• In view of the ongoing COVID-19 pandemic, Indian Administration vide DGS Order No. 23 of 2021 has established following procedures for conduct of Surveys /Audits /Inspections which are falling due on or before 31st August 2021, and issuance of Short Term Statutory Certificates.
1. The procedure for extension request of Annual statutory surveys, periodical Load Line inspections or Interim/Initial/Intermediate/Renewal Audits/inspections:
a. Since the convention provisions provide sufficient time ranging between 3-12 months to the ship owners to complete these surveys/inspections/audits, all efforts are to be made by the company /owners to offer their ships to the RO for surveys, audits/inspections, in case these are within the range period.
b. Nevertheless, considering the gravity of situation developed by second wave of COVID-19, the Directorate permits conduct of Remote Annual statutory surveys & Interim/Initial/Intermediate/Renewal Audits/inspections provided the stated remote survey/inspection/audit is subsequently confirmed through a physical survey /audit/inspection (except for interim SMS/ISPS Audit or interim MLC inspection) within 6-months of this remote survey/audit/inspection and accordingly the endorsement/issuance of relevant Statutory Certificates are subjected to following conditions:
i. The Vessel is an ESP Vessel less than 15-Years of age or a non-ESP Vessel less than 20-Years of age.
ii. The vessel has not been detained under PSC/FSI since last survey or involved in a casualty requiring investigation by Administration/Port State.
iii. Vessel has not been under any Condition Improvement/Monitoring programme of RO since last renewal survey.
iv. RO must have procedures for satisfactory conduct of such survey/audit/inspection.
v. The SMC/ISPS Audit & MLC inspections which require Administration participation to have mandatorily participation of Administration Surveyor appointed by Registrar of Vessel/Directorate irrespective of the vessel location. However, there is no need for participation for confirmatory physical audit/inspection irrespective of the location of the vessel.
vi. No permission from Directorate is required for issuance/endorsement of relevant statutory certificates.
vii. In case interim SMC/ISPS Audit or interim MLC inspection has been conducted using above provisions, the subsequent initial audit/inspection using above remote provisions is not allowed.
c. The permission to grant short term statutory certificates valid for a maximum period of 3-months for vessels which do not fall under above category will be subject to:
i. Submission to Administration of satisfactory Risk Assessment based on a remote survey, past survey reports, SMC/ISPS/DOC audit non-conformities, MLC deficiencies, and FSI/PSC deficiencies/records.
ii. Based on above, Administration will permit issuance of short term statutory certificates valid for a maximum period of 3 months.
iii. These vessels are to be offered for complete physical survey at first available opportunity for issuance of full term statutory certificates.
2. The procedure for issuance of Short Term Statutory Certificates due to non-availability of docks for completion of Intermediate Surveys requiring dry-dock are to be subjected to following:
a. Issuance of Short Term Statutory Certificates will not be granted for a period more than 3-months after the expiry date of window period or 42 months since last dry-dock, whichever is earlier. Even in case of ships completing, 36-Months prior expiry date of window period for SAFCON intermediate surveys, the short term statutory certification will be limited to 3-Months.
b. The Administration will permit issuance of short term statutory certificate for those intermediate surveys requiring dry-dock (Safety-Construction) subject to:
i. Submission of a firm evidence, of date of dry-dock availability from the selected dry-dock, that is, stemming agreement.
ii. No short term statutory certificate will be granted at a time for a period more than 3-months. In case of vessels where an extension is already obtained after submission of firm stemming agreement, no further issuance of Short Term Statutory Certificate will be considered unless valid reasons are furnished by the applicant towards the change in the stemming date.
iii. RO recommendation after satisfactory general examination of hull, machinery, fittings (structural and non-structural) and equipment, satisfactory thickness measurement, as applicable, examination of forepeak ballast tank, aft-peak ballast tank and other representative water-ballast tanks, examination of foremost and aft cargo holds and one other Cargo Hold in case of Single-Hull Bulk Carriers, trammel gauge reading, last poker gauge readings etc. as required by Directorate or RO and a CCTV examination of the underwater portion of the hull, appendages, propeller and rudder.
iv. For non-ESP Vessels and ESP Vessels (less than 15- years of age), Administration will accept recommendation from RO based on a satisfactory report of underwater examination by RO after a review of video-recording of the underwater examination endorsed for witness by Master/CE/Superintendent/DPA of the vessel.
v. These Surveys are to be carried out prior grant of short term statutory certificates. In case RO Surveyor is unable to board the vessel, short term statutory certificate will be granted till the port RO Surveyor can board the vessel and subject to submission of a satisfactory risk assessment based on remote survey/inspection by RO.
vi. Second issuance of short term statutory certificate is considered only in case of change in date of dry-dock. CCTV examination carried out during previous issuance of short term statutory certificate can be accepted by RO provided Master gives a declaration that no damage to underwater portion of hull or appendages has occurred since that underwater examination.
c. The Intermediate Surveys related to Statutory Certificates not requiring dry-dock (such as Safety Equipment/Radio/IAPP/IOPP/Load-Line etc.) are required to be completed in entirety through physical surveys. In case a RO Surveyor is unable to board a vessel, Administration will permit for issuance of short term statutory certificate for a maximum period of 3- months or till the port the RO Surveyor can board the vessel for physical surveys and after submission of a satisfactory Risk Assessment involving remote survey/inspection by RO.
3. The procedure for issuance of Short Term Statutory Certificates beyond 3-months from expiry date of statutory certificate due to non-availability of docks for completion of Renewal surveys:
a. Issuance of short term statutory certificates will not be granted for a period more than 6-months after the due date of renewal survey or 42 months since last dry-dock, which-ever is earlier.
b. No short term statutory certificate will be granted for a period more than 3-months. In case of vessels where an extension is already obtained after submission of firm stemming agreement, no further extension will be considered unless valid reasons are furnished by the applicant towards the change in the stemming date.
c. Administration will grant issuance of the Short term statutory certificates for surveys requiring docking (Safety Construction) for a period beyond 36-Months since last dry-dock or beyond 3-months of expiry date, subject to:
i. Submission of a firm evidence of date of dry-dock availability from the selected dry-dock, that is stemming agreement.
ii. Renewal Surveys to be progressed as far as feasible.
iii. Recommendation from RO after a satisfactory general examination of hull, machinery, fitting (structural and non-structural), equipment, satisfactory thickness measurement, as applicable, examination of forepeak ballast tank, aft peak ballast tank and other representative water-ballast tanks, examination of fore-most and aft Cargo holds and one other Cargo Hold in case of Single-Hull Bulk Carriers, trammel gauge reading, last poker gauge readings etc. as required by Directorate or RO.
iv. A CCTV examination of the underwater portion of the hull, appendages, propeller and rudder.
v. For non-ESP Vessels and ESP Vessels (less than 15- years of age), Administration will accept recommendation from RO based on a satisfactory report of underwater examination by RO after a review of video-recording of the underwater examination endorsed for witness by Master/CE/Superintendent/DPA of the vessel.
vi. In case second issuance of short term statutory certificate is considered, CCTV examination carried out during previous issuance of short term statutory certificate can be accepted by RO provided Master give a declaration that no damage to underwater portion of hull or appendages has occurred since that underwater examination.
vii. These Surveys are to be carried out prior grant of short term statutory certificates. In case RO Surveyor is unable to board the vessel, short term statutory certificate will be granted till the port RO Surveyor can board the vessel and subject to submission of a satisfactory risk assessment based on remote survey/inspection by RO.
d. Administration will grant issuance of the Short term statutory Certificates for renewal Surveys not requiring dry-dock (SEQ/SRT/IOPP/IAPP/Load-Line etc.) subject to:
i. Surveys are completed to the extent possible either prior extension or at first port.
ii. A risk assessment to be conducted for items outstanding to be completed at drydock such as 5-yearly load testing of life-boat/rescue boat and launching appliances, load test of accommodation ladder, calibration of oil-content meter etc. and recommended for extension with the Risk assessment.
iii. These Surveys are to be carried out prior grant of short term statutory certificates. In case RO Surveyor is unable to board the vessel, short term statutory certificate will be granted till the port RO Surveyor can board the vessel and after submission of a satisfactory risk assessment based on remote survey/inspection by RO.
4. Extension of Annual/Periodical/5-Yearly Servicing Life-Saving, Safety and Navigational Equipment.
Owners are to make all efforts to complete Annual/Periodical servicing of life-saving/Safety/Navigational items and may use approved service supplier without specific manufacturer approval for that make and type of life-saving appliances, provided the servicing is carried out in presence of RO Surveyor. This extension can only be granted for a maximum period of 3-months subject to satisfactory:
a. Risk Assessment carried by RO Surveyor either by physically attending the vessel or, if the Surveyor cannot attend due to restrictions, on the basis of submission of documents/photographs/Videos, past servicing records, PSC/FSI deficiencies on said item after last servicing etc. and
b. A declaration from Master/CE stating continued effectiveness of these items during the period for which dispensation is sought.
c. No extension from expiry date of replacement of Safety/Life-Saving/Navigational items will be granted/permitted.
5. Exemptions from Safe Manning Document:
Any dispensation from safe manning will be on case to case basis where-in a seafarer is required to be signed-off in an emergency and a risk assessment is submitted.
6. Interim/Initial/Annual/Renewal DOC Audit.
Owners can opt for remote DOC Audit and issuance of short term DOC valid for a maximum period of 6-months may be issued and within this validity to complete the physical audit for issuance of endorsement/full-term certificate.
7. Change of Flag Surveys.
a. This provision is only applicable where the change of flag is undertaken at ports which do not permit RO Surveyor to board the vessel once replacement crew joins the ship.
b. Issuance of Statutory Certificates.
i. As far as possible, the Owner/Manager to ensure that RO Surveyor boards the vessel before replacement crew joins and carry out a satisfactory general inspection with specific attention to safety/life-saving/navigational equipment and their continued effectiveness. In case, he is unable to do so, the joining Master and CE have to carry out a joint inspection and send report to RO Surveyor along with photographic evidence of satisfactory condition of ship, machinery and equipment.
ii. The vessel will be issued short term Statutory Certificates valid for a period of 6-months or shorter depending upon the expiry date of window period of Annual/Intermediate surveys, if within the range date or expiry date of certificate. These Short Term Certificates can be converted into full term certificates subject to satisfactory physical confirmatory surveys within that period.
iii. No remote Annual surveys under Paragraph 1 will be permitted in all such cases without completion of a physical confirmatory survey held prior to that.
c. Carving and Marking Surveys during Provisional Registration.
i. The joining Master of the Vessel has to send photographic evidence of the Carving and Marking carried out with his CoC details to RO Surveyor conducting provisional registration surveys.
8. The extension of tail-shaft surveys for a maximum period of 1-Year and boiler surveys for maximum period of 3-months will be considered by the Administration for all ship type and age based on a recommendation by RO after satisfactory physical or remote surveys.
9. Dispensation from fitment of Ballast Water Treatment System:
a. In case Docking Survey extension is granted by the Administration, the dispensation from fitment of ballast water treatment system for compliance to BWM Convention will be automatically granted.
b. For ships with de-harmonized IOPP Certificate, the dispensation from fitment will be granted subject to submission of valid documents necessitating such dispensation.
c. All vessels granted dispensation are required to meet all other requirements of BWM Convention and shall discharge Ballast Water complying with D-1 standards at Indian ports. Further following condition will be imposed on Statement of Compliance:
i. Prior permission is to be taken from Maritime Administration of the foreign ports with regards to dispensation from BWTS granted irrespective of whether the vessel intends to discharge Ballast Water or not at that port and in case ballast water is required to discharged, permission to discharge ballast water complying with D-I standards is also to be undertaken.
10. Extension of Flag State Inspections:
a. Whereas FSI are required to be carried out within 1-3 months of Annual/Periodical/Intermediate/Renewal surveys, all FSI stands extended in case any extension is granted for Annual/Periodical/Renewal Surveys.
b. Further this period of 1-3 months is extended to 1-6 months for all those ships which have completed Annual/Periodical/Intermediate/Renewal Surveys in 2021 or will complete the same within the validity period of DGS Order No. 23 of 2021.
c. However, any FSI imposed while granting extension under above Order has to be completed within the time given or extension sought separately from FSI cell of the Directorate.
11. All vessels issued with short term Statutory Certificates granted without having completed physical surveys are subject to following additional conditions to be imposed on relevant short-term Statutory Certificates:
a. Prior entering any foreign load/discharge port, will take permission from relevant Maritime Authorities for acceptance of statutory certificates in case where the short- term certificates are issued beyond Convention provisions.
b. The Company is to enhance monitoring by way of self-regulation such as increased internal audit, superintendent inspection of their vessels, etc. to ensure safety of ship and seafarer through its shore staff during this period of extension.
c. Any other conditions imposed by Directorate.
12. The Procedure and policy for above monitoring to be addressed in the company’s SMS (Safety management System) and approved by DPA and records to be maintained for verification at next audit/FSI.
13. Administration has urged Company/owners to exercise due diligence while requesting for any such extensions, keeping primary importance to environmental protection and public health over its commercial / earning aspects of the vessel.
14. Acceptance of Extensions granted to Foreign Ships beyond what is permitted under International Conventions by their Administration:
All such ships are required to take prior permission from jurisdictional Principal Officer prior entering an Indian Port. This may require submission of survey status, past Port State control, reports etc. and imposition of any other requirements by jurisdictional Principal Officer such as inspection by a Port State Control Officer.
15. Ship owners/ managers and masters are advised to be guided by above and are requested to contact IRS HO for conduct of surveys under the provisions of DGS Order No. 23 of 2021 so that necessary guidance can be provided.
16. This Technical Circular supersedes and revokes earlier Technical Circular No. 007/2021, dated 27th January 2021.
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.