ACS and EAS
Alternative Compliance Scheme and Enhanced Authorisation Scheme
There is a good chance that the ACS or EAS will come up in your exam, especially if you mention them in passing when talking about surveys and certificates. This is a golden opportunity, as both the ACS and EAS are very easy to remember and talk about, so I would urge you to mention them if you are already on these topics. Find out if your ship is on either of these, as that can be a good lead-in.
For example, while answering the classic ‘which certificates would you check on joining?’ question:
‘…I’d also check the Safety Management Certificate, the Maritime Labour Certificate and the International Ship Security Certificate, especially since these have a different schedule to the HSSC certificates and as they are retained by flag for ships on the ACS…’
Learning about both the ACS and EAS at the same time is a good idea, as they are similar in some ways, but do be careful not to get them mixed up.
Relevant MGNs: MGN 561 (EAS) and MGN 568 (ACS)
Firstly, let’s talk about the Alternative Compliance Scheme. This is the older of the two schemes and is a way of the flag state to reduce duplication of effort by delegating a lot of survey work to classification societies. It’s worth noting that the MCA intend to phase out the ACS, replacing it with the EAS, but that is a long way off yet. It’s a UK thing (other countries may have their own versions, but you’re sitting a UK exam so forget about those) and it’s only open to vessels that meet certain criteria.
To apply for and be accepted to the ACS, a cargo ship must meet the following criteria ( I have made bold the figures that are worth memorising). Remember that passenger vessels are not eligible for the ACS:
The vessel has not been detained within the previous 36 months;
During any port state control inspection within the previous 12 months no inspection report shall have recorded more than 5 deficiencies;
The vessel is classed with one of the Recognised Organisations authorised by the UK (look up the list; Lloyds, BV, RINA, ABS etc.)
The owner shall permit access by the MCA to any or all records, files, reports, documents and certificates held or issued by the ACS Recognised Organisation the vessel is classed with; and,
The owner or operator shall notify the MCA one-month in advance of all in water
surveys or dry docking dates.
As you can see, this is an easy list to remember. Bad-boy ships don’t get to be ACS. Bad boys have been to jail (detentions), been fined (deficiencies), they don’t hang about with the good gang (the ROs), they won’t let you see their passport (access to documents) and they never tell you when they’re going to show up (notice of in water surveys or drydocking).
How does a vessel become part of the ACS?
The owner or operator of a vessel applies to the UK Ship Register (UKSR) for enrolment into the scheme. You have to apply; this is in contrast to the EAS, which is invite-only. Then the UKSR verify that you meet the requirements, and forward the information to the Survey Operations Branch.
Once the ship has been inspected (often at delivery, or when flagging-in) an interim Certificate of Inspection (CoI) is issued, with the same expiry date (6 months) as the interim Safety Management Certificate (SMC). Then, after 3 months, an initial inspection is carried out along with the initial inspection for the full-term SMC and the vessel gets a full-term CoI, with an expiry date synced with that of the SMC. From this point onwards, all surveys except the ISM and ISPS audits and the MLC inspections are carried out by your RO (class society) as they fall due.
(If you’re hazy on the difference between the interim, initial, annual, intermediate, periodical and renewal inspections/audits, read the article ‘Audit, survey or inspection’; a link will be posted here once published.)
The MCA always issue your Safe Manning Document, the company Document of Compliance and any exemptions, exceptions and equivalencies.
How can you be kicked out of the ACS?
Again, there is a simple, easy to remember list:
the vessel’s involvement in a serious marine accident, casualty or pollution incident
failure to correct an ACS Recognised Organisations’ condition of class or statutory deficiency within the permitted time
expiry or invalidation of required documents
Port State Control (PSC) detention which in view of MCA is technically justified. (In reaching this decision, MCA shall technically evaluate the PSC inspection report)
Repeated failure in rectifying deficiencies identified at PSC inspections and/or surveys
If the CoI is revoked, the owner/operator will be notified in writing by the MCA.
Which certificates are covered by the ACS?
N= No, F=Full, A=Advise flag
The Enhanced Authorisation Scheme is, if anything, even easier to remember. To the question ‘What is the EAS?’ an excellent answer would start with:
‘EAS provides for partial or full authorisation to UK Recognised Organisations for survey and audit of selected UK registered ships operated by eligible shipping companies; linked to a flag inspection regime and based on a risk profile.’
Who is eligible for the EAS?
The EAS is a voluntary, invite-only scheme, eligible to ‘selected ships’ run by ‘eligible companies’. It’s like a posh country club, where only the very best members of society are invited to join. This is largely based on the ship’s risk profile (more on this to follow).
The conditions of the scheme are:
Once accepted, ships will remain on the scheme, unless they are considered High risk, in which case they will be removed from the scheme.
The company agree to pay MCA fees to cover the cost of flag inspections.
The company will facilitate and maintain flag inspections at the stipulated schedule.
The company will actively facilitate MCA monitoring of RO performance through Vertical Contract Audits (VCA) on ships enrolled or to be enrolled under the EAS.
Once a ship is part of the scheme, it will be issued with a Letter of Authorisation of Enhanced Authorisation (the Letter of Authorisation). A new LoA is issued each year, giving the ships risk profile.
What certs does the MCA still issue, what inspections does the MCA still carry out?
The MCA still issues the company Document of Compliance, and will retain oversight of the vessel by carrying out flag state inspections of the ship, with the intervals between these based on the ships risk profile. This risk profile is calculated annually, and issued with the Letter of Authorisation. It is based on:
Port State Control (PSC) record
General Inspection (GI) record
RO Statutory Records
Management Company ISM Performance
Other Ship Factors (takes account of ship type/age/casualties/ship builder)
Other non-specified factors
Each factor covers a rolling five year period with a declining importance of any detentions, deficiencies or non-conformities over time. Risk profile and inspection intervals are best presented as a table.
There is a fourth risk category - High Risk Ships. These are kicked off the EAS and subject to 6-monthly inspections, starting within 6 weeks.
The MCA remain responsible for exceptions, exemptions, equivalences and Temporary Dispensation Letters.
MCAQs for this subject:
Which certificates are reserved to class under the ACS?
Which certificates are reserved to class under the EAS?
What are the conditions for becoming part of the ACS?
What can lead to a ship being kicked off the ACS?
How would you know/check if your ship is on the ACS? (Think about which certificate you’d have).
Which vessel-type specific certificates are retained by the MCA for ships on the ACS? (High-Speed Craft Safety Certificate, Certificate of Survey of Vessel Standing by Offshore Installations. Can also answer Passenger Ships, but explained that all passenger ship certificates are retained by the MCA.)
How would you know/check if your ship is on the EAS?
How would you know the frequency of port state inspections if your ships is on the EAS?
Your MLC Certificate has expires; who should you inform?