2016096:谈一艘被滞留35天船舶的相关MLC缺陷

ARFETISALLE轮悬挂CONGO旗，2016.1.26停靠希腊Kalamata港，对于如此大龄船舶毫无争议，psco上船检查，检查期间共发现59项缺陷，26项滞留缺陷，船舶被滞留35天后，修理完毕后于2016年3月15日驶离Kalamata港。可以想象这么长寿的船舶，船况、硬件设施肯定很差啦。我们都知道MLC公约对硬件的要求适用于公约生效后的新造船舶，有些船东有恃无恐，本期重点介绍MLC类缺陷，且看PSCO如何开具的MLC缺陷并滞留船舶的。

PSCO上船后先检查了证书，请看证书类缺陷涉及较多，由以下七项，其中6项可以作为滞留缺陷。其中第四项MLC证书不在船可以作为滞留的，请注意，无论船旗国是不是MLC公约的缔约国，港口国希腊作为MLC的缔约国是有义务检查并可以以此项滞留船舶的。

1. The Cargo Safety Equipment certificate was found expired.

2. In the Form E (field 3.1.6.), it was missing the entry about the Heading Control System which was found installed on board.

3. The C.S.R issued by the ship’s Flag Administration was not found on board. The competent authority did not follow the requirements of SOLAS ‘74/2005 Amend./Ch.XI-1/Reg.5/par. 8-9-13, which describes the procedure of issuance the C.S.R, in case of change ship’s flag.

4. The MLC certificate was not found on board.

5. The attestation issued from the Flag State regarding the confirmation of receipt of seafarers application for STCW endorsement (for all the crew members), were found expired since 23-12-2015.

6. One crew member from the engine department (electrician), who was performing duties as a watch keeper in the engine room, was not holding the appropriate certificate (STCW III/4).

7. The ship was not manned according the MSMD. Specifically, one person with the appropriate certificate (STCW III/4) was missing from the Engine Department.

涉及MLC的缺陷共计12项，小编知道大家英文水平都很高，不用我句句翻译了，不过还是将每项的依据给找了出来，啰嗦几句，不愿翻公约的爱莫能助啦！

2.1 No documentary evidence found available on board to indicate that the private service or private agency is operated in accordance with MLC-2006.

公约依据：Standard A1.4, paragraph 2，船东使用私营招募机构 招募船员，该机构应获得许可认证。另外不能向船员收费。（有人抬杠招募机构是慈善机构么？不收钱怎么活。其实招募机构通过向船东收费存货下去，对船员不收费的）

2.2 The SEA for C/E , Bosun and AB’s were not signed by them.

公约依据：Standard A2.1, paragraph 1(a) 不知道SEA的普及下啊：seafarers'  employment  agrrements

2.3 Records of rest hours (as DMLC 1 specifies) for the seafarers of the engine department were not kept at all.

公约依据：StandardA2.3, paragraph 5,滞留选项，希腊PSCO重点标注了该项目（PS： DMLC跟MLC证书同能重要需保存在船，并需船旗国批准的。)

2.4 No evidence of an on board programs for the prevention of occupational accidents meeting the standards of MLC 2006 found on board.

公约依据：StandardA4.3 ；后台有船员朋友留言MLC怎么保护船员的，这一条款重点研究，保护船员的内容很丰富。

2.5 Records of accommodation inspections by the Master or by an authorized crew member were not found on board.

公约依据：Standard A3.1, paragraph 18，船长工作不到位，定期检查方能确保船员工作休息环境

2.6 Records of food and catering inspections by Master or by an authorized crew member were not found on board.

公约依据：Standard A3.2, paragraph 7膳食也要定期检查的

2.7 No evidence was found concerning on board program/s for the prevention of occupational injuries and diseases meeting the standards of MLC 2006.

公约依据：StandardA4.3 又是这一章occupational injuries.

2.8 Ship’s safety committee was not established on board.

公约依据：Standard A4.3, paragraph 2(d)安全委员会须有五名及以上船员组成

2.9 The on board complaint procedure applicable to the ship, as required by MLC-2006, was not found on board.

公约依据：StandardA5.1.5,paragraph 4投诉程序不仅要编制而且要人手一册。

2.10 During the inspection the crew members were not using personal protective equipment, such as helmets, protective clothes - shoes and earplugs.

公约依据：StandardA4.3 个人防护设备

2.11 Mooring ropes located at the stern, were found in a non acceptable condition and needed to be replaced.

公约依据：StandardA4.3 个人觉得缆绳不符合要求可以归结在该条内

2.12 Two (02) of the four (04) mooring rollers located at bow deck, were found stucked.

公约依据：StandardA4.3 个人觉得缆绳不符合要求可以归结在该条内，应该属于safety protection吧。

以上，是该轮相关的MLC缺陷，从PSCO的报告中可以推测：

1、涉及MLC的相关证书、记录等是必查的。

2、由于MLC设备类规定适应于公约生效后建造的船舶，一般舱室大小、床铺大小等缺陷不会检查，但是涉及到人员防护也就是第4.3的内容会加强检查，体香各相关方注意迎检工作。具体到该轮其他各缺陷蛮多，也很精彩需要全部报告的可以扫描下方二位码，群内分享，先到先得。