superintendent, Port Engineer or
other owner’s representatives are available onboard. The Nautical Inspector should request
an escort for the purpose of conducting the inspection. In rare cases where the Master has
reasonable arguments why the inspection cannot be carried out, it should be respected and
the SHIPDESK contacted for guidance.
2.5.3 The MSD 252SUPP should be completed by the crew prior to the inspection and is to be
acknowledged by the Master for correctness. A random check or audit should be carried out
on a number of documents and certificates listed on the supplement. The audit is to be
carried out to the extent that the inspector is satisfied, and verifies that the information
provided in the MSD 252SUPP is correct. This allows more time for the inspector to focus
on the material condition of the ship and the performance of the crew in execution of their
duties and emergency drills. Should the inspector board the vessel and the supplement is not
completed, the inspector is to instruct the Master to have this completed by a ship’s officer.
The inspector can then review the supplement with the Master at the end of the inspection.
2.5.4 The MSD 252 provides the inspector with a scope of the inspection by topic, but there is no
requirement to follow the sections in the order listed on the inspection form. Ship
operational requirements or weather related reasons, may require that the physical inspection
and drills be carried out prior to checking the documents. It is also advisable to conduct
Rev. 3/13 12 MSD 255
operational test and examination of critical systems early in the inspection to allow time for
rectification of any deficiencies without unduly delaying the vessel. In this regard, at the
beginning of the inspection the ship staff should be given opportunity to inform the Nautical
Inspector about the ship’s condition, statutory compliance, crew wellness and performance.
2.5.5 Inspections should be scheduled so the inspection of the weather decks, lifesaving gear as
well as boat drills can be completed during daylight hours. A minimum of four (4) hours of
daylight is required for the typical safety inspection. Inspections carried out with less
daylight time must be specifically authorized by the regional SHIPDESK.
2.6 CONDUCT
The following rules of conduct apply to Nautical Inspectors when they are performing their
inspection duties:
Always act professionally and courteously in conducting inspections. Remember you are
acting as a representative of the Administrator and as such you are to be professional at
all times.
Remember that a ship is a home as well as a workplace for the ship’s personnel and do
not unduly disturb their rest or privacy. Comply with any ship housekeeping rules such
as removing dirty shoes or work clothes.
Avoid being prejudiced by the race, religion or nationality of the crew when making
decisions, treating all personnel on board with respect.
Respect the authority of the Master.
Be polite but professional and firm as required. Never become threatening, abrasive or
dictatorial or use offensive language.
Comply with all health and safety requirements of the ship. Do not take any action or
cause any action to be taken which could compromise safety.
Apply the RMI rules, regulations and the convention requirements in a consistent and
professional way.
Do not try to entrap the crew, for example by asking them to do things that are contrary
to the Conventions.
Request the crew to demonstrate the functioning of equipment and operational activities,
such as drills. Inspectors shall not operate any shipboard equipment or systems.
Inspectors should also refrain from giving instructions to crew members on how to
operate equipment. Remember when witnessing an operational test of equipment or a
drill, the crew is performing the test or drill and you are only there as a witness. Never
jump in and perform the operation yourself. If you see a safety issue during a drill or
operational test you ask the Master or Chief Engineer or the representative escorting you
to stop the operation and resolve the safety issue.
Deal with any disagreement over the conduct or findings of the inspection calmly and
patiently. Advise the Master that his complaints will be taken note of, and additionally
that the Master should inform the company DPA about any disagreement.
Make decisions based on the findings of the inspections and not on any commercial
considerations. Firmly refuse any attempts of bribery and report any blatant cases to your
Regional Fleet Operations Manager. Misuse of authority for financial or personal benefit
is prohibited.
The Pre-Reg is conducted on certain vessels applying for registration to assess the general
condition of a ship and its ability to meet the quality standards of the RMI. The Pre-Reg
inspection form should be accompanied by sufficient pictures of all applicable items detailed
in the form. In addition, the Pre-Reg form shall include a recommendation from the
inspector whether or not this vessel should be considered for registration. When a vessel
does not meet the criteria and expectations for registration in the RMI, the Pre-Reg report is
to be completed with a list of defects and findings that support the areas found deficient. As
there is little time available between the Pre-Reg and the proposed date of the sale, it is
important that the full report be sent by email within 72 hours of the completion of the
inspection.
The ISI is carried out within 60 days following registration. It serves the purpose of verifying
that the ship is being operated in compliance with all national and international rules and
regulations and that all procedures are in place so that the vessel remains in compliance
during operations and trade. The date of completing the initial inspection will become the
anniversary date for the annual inspection. The scope of this inspection is the same as the
annual inspection
The ASI is due one (1) year after the ISI and every subsequent year. This inspection falls due
each year on the anniversary date of the Initial Inspection. This inspection may be carried out
within the period one (1) month before and one (1) month after the anniversary date.
MODUs and certain vessels in hard to reach locations may be given a window of three (3)
months on either side of the anniversary date. The date on which the next inspection falls
due remains one (1) year after the anniversary date regardless of when the ASI is conducted.
The ASI is to verify the level of compliance, provide oversight on RO performance, and
provide an objective report on ship and crew performance to the benefit of the owners/
managers.
An SI is carried out when the Administrator has determined a particular vessel or operator
may require additional oversight for compliance with national and international standards.
An SI may also be carried out when port State authorities have raised a substantial amount of
deficiencies or the vessel has been involved in port State control actions or a detention. As
indicated earlier, the Administrator may carry out an SI any time the circumstances the vessel
is involved with may warrant additional scrutiny or assistance. Additionally, an SI may be
initiated through information available from an RO or a third party through websites such as
Equasis, Rightship or Lloyds List. An SI is normally not credited toward completion of an
ASI.
An SI may also be performed for quality control purposes. In this case the inspection would
be referred to as an SI, Quality Control Boarding (SI-QCB). The SI-QCB may be conducted
for any number of reasons including to assist an owner or operator with compliance activities
by conducting a random quality overview of the condition and compliance of a vessel. These
inspections may be conducted announced or unannounced as “spot checks” on compliance
activities on a vessel. Additionally an SI-QCB may also be conducted to gauge the
performance of an RO or RSO in performance of their duties. An SI-QCB would normally
not be credited toward completion of an ASI.
An FI is used to verify that deficiencies found during a recent inspection have been properly
rectified. The scope of this inspection is restricted to those items noted as deficiencies in the
preceding inspection. Therefore a full inspection report is not normally completed. Only the
narrative and deficiencies pages are required to be completed.
Liquefied Gas Carriers require a supplemental inspection tailored to examine the additional
systems such as cargo handling equipment for these types of vessels. A supplemental
inspection form (MSD 252 LGC) in addition to the normal MSD 252 is to be filled out
during the ASI. This supplemental form may also be required during a SI of a gas carrier.
Mobile offshore drilling units (MODUs) and mobile offshore units (MOUs) are also subject
to an ASI. However, the window to complete the annual inspection on these vessels may be
extended up to three (3) months before or after the date the inspection is due. This is
primarily due to these vessels being in a number of remote locations and the difficulty with
arranging Nautical Inspectors to attend in the remote locations. Inspections on
MODUs/MOUs use the MSD 252 MODU/MOU form as a job aid and for recording the
major details of the inspection.
All forms shall be filled out electronically. The Administrator will not accept hand written
inspection forms. The following table is a reference for Nautical Inspectors regarding the
forms required to be submitted to the Administrator.
Passenger Vessel MSD 252SUPP Completed supplement form shall be collected at the
MSD 252 beginning of the inspection and reviewed by the inspector
during the course of the inspection. If the supplement has
not been completed by the crew, the inspector shall hand a
blank copy to the Master for completion by the crew during
the inspection. Before conclusion of the inspection, the
inspector should collect the form, review it, and audit a
sampling of the items on the supplement.
Gas Carriers MSD 252SUPP Completed supplement form shall be collected at the
beginning of the inspection and reviewed by the inspector
MSD 252 during the course of the inspection. If the supplement has
not been completed by the crew, the inspector shall hand a
MSD 252 LGC blank copy to the Master for completion by the crew during
the inspection. Before conclusion of the inspection, the
inspector should collect the form, review it, and audit a
sampling of the items on the supplement.
Entire MSD 252 and MSD 252 LGC shall be filled out
electronically for submission to the Administrator. It is not
necessary to fill the form out while onboard the vessel. It is
preferred this is done afterwards so more time is spent on the
physical inspection of the vessel.