SR &G SHIPPING REGULATIONS & GUIDANCE

Port State Control Update including current and future campaigns April 2017

Contents

Introduction...... 1 Regional PSC Agreements...... 2 Recent and Future Concentrated Inspection Campaigns...... 5 Deficiencies and Observations ...... 6 Paris MoU 6 Tokyo MoU 8 United States 9 Checklist for a PSC Inspection...... 11

Witherby Publishing Group - Shipping Regulations & Guidance Introduction

Definition A port State administration is the government within whose territorial waters a port, anchorage or berth is located. In the United Kingdom for example, the Maritime and Coastguard Agency (MCA) is the port State control authority. Port State Control (PSC) is the inspection of foreign ships that do not fly the flag of the coastal State of the port that the ship is visiting. It is carried out by Port State Control Officers (PSCOs), who are usually surveyors or inspectors of the port State control authority.

Purpose The purpose of a PSC inspection is to verify that the condition of the ship, its equipment, manning and operations comply with the requirements of international regulations. The International Maritime Organization (IMO) has stated that PSC is important in ensuring global maritime standards are implemented consistently on ships of different nationalities. This consistency of approach allows more ships to be inspected to the correct standards and improves sharing of maritime knowledge. It is complementary to flag State control.

Consequences Where deficiencies are found that are considered a hazard to health, safety or the environment, the ship will have action taken against it by the port State. This could potentially result in fines and, depending on the severity of infringement, may result in a detention until the deficiencies are rectified. The ship’s staff may even be arrested if a criminal offence has been committed that violates the national law of the port State.

IMO Framework The IMO has developed a framework to help promote the global harmonisation and coordination of PSC activities. This was adopted in Resolution A.1052(27). It includes the publication ‘Procedures for Port State Control’, 2012 edition.

This is supported by IMO Resolution A.682(17) on ‘Regional co-operation in the control of ships and discharges’ which assists in harmonising regional PSC inspections, as a ship going to one port State will often visit other port States in the region. It is therefore more efficient if inspections are closely coordinated and resources are used to focus on substandard ships by avoiding multiple inspections of low-risk ships.

The IMO issues updated guidance periodically to assist member States with compliance as it relates to PSC inspections. For example, in December 2016 the IMO issued MSC.1/Circ.1560, which contains advice for port State control authorities on action to be taken where not all seafarers carry certificates and endorsements meeting the 2010 Manila amendments to the STCW Convention and Code.

Witherby Publishing Group - Shipping Regulations & Guidance 1 Regional PSC Agreements

The establishment of the regional Port State Control organisations and implementation of Memoranda of Understanding (MoUs) facilitate regional inspections. A Memorandum of Understanding is an official document in which participating maritime authorities agree to follow a harmonised system of port State control.

As of 2017, the nine regional MoUs and their member States are:

Abuja MoU Angola, Benin, Cameroon, Cape Verde, Congo, Cote d’Ivoire, Gabon, Gambia, Ghana, Guinea, Guinea-Bissau, Liberia, Mauritania, Namibia, Nigeria, Senegal, Sierra Leone, South Africa, Sao Tome and Principe, Democratic Republic of Congo and Togo. http://www.abujamou.org/index.php

Acuerdo de Viña del Mar Argentina, Bolivia, Brazil, Chile, Colombia, Cuba, Dominican Republic, Ecuador, Guatemala, Honduras, Mexico, Panama, Peru, Uruguay and Venezuela. http://alvm.prefecturanaval.gob.ar/

Black Sea MoU Bulgaria, Georgia, Romania, the Russian Federation, Turkey and Ukraine. http://www.bsmou.org/

Caribbean MoU Anguilla, Antigua and Barbuda, Aruba, Bahamas, Barbados, Belize, Bermuda, British Virgin Islands, CaymaN Islands, Cuba, Curacao, Dominica, Grenada, Guyana, Jamaica, Montserrat, the Netherlands, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Suriname, Trinidad and Tobago, Turks and Caicos Islands. http://www.caribbeanmou.org/  Indian Ocean MoU Australia, Bangladesh, Comoros, Djibouti, Eritrea, Ethiopia, India, Iran, France (La Reunion), Kenya, Maldives, Mauritius, Mozambique, Myanmar, Oman, Seychelles, South Africa, Sri Lanka, Sudan, Tanzania and Yemen. http://www.iomou.org/

Mediterranean MoU Algeria, Cyprus, Egypt, Israel, Jordan, Lebanon, Malta, Morocco, Tunisia and Turkey. http://www.medmou.org/

Paris MoU Belgium, Bulgaria, Canada, Croatia, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Latvia, Lithuania, Malta, the Netherlands, Norway, Poland, Portugal, Romania, the Russian Federation, Slovenia, Spain, Sweden and the UK. https://www.parismou.org/

Riyadh MoU Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and UAE. http://www.riyadhmou.org/  Tokyo MoU Australia, Canada, Chile, China, Fiji, Hong Kong, Indonesia, Japan, Republic of Korea, Malaysia, the Marshall Islands, New Zealand, Papua New Guinea, Peru, the Philippines, the Russian Federation, Singapore, Thailand, Vanuatu and Vietnam. http://www.tokyo-mou.org/

Frequency of Inspections Inspections may be conducted routinely (generally every six months) or at any time where there is doubt over the conformity and condition of a ship in port that does not fly the flag of the coastal State of the port. Certain types of ships, ships flying identified flags and older ships may receive more frequent PSC inspections. Each MoU has a central database that enables appropriate ships to be identified for inspection and, importantly, reduces the likelihood of ships with good PSC records being inspected too frequently.

Considerations Ships will be considered as priorities for PSC inspections if they are:

• Reported by pilots or port authorities, or are the subject of a report or notification by another authority • carrying dangerous or polluting goods and have failed to report the relevant information to the port and coastal State, or are suspected of violating the provisions on discharging harmful substances or effluents • the subject of a report or complaint by the Master, crew member or other person/ organisation with a legitimate interest in the safe operation of the ship • involved in a collision, grounding or stranding en route to the port • manoeuvred in an erratic or unsafe manner, where routeing measures were not followed • suspected of operating in a dangerous or hazardous way • suspended/withdrawn from Class for safety reasons in the previous six months. • When undertaking PSC inspections, ships are not to be unduly detained or delayed, and where this occurs they are entitled to compensation for loss or damage. However, where the ship is detained due to deficiencies, the costs accrued by the port State during the inspection will be charged to the shipowner, and the ship will not be permitted to sail until they are paid or a guarantee of payment provided.

2 Witherby Publishing Group - Shipping Regulations & Guidance Type of Inspection PSC inspections may be:

• Initial – documentation, crew, general condition, machinery spaces and accommodation spaces • Detailed – as a result of missing or invalid documentation or there are clear grounds that the ship fails to meet international standards • Expanded – annually for specific ship types and ages • Suspended – where substandard conditions are found, inspections can be suspended until the ship is brought up to standard. The PSC inspection can then be continued. • Inspection Procedure • A typical initial PSC inspection sequence will involve inspecting: »» Ship’s certificates »» ship’s condition, equipment and the crew »» prioritised areas of concern that have been identified.

Where a ship is found to be compliant, a ‘clean’ inspection report will be issued to the Master and recorded on the MoU system. If a ship is found to be deficient, a PSCO will determine the action required, i.e. permitting the ship to sail with the noted deficiencies, provided that the deficiencies do not pose a threat to safety, health or the environment, or detaining the ship where the deficiencies are considered sufficiently serious to merit reinspecting the ship before it sails. There are non-exhaustive lists of detainable deficiencies grouped under the relevant conventions and codes. Where deficiencies cannot be rectified at the port, the authorities may permit the vessel to sail subject to specified conditions.

Inspection Procedure A typical initial PSC inspection sequence will involve inspecting: • Ship’s certificates • ship’s condition, equipment and the crew • prioritised areas of concern that have been identified.

Where a ship is found to be compliant, a ‘clean’ inspection report will be issued to the Master and recorded on the MoU system. If a ship is found to be deficient, a PSCO will determine the action required, i.e. permitting the ship to sail with the noted deficiencies, provided that the deficiencies do not pose a threat to safety, health or the environment, or detaining the ship where the deficiencies are considered sufficiently serious to merit reinspecting the ship before it sails.

There are non-exhaustive lists of detainable deficiencies grouped under the relevant conventions and codes. Where deficiencies cannot be rectified at the port, the authorities may permit the vessel to sail subject to specified conditions.

Witherby Publishing Group - Shipping Regulations & Guidance 3 An Example: The Paris MoU The Paris MoU consists of 27 participating maritime Administrations that cover the waters of European coastal States, the North Atlantic and the Mediterranean Sea. On average, more than 18,000 ship inspections take place annually within the Paris MoU. The MoU is based on an official text document, which received its 39th amendment in 2016. The text consists of the agreement of the States on:

• Their commitments and the relevant international conventions that apply to inspections • the inspection procedures and the investigation of operational procedures • the exchange of information to aid further awareness and understanding • the structure of the organisation and amendment procedures.

The Paris MoU was made mandatory in EU member states under the Port State Control Directive (Directive 2009/16/EC), which entered into force on 1st January 2011 with a new inspection regime (NIR). In the UK, for example, this is implemented under the Merchant Shipping (Port State Control) Regulations 2011.

Since the New Inspection Regime (NIR) of the Paris MoU was adopted in 2011, each ship is assigned a ship risk profile (SRP), in accordance with Annex 7 of the Paris MoU text. This SRP determines the ship’s priority for inspection, the interval between inspections and the scope of the inspection.

The SRP assesses the type and age of ship, the number of previous deficiencies and detentions, the performance of the flag of the ship, and the performance of the recognised organisation(s). It also considers a company’s performance and takes into account the detention and deficiency history of all ships in a company’s fleet in the Paris MoU area in the last 36 months.

SRPs are automatically recalculated daily and after inspections, or after a change of flag/RO performance, into one of three categories:

• Low risk ships – due an inspection every 24 to 36 months • standard risk ships – due an inspection every 10 to 12 months • high risk ships – due an inspection ever 5 to 6 months.

Additional inspections may be carried out for the reasons listed earlier under ‘considerations’. The type of inspection will depend on the ship’s risk profile; the minimum for a high risk ship will be an expanded inspection. To maintain a low risk status, a vessel must have no more than five deficiencies during any one inspection and no detention recorded in the preceding three years. The Paris MoU publishes its results in an annual report. This includes the White, Grey and Black (WGB) List. It contains a list of flag States, ranked according to the number of detentions of ships under their flag, as a result of a Paris MoU inspection. The White List contains flags with a lower than average detention record. The Black List contains flags with a higher than average detention record. The Grey List contains flags with neither a substantially higher nor lower than average detention record.

4 Witherby Publishing Group - Shipping Regulations & Guidance General Reporting Obligations (24 ETA) Under the Paris MoU, a ship has to report 24 hours (24 ETA) before arriving at a port or anchorage of the Paris MoU region or before leaving the previous port or anchorage if the voyage is expected to take less than 24 hours. This pre-arrival notification has to be reported to all ports in the Paris MoU region at which the ship will call. The 72 hours reporting obligation (72 ETA) is only required when the ship is due for an expanded inspection.

Expanded Reporting Obligations (72 ETA) Ships due for an expanded inspection have to report 72 hours (72 ETA) before arriving at a port or anchorage of the Paris MoU region or before leaving the previous port or anchorage if the voyage is expected to take less than 72 hours. The following information must be supplied to the port authority:

(a) Ship identification (name, flag, call sign, IMO or MMSI number) (b) port of destination (c) estimated time of arrival (ETA) (d) estimated time of departure (ETD) (e) planned duration of the call (f) for tankers: i. configuration: single hull, single hull with SBT, double hull ii. condition of the cargo and ballast tanks: full, empty, inerted iii. volume and nature of cargo (g) planned operations at the port or anchorage of destination (loading, unloading, other) (h) planned statutory survey inspections and substantial maintenance and repair work to be carried out whilst in the port of destination (i) date of last expanded inspection in the Paris MoU region.

Recent and Future Concentrated Inspection Campaigns

A concentrated inspection campaign (CIC) is an organised effort to focus for a period on one agreed subject of concern. This may be due to a new regulation entering into force or due to a growing safety concern that requires greater effort to mitigate through inspections. A CIC is usually carried out by a single MoU, but may sometimes be conducted jointly between different regions. Campaigns vary in duration, but usually take place yearly, over a period of 3 months between September and November. Sometimes, a CIC in one MoU may be similar to a previous MoU’s CIC, but occurs in a later year.

Some examples of past campaigns include:

Abuja MoU Pilot transfer arrangements (2016)

Acuerdo de Viña del Mar Harmful substances in packaged form (2010), fire safety systems (2012), SOLAS Chapter II-1 (2013), crew familiarisation for enclosed-space entry (2015), cargo securing arrangements (2016)

Black Sea MoU Propulsion and auxiliary machinery (2013), hours of rest (2014), crew familiarisation for enclosed-space entry (2015), cargo securing arrangements (2016)  Caribbean MoU Fire safety systems (2014), safety of navigation and hours of rest (2015), crew familiarisation for enclosed- space entry (2016)

Indian Ocean MoU Hours of rest (2014), crew familiarisation for enclosed-space entry (2015), cargo securing arrangements (2016)

Mediterranean MoU Crew familiarisation for enclosed-space entry (2015), cargo securing arrangements (2016)

Paris MoU SOLAS Chapter V (2008), lifeboats (2009), tanker damage stability (2010), structural safety and load lines (2011), fire safety systems (2012), propulsion and auxiliary machinery (2013), hours of work (2014), crew familiarisation for enclosed-space entry (2015), compliance with the Maritime Labour Convention (2016)

Riyadh MoU Fire safety systems (2014), SOLAS Chapter V (2015), pilot transfer arrangements (2016)

Tokyo MoU Fire safety systems (2012), propulsion and auxiliary machinery (2013), hours of rest (2014), crew familiarisation for enclosed-space entry (2015), cargo securing arrangements (2016).

Witherby Publishing Group - Shipping Regulations & Guidance 5 Current and future campaigns include: • Black Sea MoU – The 2017 CIC will be on Safety of Navigation, including ECDIS. The 2018 CIC will be on the Maritime Labour Convention (MLC). • Paris MoU – The 2017 CIC will be on Safety of Navigation, including ECDIS. The 2018 CIC will be on MARPOL Annex VI. • Tokyo MoU – The 2017 CIC will be on Safety of Navigation, including ECDIS. The 2018 CIC will be on MARPOL Annex VI.

Deficiencies and Observations

Findings from the PSC regimes for one year are usually published the following year, or even later. In March 2017, the most recent published reports from the Tokyo MoU, Paris MoU and the United States are for inspections across 2015. However, a PSC may publish the findings of a CIC separately, which may be earlier than its annual results.

Paris MoU

In 2015:

• A total of 17,858 inspections was performed • a total of 41,436 deficiencies was found • 53% of inspections resulted in a deficiency being found • the average number of deficiencies per inspection was 2.3 • there were 595 detentions, with an average detention rate of 3.33% • the top five performing flag States were Sweden, United Kingdom, France, Denmark and Norway • the five poorest performing flag States were Tanzania, Republic of Moldova, Togo, Comoros and Cook Islands • by ship type, the top detention rates were: general cargo/multipurpose ships at 5.7%; commercial yachts at 4.8%; tugs at 4.7%; refrigerated cargo ships at 4.6%; and high speed passenger craft at 3.6%. Although “other” is not a specific type, the detention rate was the highest at 7.1% • the best performing ship types were combination carriers and heavy load ships with a zero detention rate • the top five performing Recognized Organizations were DNV GL AS (DNVGL), Det Norske Veritas (DNV), American Bureau of Shipping (ABS), Lloyd’s Register (LR) and the Korean Register of Shipping (KRS) • the lowest performing Recognized Organizations were the International Register of Shipping (IS), Universal Shipping Bureau Inc (USB) and the Bulgarian Register of Shipping (BRS).

Top five deficiency categories:

CATEGORY NUMBER PERCENTAGE

Fire safety 5,558 13.4% Safety of navigation 5,150 12.4%

Life-saving appliances 3,709 9.0%

Labour conditions, e.g. health, medical care, social 2,709 6.7%

Certificate and Documentation 2,600 6.3%

6 Witherby Publishing Group - Shipping Regulations & Guidance Top five specific deficiencies:

CATEGORY NUMBER PERCENTAGE

ISM 1,797 4.3%

Fire doors/openings in fire-resisting divisions 1,044 2.5%

Nautical publications 1,016 2.5%

Charts 996 2.4%

Oil record book 645 1.6%

Top five MLC deficiencies:

CATEGORY NUMBER PERCENTAGE

Records of seafarers’ daily hours of work or rest 1,797 4.3%

Electrical 1,044 2.5%

Seafarers’ employment agreement (SEA) 1,016 2.5%

Access/structural features (ship) 996 2.4%

Cold room; cleanliness and temperature 645 1.6%

Witherby Publishing Group - Shipping Regulations & Guidance 7 Tokyo MoU

In 2015:

• A total of 31,407 inspections was performed • a total of 83,606 deficiencies was found • there were 1,153 detentions, with an average detention rate of 3.67% • the five poorest performing flag States were Sierra Leone, Indonesia, Niue, Mongolia and Palau.

Top six deficiency categories:

CATEGORY NUMBER PERCENTAGE

Fire safety measures 15,143 18.11%

Safety of navigation 12,619 15.09%

Life-saving appliances 11,213 13.41%

Loadlines 5,584 6.68%

ISM-related deficiencies 2,803 3.35%

Stability, structure and relevant equipment 2,422 2.90%

Most frequent items of equipment deficiency resulting in detention:

CATEGORY NUMBER

Lifeboats (life-saving appliances) 136

Fire-dampers (fire safety) 103

Shipboard operations (ISM) 82

Resources and personnel (ISM) 81

Ventilators, air pipes, casings (water/weathertight conditions) 80

Emergency fire pump and its pipes (emergency systems) 72

Oil filtering equipment (MARPOL Annex I) 69

Fire detection and alarm system (fire safety) 67

8 Witherby Publishing Group - Shipping Regulations & Guidance United States

The US has its own port State control regime. The USCG verifies foreign-flagged vessels operating in its territorial waters.

In 2015:

• A total of 73,752 ship visits was carried out by the USCG • 9,265 detailed safety inspections were carried out • 8,655 detailed security inspections were carried out • 202 ships were detained • the top five performing flag States were United Kingdom, South Korea, Japan, Norway and Germany • the five poorest performing flag States were Belize, Bolivia, Taiwan, Honduras and Tanzania.

The categories and percentages for safety deficiencies were:

CATEGORY PERCENTAGE

Fire-fighting appliances 21%

ISM-related deficiencies 17%

Life-saving appliances 14%

MARPOL Annex I 12%

Propulsion and auxiliary machinery 10%

All other 9%

Safety in general 7%

SOLAS operational deficiencies 3%

Load lines 3%

Crew 3%

See http://Shippingregs.org/2398.re for further information on US PSC Inspections

Other Sources Several P&I Clubs and Classification Societies release their own analysis of deficiencies and detention statistics. However, these usually apply only to vessels under their services. Readers should consult the relevant organisations for their vessels. For example:

• ABS – http://Shippingregs.org/2396.re • Class NK – http://Shippingregs.org/2393.re • DNV GL – http://Shippingregs.org/2397.re • Lloyds Register – http://Shippingregs.org/2395.re • North of England P&I Club – http://Shippingregs.org/2394.re

Witherby Publishing Group - Shipping Regulations & Guidance 9 Analysis In 2015, the category of fire-fighting appliances saw the highest number of ship deficiency observations and detentions across the Paris MoU, the Tokyo MoU and the US PSC inspection regimes. ISM, life-saving appliances and safety of navigation are also principal categories for safety deficiencies.

ISM Life-saving appliances Safety of navigation

Harry Harris Technical Advisor Marine Compliance & Regulations April 2017

10 Witherby Publishing Group - Shipping Regulations & Guidance Checklist for a PSC Inspection

The following areas that may be covered during a PSC inspection.

Documentation, Records and SMS

Inspection form details, e.g. date, place of inspection, time of inspection, ETD

Ship particulars form and ship/class/company information

All original copies of trading certificates

CSR file and ship’s plans

Seafarers’ national documents, certificates of competency and medical certificates

Approved manuals/documents (e.g. stability, cargo securing, SOPEP, etc)

Ship’s official, deck and engine log books

Safety Management System (SMS) in ship’s working language

Master’s review, internal and external audits under the SMS

Inspection, service, survey and maintenance records of LSA and FFA, and of navigation, engine, cargo and GMDSS equipment

Records and evidence of drills and training Records of crew familiarisation Emergency situations identified and checklists available Emergency contact information including DPA/shore contact details available and posted Accident, incident and non-conformity reporting procedures Master and crew familiar with their responsibilities and procedures [this may include, for example being asked to start the emergency generator, launch a survival craft and how to respond in the event of a fire] Documents being properly controlled

Life-Saving Appliances

Lifeboats and rescue boats – condition, equipment and certification Liferafts and HRUs Lifebuoys Lifejackets and immersion suits Means of embarkation for survival craft Emergency lights at survival stations Donning instructions (lifejackets and immersion suits), launching instructions and IMO symbols are posted LSA manufacturer’s maintenance instructions and SOLAS training manual

Witherby Publishing Group - Shipping Regulations & Guidance 11 Fire-Fighting Appliances

Fire detectors and alarm panels (bridge, E/R and fire control station) Fire lines, hydrants, equipment and international shore connection Main and emergency fire pumps Fixed gas/foam/dry powder/water spray fire-fighting installations Ventilation and insulation Portable fire extinguishers Fire-fighting arrangements are available and working in spaces such as in the galley, the engine room and the laundry Fire doors, fire dampers/ventilators FO/LO quick closing valves, E/R ventilation and FO pump remote stops EEBDs, BA sets and fire-fighters’ outfits Escape routes lighted, marked and unobstructed Testing schedule and maintenance records

Pollution Prevention

Oily water separator (OWS) operated correctly and oil content meter calibrated Oil discharge monitoring and control equipment (ODME) and 15 ppm alarm (if fitted) tested and operated correctly No illegal bypass piping or evidence of illegal discharge occurrences Warning placards against prohibited discharges posted Bilge and sludge pumps operational and other arrangements in good order Standard discharge connection readily available Garbage reception facilities adequate and categorised Records up to date, correct and available for inspection (including oil record book, garbage record book, ODS record book, record book of engine parameters, bunker delivery notes)

Navigation Safety and Communication

Up-to-date and corrected nautical publications and charts available Latest IMO and flag State required publications available Navigation equipment including inspection and testing records GMDSS installations including testing and records A fully prepared voyage plan, from berth to berth, approved by the Master Compass deviation card and records of compass errors Steering gear changeover procedure posted Navigational lights, shapes and sound signals in good order Engine telegraph, engine room and steering gear room communication operational Pilot ladders/hoist and arrangement for safe boarding Evidence of frequent position checking by multiple means

12 Witherby Publishing Group - Shipping Regulations & Guidance Machinery and Electrical

Main and auxiliary engines Instrumentation Remote and emergency starting systems Fuel oil and lubricating oil systems Boilers including the local and remote control of safety devices Bilge pumping system Engine control room equipment and switchboards Emergency generator Engine room cleanliness and organisation Quick closing emergency valves Emergency exits clear of any obstructions, lights working and safety symbols displayed. Electric circuits in good order and no earth faults present

Accommodation and ILO Requirements

Accommodation clean and habitable Galleys, pantries and food preparation areas clean and free of any infestation Hospital and sick bay clean and ready for use (hospital is not used as an extra cabin/store room) Adequate medical equipment and medical chest stocked as per WHO standards Readily available cold and hot water Adequate lighting, ventilation and heating systems Sufficient food and potable fresh water Refrigerated store room at adequate temperature and food storage routines observed

Load Line and Structures

Condition of hull, cargo hold/cargo tank structures, deck fittings and equipment and pipelines Load line marks clearly marked Hatch covers, coamings and stays Weathertight and watertight doors Safe access to the vessel, e.g. inspection of gangway and pilot ladders Remote operation of scuppers, inlets and discharges Guard-rails, catwalks and bulwarks Ventilators and air pipes, dampers, flaps and closing devices in order Approved stability booklet

Witherby Publishing Group - Shipping Regulations & Guidance 13 Ship Security

Ship Security Plan (SSP) available and protected from unauthorised access Master’s understanding of his responsibility and overriding authority Ship Security Officer (SSO) certificate and evidence of understanding Programmes and records for training, drills and exercises available Ship Security Alert System (SSAS) operational and the main and alternative power source properly maintained Control of access to ship Stowaway searches and records of security activities maintained

14 Witherby Publishing Group - Shipping Regulations & Guidance