The Marshall Islands Administration vide Marine Safety Advisory No. 14-20 has provided guidance as detailed below on maintaining the validity of statutory certificates due to restrictions imposed as a result of the COVID-19 pandemic.
Extending the period between dry-docks and the validity of certificates for more than three months:
a. For extensions due to extreme extenuating circumstances, provided there is evidence suggesting best efforts have been made to secure dry-dock space, the Administrator will consider extensions to intermediate and renewal dry-docking beyond three months. The current limit of this extension will be up to six months. This will be kept under review as the result of the efforts to tackle the pandemic become clearer. The operator should apply to the RO for an extension and prepare the ship to allow a survey to the maximum extent possible while out of a dry-dock. The extent of this preparation must be agreed with the RO prior to commencement of surveys.
b. The ship’s Classification Society must also be willing to consider the validity of the ship’s main Class certificate, since in accordance with IMO Circular, MSC-MEPC.5/Circ.1, “the extension period of the relevant statutory certificate(s) should not exceed the period of validity of the certificate which may be issued to document compliance with the structural, mechanical and electrical requirements of the recognized classification society.”
c. All Class and statutory surveys must have been progressed as far as practicable while afloat, leaving only the minimum pending items to be checked in dry-dock. Where it is relevant to the age and type of ship, and safe to do so, the scope of the survey should also give consideration to the enhanced survey program. Any minor deficiencies can be recorded as Conditions of Class, or Statutory Conditions, as appropriate, with due date until dry-docking. Major deficiencies must be rectified. Class and short-term statutory certificates should be issued to reflect the pending items that remain to be tested and surveyed.
Ships experiencing problems installing and commissioning Ballast Water Management Systems (BWMS):
When the date for D-2 compliance for a ship has passed and there are issues with respect to installation and commissioning of BWMS, the ship must maintain an approved plan for conducting a D-1 ballast water exchange. A remark should be made in the Ballast Water Record Book that the BWMS is not operational and covered by a short-term certificate.
The below are some specific scenarios; others may be dealt with in a similar manner.
a. The ship cannot enter a drydock. Consider extending certificate renewal and maintain the current D-1 Ballast Water Management option on International Ballast Water Management Certificate (IBWMC).
b. The ship can enter a drydock but is not able to install the BWMS because the equipment is in another location with quarantine restrictions.
Consider continuing with the drydock and preparing the ship to receive the BWMS and complete the installation without going back to dry-dock. The RO may issue a short term IBWMC, valid for three months, indicating the D-1 Ballast Water Management method. The certificate should be annotated with text to the effect: “The BWMS could not be installed due to COVID-19. Prior to any ballast discharge the relevant coastal State must be contacted to discuss contingency measures, guidance on these can be found in IMO Circular BWM.2/Circ.62. The ship has a ballast water exchange method approved to the D-1 standard and the Administrator has no objections to D-1 exchange being used in-lieu of the BWMS, however concurrence from the coastal State must be obtained before this option can be used.”
Alternatively, consider delaying the drydock.
c. The ship is able install the BWMS, but due to travel restrictions/quarantine is unable to commission the BWMS: Complete the drydock and BWMS installation, and renew all certificates. The RO may issue a short-term IBWMC, valid for three months, indicating only the D-2 Ballast Water Management method. The certificate should be annotated with text to the effect: “The BWMS is not functional. Prior to any ballast discharge the relevant coastal State must be contacted to discuss contingency measures, guidance on these can be found in IMO Circular BWM.2/Circ.62. The ship has a ballast water exchange method approved to the D-1 standard and the Administrator has no objections to D-1 exchange being used in-lieu of the BWMS, however concurrence from the coastal State must be obtained before this option can be used.”
Ship owners/ operators and masters of Marshall Islands flagged ships are advised to be guided by above.
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.