New MCA Report: Port Marine Safety Code Health Check Trends 2015

On 3 March 2016, the Maritime and Coastguard Agency ("MCA") published its report: Port Marine Safety Code Health Check Trends 2015. This report relates to the eight Port Marine Safety Code Health Checks the MCA conducted in 2015, at the following types of port within the UK: 

  • 1 Private Port
  • 3 Municipal Ports
  • 4 Trust Ports

Three of the organisations above were deemed as non-compliant with the Port Marine Safety Code ("PMSC") and will be visited again by the MCA during 2016, to verify that issues have been addressed.

Three adverse trends had been highlighted during the 2014 health checks.  Following the 2015 health checks, they are all still considered areas for improvement in a number of cases: 

1. Duty holder
2. Risk assessment
3. Marine safety management system

In addition, two new adverse trends highlighted during the 2015 health checks were: 

4. Conducting proper consultation or stakeholder engagement
5. Information dissemination

The MCA is encouraging the whole industry to take account of the points identified in its report and to consider whether any of them may be applicable to their organisations. The report (at 22 pages) is not a lengthy document and should be read and considered by all statutory harbour authorities; any improvement points identified should then be actioned.

Below is a summary of some of the issues identified in relation to the five adverse trends above. The actual report contains specific examples which it would be sensible for all statutory harbour authorities to consider, over and above the broad points outlined below:

1. Duty Holder

  • Duty holder awareness of roles & responsibilities under PMSC 
  • Formal & documented streams of reporting to duty holder 
  • Duty holder not appointed 
  • PMSC Training for duty holders

2. Risk Assessments

  • Define & document review frequency 
  • Identify ranked hazards and use of ALARP principle 
  • Review risk assessment post incident / accident report 
  • No stakeholder engagement when reviewing risk assessments

3. Safety Management System

  • No MSMS in place 
  • MSMS produced but not being used 
  • No review frequency 
  • Customs and practices not captured by MSMS e.g. hot works, bunkering, engine immobilisation etc. 
  • Staff roles and responsibilities not defined (inc. Harbour Masters)

4. Conducting proper consultation or stakeholder engagement; and

5. Information dissemination

  • No consultation during risk assessments 
  • No user group to help build a consensus on safe navigation 
  • ALRS vol 6 entry not updated 
  • No marine / navigational guidance to users




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