东京备忘录：ECDIS导致ISM滞留复议案例

A gas carrier built in year 2008 was inspected. Following three deficiencies, including one detainable deficiency, were issued by the PSC officer:

一艘建造于2008年的气体运输船被检查，PSC检查官开列三项缺陷，包括一项滞留缺陷：

10112 Electronic charts (ECDIS) -

Both primary and secondary ECDIS being used for navigation. Equipment is not proper, both equipment screen showing alarm of non ENC data on display (Action code: 30)

主用及备用ECDIS都处于使用状态，但两台设备屏幕都显示无ENC数据报警，设备故障。（行动代码30）

10127 Voyage or passage plan - 

Passage plan not properly made as required by SOLAS (Action code: 17)

 航次计划没有按照SOLAS的要求合理设置。（行动代码17）

15106 Shipboard operations -

ISM unable to ascertain operation of Safe Navigation as evidence from deficiencies 1 and 2 (Action code: 18)

由第1和第2项缺陷得到ISM未能保证安全航行操作。（行动代码18）

The PSC officer decided to detain the vessel based on the following facts:

PSC检查官依据以下事实决定滞留此船：

1. the ECDIS indicated a warning stating “Non ENC data on display”;

安装的ECDIS显示“没有ENC数据显示”警告；

2. regarding the warning, although the Company Superintendent & Master stated they had a contract for ENCs, but were unable to explain the significance of the warning;

 关于此警告，虽然公司机务和船长表达他们与ENC有合同，但不能解释这个警告的意义；

3. till the end of inspection, it could not be definitively established that charts being used for navigation were official ENCs.

直到检查结束，船舶不能证明用于航行的ECIDS是官方ENC设备。

The company made appeal on the detention, expressed reasons that:

管理公司对此滞留提出复议，理由如下：

1. ENC were actually used in the ECDIS;

ENC当时事实上用于ECDIS；

2.The warning message was activated only when an update/object was placed on ENC.

警告信息仅当更新或在ENC设置目标时才会触发。

Summary 总结

At the time of inspection, it was appropriate for the PSCO to make the decision of detaining the ship as the Officer’s onboard were unable to explain the warning, and appeared to not be fully conversant with the operation of the ECDIS. This gives rise to great concern in relation to the crew competence in using the ECDIS and the efficiency of onboard familiarization training.

检查时，由于驾驶员不能解释警告且表明其不能熟练操作ECDIS，PSC检查官做出滞留的决定是合适的。其导致检查官重点关注船员使用ECDIS是否熟练和船上熟悉培训的效果。

 Based on the evidence received subsequently, it appears that an ISM detention was clearly justified. However, the detention was not given in relation to the effectiveness of the ISM system but only to the ECDIS. As such the detention is found technically incorrect when the matter about non ENC data used is cleared/resolved.

基于随后收到的证据，表明ISM滞留是明显合理的。不过，此次滞留仅仅基于ECDIS，并非基于ISM的有效性。如果没有ENC数据这个问题解决了，则滞留从技术上来说是错误的。

Question

What do you think about this case? 

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