- Due to the COVID-19 pandemic, some ships may experience operational challenges such as shipyards or dry docks closing down. In addition, surveys and audits can in some cases not be conducted because surveyors are unable to attend the ships due to travel restrictions or quarantines.
- IRS has issued Technical Circular 013/2020 dated 16th March 2020 enclosing the IMO Circular Letter No. 4204/Add.1, Add2, Add3 and Add4 which are addressed by IMO to all its member states. In the Circulars issued by the IMO Secretary-General has addressed the impact of COVID-19 on the shipping industry, including implementation and enforcement of mandatory IMO requirements. The Circulars provides encouragement for flexibility as the IMO can only encourage co-operation and a pragmatic approach between flag and port states, and cannot issue a general exemption from the mandatory provisions of the relevant statutory conventions, nor delay implementation of mandatory regulations coming into force - not even in the current uncertain situation.
- The current situation due to outbreak of Covid-19 presents operational challenges to everyone in the maritime industry. Protecting the health of our colleagues and our clients while taking steps to help contain the spread of the virus is our main focus.
- IRS remains committed to supporting our global clients with our team continuing to provide services worldwide while complying with all government-directed health and operational requirements and guidance.
- Depending on the specific circumstances, IRS may grant survey extensions as allowed by its Rules and IMO requirements for granting force majeure extensions for vessels scheduled to drydock for repairs or renewal surveys in affected areas or in the event if it is not possible for a Surveyor to immediately attend the vessel as scheduled.
- To contain the spread of the virus, depending upon the specific circumstances, each survey request will be reviewed on a case to case basis wherein we will be considering alternative options, including rescheduling inspections outside affected regions. IRS is working very closely with its clients and may also consider to postpone non-critical work where appropriate.
IRS has “force majeure” provisions in our Rules, applicable when survey work cannot be undertaken. The IRS Sub Committee of Classification will consider Force Majeure in the following circumstances:
a. When surveyors cannot attend a vessel because the ship is quarantined or due to travel or quarantine restrictions prevents the surveyor from attending the vessel.
b. In cases where the owner cannot mobilize essential technicians/service teams and any specialized equipment; or have essential spares delivered.
- IRS will generally accept the current COVID-19 situation as the justification for postponement of Class Surveys for up to 3 months beyond the due date in accordance with its Class Rules.
- Where Class Rules do not permit a postponement of the survey, IRS will consider an application for postponement based on Force Majeure.
- In all cases the basis for Force Majeure request is to be submitted by the client.
- Considering force majeure for statutory surveys is also subject to flag agreement being received for the duration of postponement/ delay in survey completion and towards this IRS will liaise with the Flag Administration where we are authorised to undertake statutory surveys on their behalf.
- Requests for postponement of surveys due to force majeure should be submitted to our Head Office at firstname.lastname@example.org . Each case will be different and will need careful consideration. Supplying information about the ship, its location and survey plan, as well as documents showing force majeure, will assist this process. IRS will not be able to consider a force majeure application which does not include a plan as to when the surveys will be completed. We will endeavor to process such requests as quickly as possible and should be able to respond to such requests within 48 hours.
- These are challenging times for everyone, as the Covid-19 outbreak is constantly evolving. IRS is actively monitoring the global situation and is committed to working with all its clients to support their business needs.
- If you need clarification in respect of any of the above, please do not hesitate to contact our Head Office or our local IRS Office.
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.