BMSR Compassionate Statement In memory of : Chief Officer Dang Duy Kien, Bosun Bobie T. Silvestre, Messman Isiah Penaverde

BMSR Compassionate Statement In memory of : Chief Officer Dang Duy Kien, Bosun Bobie T. Silvestre, Messman Isiah Penaverde

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Bulletin 015 – Continuous Synopsis Records

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

 

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) SOLAS, International Convention for the Safety of Life at Sea.
c) IMO Resolution A.959(23) Format and guidelines for the maintenance of the Continuous Synopsis Record (CSR)
d) The International Ship and Port Facility Security Code (ISPS Code).

2. Purpose

2.1 This Bulletin outlines the requirements of the BMSR for the issuance of Continuous Synopsis Record (CSR), as required by SOLAS Chapter XI-1/5.
2.2 The CSR is intended to provide an on-board record of the history of the vessel with respect to the information recorded therein.

3. Definitions

3.1 Company means the owner of the ship or any other organisation or person such as the Manager, or the Bareboat Charterer, who has assumed the responsibility for operation of the ship from the shipowner and who, on assuming such responsibility, has agreed in writing to take over.
3.2 In accordance with IMO Resolution A.959(23):
.1 CSR Document means Form 1 that is issued by the BMSR, numbered sequentially over the life of the vessel;
.2 CSR Amendment Form means Form 2 filled in by the Company to update information contained in the CSR;
.3 CSR Index of Amendments means Form 3 filled in by the Company for the record of amendments made to the CSR.
.4 CSR file means all the Form 1, 2 and 3

4. Application

4.1 This Bulletin applies to all Barbadian vessels engaged on international voyages, except for .
.1 Cargo ships of less than 500 gross tonnage;
.2 Vessels not propelled by mechanical means;
.3 Pleasure (Private) yachts not engaged in commercial operations.
4.2 Vessels voluntarily complying with the ISPS Code must make a written request to the BMSR for the issuance of a CSR Document. Once issued, it must be maintained in accordance with SOLAS requirements.

5. Requirements

5.1 The BMSR now issues certificates electronically, including CSRs. All previously issued “wet ink” certificates remain valid and do not require reissuing.
5.2 The CSR shall be kept on board the vessel and shall be available for inspection at all times. 5.3 A permanent CSR file must be kept onboard the ship and be available for inspection upon request by any Designated Authority. It must contain all previously issued, original CSR Documents comprised of all:
.1 CSR Document (Form 1);
.2 CSR Amendment Form (Form 2);
.3 CSR Index of Amendments (Form 3).
5.4 The CSR must be left onboard a vessel whenever:
.1 transferring to the flag of another State;
.2 selling to another owner;
.3 taking over by another bareboat charterer;
.4 another Company assumes the responsibility for the operation.
5.5 For vessels constructed before 01 July 2004, the CSR Record shall, at least, provide the history of the ship as from 01 July 2004.
5.6 Electronic CSR file backups are permitted. However, the original CSR Documents, dated and countersigned by the Master, and complete CSR file must be maintained onboard the vessel.
5.7 If any of the information in sections 2 to 16 of the CSR document changes or is incorrect, a new CSR document must be issued.
5.8 To make amendments to the CSR, the company or Master shall complete an amendment form (Form 2 of the CSR). The original amendment form is to be attached to the current original CSR document. Details of the amendment are also to be entered in the index of amendments (Form 3) and attached to the current CSR document in date order.
5.9 On receipt of a revised and updated CSR document, the Master should check its sequential number and review the document to ensure that it covers all relevant amendment forms attached to the previous CSR document.
5.10 CSR Index of Amendments Form 3 is not required for issuing a new CSR and is to be completed and signed by the Master or other authorised signatory and kept in the vessel’s CSR file on board. A new form 3 shall be completed as a record for each Amendment and dated accordingly.

6. CSR Application

6.1 For new building and registration anew the BMSR will issue CSR Document with number 1 at provisional registration.
6.2 A completed Form 2 is to be submitted to the BMSR for all the cases below:
.1 Registration from another flag;
.2 Laid-Up/Re-activation;
.3 Bareboat in and out;
.4 Change of Registered Ownership;
.5 Change of Registered Owner’s Name and/or Address;
.6 Change of a vessel’s name;
.7 Change of ISM Management/Address;
.8 Change of Classification issuing body;
.9 Change of ISSC/SMC issuing body;
.10 Duplicate for lost/damaged originals.6.3 The application should be accompanied, as appropriate, by:
.1 Copy of Certificate of Class;
.2 Copy of current Barbados ISM Document of Compliance (DOC);
.3 Copy of the vessel’s ISSC & SMC Certificates;
.4 Copies of all previously issued CSRs (In the case of a vessel being transferred from another flag, within 3 three months after the registration).

7. Barbados initial CSR

7.1 When registering in with the BMSR from another flag Administration, the following is also required:
.1 Former flag deletion certificate;
.2 Former flag final (ceased) CSR.
7.2 The former flag State should issue the final CSR document to the vessel showing the date the vessel ceased to be registered with that flag State.
7.3 That flag State is required to send a copy of the vessel’s CSR file, as soon as possible and preferably not later than one month from the date the vessel ceased to be registered, to the new flag State.
7.4 The BMSR will issue the initial CSR as soon documents as per Sec 7.1 above are received. Nevertheless, in accordance with IMO Resolution A.959(23), should the former flag State or the managers fail to provide the ceased CSR within three months from the date of change of flag, the BMSR shall issue to the vessel a CSR based on the CSR information received from onboard the vessel. The sequential number of the CSR document will be the second sequential number after the last sequential number shown on the CSR document found (i.e. leaving first sequential number unused). The BMSR shall record this in entry box 11.
7.5 A vessel cannot be permanently registered until the BMSR receive the ceased CSR from former flag. Therefore, at provisional registration the BMSR will issue a 3-month Certificate of Registry, to wait for ceased CSR or to issue a new CSR as per sec. 7.4 above.

Revision No

Description Of Revision

1.0

First Issue.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Bulletin 027 – MARPOL Annex VI

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

 

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) Barbados Shipping (Oil Pollution) Act (CAP296A.
c) International Convention for the Prevention of Pollution from Ships (MARPOL).
d) NOX Technical Code 2008 (NTC 2008).
e) MEPC.1/Circ.892 Guidelines for exemption of unmanned non-self-propelled (UNSP) barges from the survey and certification requirements under the MARPOL Convention.
f) Resolution MEPC.340(77) 2021 Guidelines for Exhaust Gas Cleaning System.
g) MEPC.1/Circ.795/Rev.2, Unified Interpretations to MARPOL Annex VI.
h) Resolution MEPC.364(79) 2022 Guidelines on the Method of Calculation of the Attained EEDI for New Ships.
i) Resolution MEPC.333(76) 2021 Guidelines on the Method of Calculation of the Attained (EEXI).
j) Resolution MEPC.324(75) Procedures for sampling and verification of the sulphur content of fuel oil and the Energy Efficiency Design Index (EEDI).
k) Resolution MEPC.320(74) 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.
l) MEPC.1/Circ.881 Guidance for port State control on contingency measures for addressing non-compliant fuel oil;
m) MEPC.1/Circ.864/Rev.1 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships.
n) MEPC.1/Circ.889 2020 Guidelines for on board sampling of fuel oil intended to be used or carried for use on board a ship.
o) MEPC.1/Circ.884/Rev.1 Guidance for best practice for Member State/coastal State.
p) Resolution MEPC.346(78) 2022 Guidelines for the development of a ship energy efficiency management plan (SEEMP).
q) Bulletin 008 – Permits Exemptions and Equivalences.
r) Resolution MEPC.348(78) 2022 Guidelines for Administration verification of ship fuel oil consumption data and operational carbon intensity.
s) MEPC.1-Circ.876 Sample Format for The Confirmation Of Compliance, Early Submission Of The SEEMP Part II etc.
t) Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport, and amending Directive 2009/16/EC.
u) SI 2018/1388 The Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions) (Amendment) (EU Exit) Regulations 2018.
v) MIN 669 (M+F) Amendments 1 – Reporting Emissions Data into the UK MRV Regime.
w) Resolution MEPC.335(76) 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve.
x) Resolution MEPC.375(80) Amendments to the 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve (res. MEPC.335(76)). 

2. Purpose

2.1 This Bulletin outlines the requirements of MARPOL Annex VI, and specifically Chapter 3 requirements for control of emissions and Chapter 4 requirements to reduce the carbon intensity for Barbadian vessels.

2.2 MARPOL Annex VI sets limits on vessel sulphur oxide (SOX) and nitrogen oxide (NOX) emissions. It regulates the deliberate emissions of ozone-depleting substances (ODS), the emissions of volatile organic compounds (VOCs) from tankers, and the incineration of certain products on board vessels. It also establishes fuel oil quality standards.

3. Application

3.1 The MARPOL Annex VI Chapter 3 requirements apply to all Barbadian vessels, regardless of tonnage, except where expressly provided otherwise.

3.2 The MARPOL Annex VI Chapter 4 requirements apply to Barbadian vessels of 400 gross tonnage (GT) and above, except where expressly provided otherwise as detailed in the relevant sections below.

3.3 The MARPOL Annex VI Chapter 4 requirements do not apply to vessels not propelled by mechanical means, platforms including Floating Production, Storage and Offloading Facilities (FPSOs) and Floating Storage Units (FSUs), and drilling rigs regardless of their propulsion and vessels operating in Barbados national waters.

4. Definitions

4.1 For the purposes of the MARPOL Annex VI Chapter 4, the definition of “New ship”, Major conversion MARPOL Annex VI Reg. 2, as per MEPC.1/Circ.795/Rev.2 defines the following terms:

.1 “New ship” means a vessel:

          i) for which the building contract is placed on or after 01 January 2013; or
          ii) in the absence of a building contract, the keel of which is laid, or which is at  a similar stage of construction on or after 01 July 2013; or
          iii) the delivery of which is on or after 01 July 2015.

.2 “Major Conversion” means a conversion of a vessel:

          i) which substantially alters the dimensions, carrying capacity, or engine power of the vessel; or
          ii) which changes the type of the vessel; or
          iii) the intent of which in the opinion of the Administration is substantially to prolong the life of the vessel; or
          iv) which otherwise so alters the vessel that, if it were a new ship, it would become subject to relevant provisions of the present Convention not applicable to                   it as an existing vessel; or
          v) which substantially alters the energy efficiency of the vessel and includes any modifications that could cause the vessel to exceed the applicable required Energy Efficiency Design Index (EEDI) as set out in MARPOL Annex VI Reg.21.

.3 A vessel delivered on or after 01 September 2019 means a vessel:
          i) for which the building contract is placed on or after 01 September 2015; or
          ii) in the absence of a building contract, the keel of which is laid, or which is at a similar stage of construction on or after 01 March 2016; or
          iii) the delivery of which is on or after 01 September 2019.

4.2 For the purposes of MARPOL Annex VI Chapter 4, the categories defined in MARPOL Annex VI Reg.: 2.2.5 Bulk carrier; 2.2.7 Combination carrier; 2.2.9 Container ship; 2.2.11 Cruise passenger ship; 2.2.14 Gas carrier; 2.2.15 General cargo ship; 2.2.16 LNG carrier; 2.2.20 Passenger ship; 2.2.22 Refrigerated cargo carrier; 2.2.26 Ro-Ro cargo ship; 2.2.27 Ro-Ro cargo ship (vehicle carrier); 2.2.28 Ro-Ro passenger ship; 2.2.29 Tanker.

5. Exceptions and Exemptions (MARPOL VI Reg.3)

5.1 MARPOL Annex VI regulations do not apply to emissions necessary for securing the safety of the vessel, saving life at sea, or those resulting from accidents and damage suffered to the vessel or its equipment:

.1 provided that all reasonable precautions have been taken after the occurrence of the damage or discovery of the emission for the purpose of preventing or minimizing the emission; and

.2 except if the Owner or the Master acted either with intent to cause damage, or recklessly and with knowledge that damage would probably result.

5.2 The requirements of MARPOL Annex VI Reg. 18 on fuel oil availability and quality shall not apply to the use of hydrocarbons that are produced and subsequently used on site as fuel and this exemption shall be annotated on the International Air Pollution Prevention Certificate (IAPPC).

5.3 The BMSR may exempt unmanned non-self-propelled (UNSP) barges from the survey and certification requirements of MARPOL Annex VI by means of an International Air Pollution Prevention Exemption Certificate for Unmanned Non-self-propelled (UNSP) Barges for a period not exceeding five years as per MEPC.1/Circ.892.

6. Equivalents (MARPOL VI Reg. 4)

6.1 Requests for equivalencies or alternative arrangements must be submitted to the BMSR at Ops@barbadosmarime.com. As per Bulletin 008, they must include a recommendation from the Recognised Organisation (RO) confirming that the alternative arrangement is at least as effective in terms of emissions reductions as required MARPOL Annex VI.

6.2 Upon satisfactory review of the application, the BMSR will notify the International Maritime Organization (IMO) of the acceptance of the equivalent/alternative compliance by making an entry in the IMO Global Integrated Shipping Information System (GISIS).

7. Surveys and Certification (MARPOL VI Reg. 5 to 9)

7.1 Barbadian vessels of 400 GT and above, engaged on international voyages, and every fixed and floating drilling rig or other platform shall be surveyed and certificated for compliance with the requirements of MARPOL Annex VI Reg. 5.1 and be issued with an IAPPC.

7.2 As per MARPOL Annex VI Reg. 13.1.1, each marine diesel engine with a power output over 130 kilowatt (kW) that is installed (or undergoes major conversion) on a vessel, irrespective of tonnage, must be surveyed and certified in accordance with the NTC 2008.

7.3 Barbadian vessels of 400 gross tonnage and above, to which MARPOL Annex VI Chapter 4 applies, shall undergo surveys in accordance with MARPOL Annex VI Reg. 5.1 and be issued with an International Energy Efficiency Certificate (IEEC).

7.4 Barbadian vessels which are not required to keep a Ship Energy Efficiency Management Plan (SEEMP) do not require an IEEC.

7.5 The ship type on the IEEC shall refer to the ship type in accordance with definitions specified in MARPOL Annex VI Reg. 2.2. which are indicated in Sec. 4.2 above.

7.6 If the vessel does not fall into the ship types defined in Sec. 4.2 above, in the IEEC the ship type shall be entered as “Ship other than ship types defined in in MARPOL Annex VI Reg. 2.2″ and “the type of ship is exempt in accordance with MARPOL Annex VI Reg. 22.1/23.1/24.1/25.1” as applicable, shall be ticked in the IEEC relevant section.

7.7 If needed, the BMSR can issue a waiver letter as confirmation by this flag Administration of the ship type and to address Sec. 7.6 above.

7.8 The BMSR considers that the ship type stated on the IEEC should usually replicate the ship type designated at the stage of design and construction on which the Certificate of Class and Statutory Certificates of the vessel are based and with the ship type of the Barbados Certificate of Registry (COR).

7.9 In situations where, owing to operational necessity, an existing vessel may be required to change the ship type on the IEEC, the BMSR will consider such requests, where supported by the RO that issues the IAPPC of the vessel, provided that the ship type on the Certificate of Class, Statutory Certificates and COR of the vessel are amended accordingly.

7.10 The Owners of a vessel certificated to the ISM Code should be aware that where a change of ship type is requested, the vessel’s Safety Management Certificate (SMC) and the Company Document of Compliance (DOC), including associated safety management documents and procedures, may require to be amended.

8. MARPOL VI – RO’s Degree of Authorisation

8.1 The BMSR has authorised all Barbados ROs to:

.1 Issue or endorse an IAPPC;

.2 Issue or endorse an Engine International Air Pollution Prevention (EIAPP) certificate;

.3 Verify VOC management plans (Sec. 12.2 below);

.4 Carry-out Type Approval of shipboard incinerators (Sec. 13 below);

.5 Approve SOX Emissions Compliance Plans and issue a SOx Emission Compliance Certificate to vessels which use an Exhaust Gas Cleaning Systems (EGCSs) as an approved equivalent;

.6 Verify attained EEDI values calculated for each vessel (Sec. 14 below);

.7 Verify attained EEXI values calculated for each vessel (Sec. 16 below);

.8 Issue an IEEC after completion of the relevant surveys referred to in Sec. 7 above. The IEEC is to remain valid for the life of the vessel, except for the cases specified under MARPOL Annex VI Reg. 9.11 (vessel withdrawn from service, major conversion, or upon transfer of the vessel to the flag of another State).

.9 Verify the Ship Energy Efficiency Management Plan (SEEMP) Part II (Ship Fuel Oil Consumption Data Collection Plan) and issue Confirmation of Compliance (Sec.17.6 below );

.10 Verify Ship Fuel Oil Consumption Data Collection from each vessel operator, per vessel and issue an Annual Statement of Compliance (SoC) (Sec. 18 below);

.11 Submit data to the IMO Ship Fuel Oil Consumption Database.

9. Ozone-Depleting Substances (MARPOL VI Reg. 12)

9.1 Deliberate emissions of ozone-depleting substances (ODS) are prohibited and all vessels with installations containing ODS must comply with MARPOL Annex VI Reg. 12, except for permanently sealed equipment where there are no refrigerant charging connections or potentially removable components that contain ODS.

9.2 The ODS Record Book is required for the vessel of 400 GT and above, and drill rigs and platforms regardless of tonnage, which have rechargeable systems containing ozone-depleting substances. The BMRS ODS Record Book can be ordered on Shipboard Document Online Form.

10. Nitrogen Oxide (NOX) Emissions (MARPOL VI Reg. 13)

10.1 It is prohibited to operate a marine diesel engine with a power output of more than 130 kW, and which is installed, or undergoes a major conversion on or after 01 January 2000, unless it complies with the applicable NOX emission limits and requirements specified in MARPOL Annex VI Reg. 13, which applies to any vessels (including yachts and fishing vessels) irrespective of tonnage.

10.2 Marine diesel engines installed on a vessel must comply, based on the date of vessel construction, with the NOx Tier III emission standards when the vessel is operating in an Emission Control Area (ECA) as specified in MARPOL Annex VI Reg. 13.5.1.2.

10.3 Emergency diesel engines and engines installed in lifeboats, devices, or equipment intended to be used solely for emergencies are exempted from the MARPOL Annex VI Reg. 13 requirements.

10.4 Emissions from fixed or floating platforms and drilling rig engines that are solely dedicated to the exploration, exploitation and associated offshore processing of seabed mineral resources are exempted from the regulations regarding NOx controls. However, any emissions from engines that jointly supply power to exploration and processing machinery and also the platform domestic load are NOT exempted.

10.5 Each engine on board a Barbados vessel subject to MARPOL Annex VI is required to have an associated Engine Technical File. The Technical file shall remain on board the vessel for as long as the engine remains on board and shall be available for inspection by duly authorised officers.

10.6 The Technical File shall include an on-board NOx verification procedure, the parent engine’s emission test report and the Engine International Air Pollution Prevention Certificate (EIAPPC).

10.7 Boilers and gas turbines are not covered under the NOx controls regulations.

11. Sulphur Oxides (SOX) and particulate matter (MARPOL VI Reg. 14)

11.1 The carriage of fuel oil for use on board the vessel with a sulphur content exceeding 0.50% m/m is prohibited under MARPOL Annex VI Reg. 14.1. This prohibition does not apply to non-compliant fuel oil carried for use onboard a vessel with an approved EGCS installed as an alternative means of compliance and to fuel oil carried on board as a cargo.

11.2 The global sulphur limit is a mandatory requirement and is applicable to all vessels on all voyages, covering all fuel carried on board for consumption – this includes fuel oil used in emergency systems (emergency generator, lifeboats, rescue boat, etc.), and concerns about the safety of the vessel and machinery do not exempt the vessel from the requirement to bunker and/or consume compliant fuel oil.

11.3 In ports where the discharge of wash water from open loop EGCS (scrubbers) is not permitted, vessels fitted with open loop/hybrid EGCS may be expected to consume compliant fuel oil or to switch to closed loop mode. Documents related to changeover procedure and records should be kept on board.

11.4 IMO Resolution MEPC.340(77) requires the EGCS Technical Manual (ETM) and Onboard Monitoring Manual (OMM) to be approved by the RO on behalf of Barbados.

11.5 While a vessel is operating within an Sulphur Emission Control Area (SECA) as defined under MARPOL Annex VI Reg. 14.3, the sulphur content of fuel oil used on board that vessel shall not exceed 0.10% m/m as per MARPOL Annex VI Reg. 14.4.

11.6 Vessels using separate fuel oils when operating within a SECA must carry a written fuel oil changeover procedure, developed specifically for the vessel. A record of the changeover operation shall be recorded in the MARPOL Annex VI Record Book.

11.7 The BMSR MARPOL Annex VI Record Book can be ordered on Shipboard Document Online Form.

12. Volatile Organic Compounds (MARPOL VI Reg. 15)

12.1 Tankers subject to vapour emissions control must be fitted with a vapour collection system approved by an RO on behalf of Barbados, within three years after a port/terminal has notified the IMO of its regulation of tanker VOC emissions. See GISIS module for ports or terminals where VOCs are controlled.

12.2 The VOC management plan, required for all tankers carrying crude oil, must be approved by an RO on behalf of Barbados.

12.3 Gas carriers must comply with the requirements of this section only if their loading and containment systems allow safe retention of non-methane VOCs on board, or their safe return ashore.

13. Shipboard Incineration (MARPOL VI Reg. 16)

13.1 All vessels, irrespective of tonnage, must comply with the regulations on shipboard incineration under MARPOL Annex VI Reg. 16. Special rules on incineration under domestic law may apply in some ports and may exist in some special areas. Operation of shipboard incinerators may require permission from individual coastal or port authorities concerned.

13.2 Incinerators installed in accordance with the requirements of MARPOL Annex VI Reg. 16 shall be provided with a manufacturer’s operating manual and personnel responsible for the operation of an incinerator shall be trained to implement the guidance provided in the manufacturer’s operating manual.

13.3 An incinerator on a vessel constructed on or after 01 January 2000, or installed on or after 01 January 2000 must be approved by an RO on behalf of Barbados, taking into account the standard specification for shipboard incinerators as per MARPOL Annex VI Reg. 16.3 and 16.6.1.

14. Fuel Oil Quality – BDN and FONAR (MARPOL VI Reg. 18)

14.1 For every vessel of 400 GT and above, details of fuel delivered for combustion purposes must be documented by means of a Bunker Delivery Note (BDN) in the format specified under Appendix V of MARPOL Annex VI.

14.2 BDNs shall be kept on board for at least 3 years after the delivery of the fuel oil and shall be accompanied by a representative sample (“MARPOL delivered sample”) which is to be sealed and signed by the Master or officer in charge of the bunker operations and retained under the vessel’s control until the fuel oil is substantially consumed, but in any case, not less than 12 months from the time of delivery. Representative samples of fuel already consumed may be retained in an appropriate shore side facility under control of the Company.

14.3 Coastal and port State authorities of a Party to MARPOL Annex VI, as appropriate, may utilise the sampling point(s) which is(are) fitted or designated for the purpose of taking representative sample(s) of the fuel oil being used on board as outlined in IMO Circulars MEPC.1/Circ.864/Rev.1, MEPC.1/Circ.889 and Resolution MEPC.324(75). The competent authority shall take fuel oil samples as expeditiously as possible without causing the vessel undue delays, and the sample must be sealed by the representative of the competent authority in the presence of the vessel’s representative and the vessel shall retain a duplicate sample.

14.4 For every vessel of 400 GT and above on scheduled services with frequent and regular port calls which would render compliance with the requirements of this section impracticable, an alternative documentation and sampling storage plan may be approved by the BMSR, after consideration of the circumstances involved and consultation with the affected States concerned.

14.5 Where, despite all reasonable efforts, compliant fuel oil is not received at the scheduled port of call, and no feasible alternative exists, the vessel will be required to prepare and submit a Fuel Oil Non-Availability Report (FONAR) as per Sec. 5 of Resolution MEPC.320(74), which shall be submitted to both the BMSR and the Coastal State authorities of the port(s) of destination.

14.6 When a vessel has presented evidence of the non-availability of compliant fuel oil, the BMSR will subsequently notify the IMO through “MARPOL Annex VI” GISIS module. The following information shall be provided to the BMSR:

.1 a record of actions taken to attempt to achieve compliance;

.2 copies of Bunker Delivery Note(s);

.3 post-bunkering laboratory analysis of drip samples taken to determine the percent concentration of sulphur found within the stemmed fuel oil; and

.4 evidence that the vessel attempted to purchase compliant fuel oil in accordance with its voyage plan and, if it was not made available where planned, that attempts were made to locate alternative sources for such fuel oil and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase.

14.7 Providing the information above does not indemnify the vessel from Port State Control (PSC) action in the event compliant fuel oil could not be obtained. The relevant authorities of a Party to MARPOL Annex VI will consider all relevant circumstances in addition to the evidence provided when determining the appropriate action to take based on the guidance for Port State Control on how to address the provision of non-compliant fuel oil , as per IMO Circular MEPC.1/Circ.881.

14.8 Follow-up actions may be considered when arranging the supply of compliant fuel oil following bunkering of non-compliant fuel oil under a FONAR:

.1 De-bunker any remaining non-compliant fuel oil at the first port where compliant fuel is available; and

.2 Specific preparations to ensure bunker tanks and fuel transfer, treatment and preparation systems are sufficiently cleaned and are suitable for compliant fuel oil without the risk of contamination by residues of non-compliant fuel oil. Such actions may include tank cleaning, system pipelines and equipment flushing or mechanical cleaning.

15. Attained EEDI and Required EEDI (MARPOL VI Reg. 22 and 24)

15.1 Energy Efficiency Design Index (EEDI) represents the equivalent amount of carbon dioxide that a vessel as a whole emits, in relation to the amount of cargo carried per mile sailed.

15.2 The attained EEDI is defined under MARPOL Annex VI Reg. 2.2.3 as the EEDI value achieved by an individual vessel in accordance with MARPOL Annex VI Reg. 22. The attained EEDI should be lower than the required EEDI prescribed in MARPOL Annex VI Reg. 24, which is the maximum value of attained EEDI allowed for the specific vessel type and size.

15.3 The attained EEDI and required EEDI are applicable for a “new ship” as defined in Sec. 4.1.1 above or an existing one which has undergone a major conversion so extensive that it is regarded as newly constructed, which falls into one or more of the categories defined in Sec. 4.2 above.

15.4 The attained EEDI shall be calculated taking into account Resolution MEPC.364(79) and verified by a Barbados RO. The attained EEDI shall be specific to each vessel and shall indicate the estimated performance of the vessel in terms of energy efficiency and be accompanied by the EEDI Technical File that contains the information necessary for the calculation of the attained EEDI and shows the process of calculation. When a vessel may be identified as falling under more than one category listed above, the more stringent criteria in calculations shall apply.

15.5 Starting from 01 April 2022 for all vessels to which requirements of MARPOL Annex VI Reg. 22and 24 apply, the attained EEDI and required EEDI shall be reported to the IMO as follows:

.1 For vessels constructed on or after 1 April 2022 within 7 months from the date if the IEEC Initial Survey; or

.2 for vessels constructed prior to 1 April 2022 by 1 November 2022.

16. Attained EEXI and Required EEXI (MARPOL VI Reg. 23 and 25)

16.1 Energy Efficiency Existing Ship Index (EEXI) is a measure of a vessel’s energy efficiency, expressed in grams of carbon dioxide per amount of cargo carried per mile sailed.

16.2 The attained EEXI shall be calculated as per MARPOL Annex VI Reg. 23. taking into account Resolution MEPC.333(76) and verified by a Barbados RO. The Required EEXI is the maximum value of attained EEXI allowed for the specific vessel type and size and is calculated as per MARPOL Annex VI Reg. 25.

16.3 The attained EEXI and required EEXI are applicable for each existing vessel and each vessel which has undergone a conversion, which fall into one or more of the categories defined in Sec. 4.2 above.

16.4 Where a vessel may be identified as falling under more than one category listed above, the more stringent criteria in calculations shall apply. The process of calculation and the necessary information to produce the EEXI calculation shall be addressed in the vessel specific EEXI Technical File.

16.5 Notwithstanding Sec. 16.2, for each vessel to which MARPOL Annex VI Reg.22 applies, the attained EEDI may be taken as the attained EEXI if the value of the attained EEDI is equal to or less than that of the required EEXI as required by MARPOL Annex VI Reg. 25. In this case, the attained EEXI shall be verified based on the EEDI Technical File and the provisions contained within the EEDI Technical File may be used in place of an EEXI Technical File.

16.6 The EEXI Technical File shall be reviewed and accepted by the Verifier. The Verifier may issue a statement affirming the completion of an EEXI Technical File review; however, such a statement does not form part of the survey requirements of MARPOL Annex VI Reg. 22.

17. Shaft / Engine Power Limitation Systems and use of Reserve of Power
17.1 As per Resolution MEPC.335(76) the following definitions are to be used:

.1 Shaft power means the mechanical power transmitted by the propeller shaft to the propeller hub. It is the product of the shaft torque and the shaft rotational speed. In case of multiple propeller shafts, the shaft power means the sum of the power transmitted to all propeller shafts.

.2 Engine power means the mechanical power transmitted from the engine to the propeller shaft. In case of multiple engines, the engine power means the sum of the power transmitted from the engines to the propeller shafts.

.3 Overridable Shaft Power Limitation (SHaPoLi) system means a verified and approved system for the limitation of the maximum shaft power by technical means that can only be overridden by the vessel’s Master or the officer in charge of navigational watch (OICNW) for the purpose of securing the safety of a vessel or saving life at sea.

.4 Overridable Engine Power Limitation (EPL) system means a verified and approved system for the limitation of the maximum engine power by technical means that can only be overridden by the vessel’s Master or OICNW for the purpose of securing the safety of a ship or saving life at sea.

.5 Power reserve means shaft/engine power above the limited power which cannot be used in normal operation unless in the case when SHaPoLi/EPL is unlimited for the purpose of securing the vessel safety.

17.2 Any SHaPoLi and EPL system installation on board of Barbadian vessels shall be approved and verified by a Barbadian RO for compliance with Resolution MEPC.335(76).

17.3 The SHaPoLi/EPL system shall be accompanied by the Onboard Management Manual (OMM) for SHaPoLi/EPL, which shall be verified by a Barbadian RO after a survey verifying the vessel’s attained EEXI and shall be permanently on board the vessel for inspection.

17.4 The use of a power reserve is only allowed for the purpose of securing the safety of a vessel or saving life at sea, consistent with MARPOL Annex VI Reg. 3.1 such as: operating in adverse weather and ice-infested waters, participation in search and rescue operations, avoidance of pirates and engine maintenance.

17.5 As per Resolution MEPC.335(76) the use of power reserve (override) shall be allowed only for the following cases:
.1 operating in adverse weather;
.2 operating in ice-infested waters;
.3 participation in search and rescue operations;
.4 avoidance of pirates;
.5 engine maintenance;
.6 description of other reasons consistent with MARPOL Annex VI Reg. 3.1.
17.6 The use of power reserve for engine maintenance as Sec. 17.5.5 above, depends on the engine type and auxiliary systems. Hence, if the maintenance, as per manufacturer’s specifications, cannot be done with normal power, the use of a power reserve can be considered for engine maintenance for any applicable regular and irregular maintenance by the RO when approving the OMM.

17.7 The RO, in this case, approves the use of a power reserve for regular maintenance only after assessment of the manufacturer’s specifications as per above. In this case, the authority for this should be clearly set out in the OMM and/or the SMS manual, as appropriate.

17.8 Any use of a power reserve should be recorded in the record page of the OMM for SHaPoLi/EPL, signed by the Master and should be kept on board and in the format as per appendix of Resolution MEPC.375(80).

17.9 Where an EPL/ SHaPoLi override is activated but the power reserve is not subsequently used, this event should be recorded in the bridge and engine-room logbooks. The engine-room logbook should record power used during the period when the override was activated. The EPL/SHaPoLi should be reset as soon as possible, and details of the reset should also be recorded in the bridge and engine-room logbooks.

17.10 In case of having used a power reserve, the vessel shall without delay (within 24 hours) notify the RO responsible for issuing the relevant certificate and the competent authority of the relevant port of destination with the information recorded as per Sec. 17.8 above. The notification need not be done to the BMSR.

17.11 On an annual basis by 30 June every year, the RO responsible for issuing the relevant certificate shall report to the IMO Secretariat uses of a power reserve over a 12 month period from 1 January to 31 December for the preceding calendar year with the information recorded in accordance with Sec. 17.8 above.

17.12 Once the risks have been mitigated, the vessel shall be operated below the certified level of engine power under the SHaPoLi/EPL.

17.13 The SHaPoLi/EPL system should be reactivated or replaced by the crew immediately after the risks have been prevented and the ship can be safely operated with the limited shaft/engine power. The reactivation or replacement of the SHaPoLi/EPL system should be confirmed (e.g. validation of mechanical sealing) with supporting evidence (e.g. engine power log, photo taken at the occasion of resetting the mechanical sealing) by the RO at the earliest opportunity.

17.14 The type of evidence and the timing of submission shall be stated in the OMM and SMS manual. The submission is to be at the earliest opportunity, hence as soon as the use of power reserve and within 24 hours.

17.15 Supporting evidence includes engine power log, photo taken at the occasion of resetting the mechanical sealing and these can be verified remotely by the RO. The BMSR does not request an additional survey for reactivation of the SHaPoLi/EPL after engine maintenance.

17.16 The RO shall carry out an additional survey in case of replacement of the SHaPoLi/EPL systems and any alteration in the systems.

18. Ship Energy Efficiency Management Plan (SEEMP) (MARPOL VI Reg. 26)

18.1 Every vessel of 400 GT and above shall keep on board a ship specific Ship Energy Efficiency Management Plan (SEEMP). This may form part of the ship’s Safety Management System (SMS). The SEEMP shall be developed and reviewed, taking into account Resolution MEPC.346(78).

18.2 The SEEMP shall be provided on board before issuance of the IEEC.

18.3 There are three parts to a SEEMP:
.1 SEEMP Part I. The purpose of this part is to provide an approach to monitor vessel and fleet efficiency performance over time and describe ways to improve the vessel’s energy efficiency performance and carbon intensity. Part I of the SEEMP applies to any vessel of 400 GT and above;
.2 SEEMP Part II. The purpose of this part is to provide a description of the methodologies that should be used to collect the Ship Fuel Oil Consumption Data required pursuant to MARPOL Annex VI Reg. 27 and the processes that the vessel should use to report the data to the Barbados RO. Part II of the SEEMP applies to any vessel of 5,000 GT and above.
.3 SEEMP Part III. The purpose of this part is to provide:
i) A description of the methodology that should be used to calculate the vessel’s attained annual operational Carbon Intensity Indicator (CII) required by MARPOL Annex VI Reg. 28 (Sec. 19 below);
ii) The processes that should be used to report this value to the Barbados RO;
iii) The required annual operational CII for the next three years;
iv) An implementation plan documenting how the required annual operational CII should be achieved during the next three years;
v) A procedure for self-evaluation and improvement; and
vi) For vessels rated as D for three consecutive years or rated as E, a plan of corrective actions to achieve the required annual operational CII.

18.4 Part III of the SEEMP applies to any vessel of 5,000 GT and above which falls into one or more of the categories defined 4.2 above.

18.5 The SEEMP Part I does not require verification or approval by the Administration/RO. This may form part of the vessel’s SMS.

18.6 The SEEMP Part II should be verified by the nominated Reporting Organisation/Verifier, prior to commencement of Ship Fuel Oil Consumption Data reporting. On successful verification of the amended SEEMP, the Reporting Organisation/Verifier is to issue a Confirmation of Compliance as per MEPC.1-Circ.876 to the vessel, in accordance with MARPOL Annex VI Reg.5.4.5.

18.7 Where there is a change of nominated Reporting Organisation/Verifier, the new Reporting Organisation/Verifier shall obtain the SEEMP Part II verified by the previous Recognised Organisation/Verifier and the related Confirmation of Compliance and take those to their files as a basis for later verifications.

18.8 The SEEMP Parts I & II & III and Confirmation of Compliance shall be kept on board.

18.9 The SEEMP Part III amendments shall be verified and confirmed acceptable to the Reporting Organisation/Verifier.

19. Collection and Reporting of Ship Fuel Oil Consumption Data (MARPOL VI Reg. 27)

19.1 The Company shall ensure that fuel consumption data and the attained annual operational CII index for the previous year for vessels to which MARPOL Annex VI Reg. 27 and 28 apply is submitted to the Reporting Organisation/Verifier by not later than 31 March. The Statement of Compliance required by MARPOL Annex VI Reg. 6.4 is to be issued by the Reporting Organisation/Verifier by 31 May each year.

19.2 Verified fuel consumption and attained annual operational CII index data is to be uploaded to the IMO Global Integrated Shipping Information System (GISIS) by the Reporting Organisation/Verifier within 1 month after issuing the Statement of Compliance but not later than 30 June each year.

19.3 When preparing the annual fuel consumption reports for their fleet, the Company should be aware that submission is also required for a part of a year if a vessel has left or been accepted to their management, joined, or left the Barbados flag, or has been recycled before 31 December. The reporting of the fuel consumption data is required on the day of completion of the transfer from one flag to another or of the change from one Company to another, or as close thereto as practical.

19.4 Notwithstanding 18.3, where a vessel changes flag to the Barbados at any time after 01 January the attained annual operational CII index shall be reported to the Reporting Organisation/Verifier for the entire 12 months period by 31 March the next year. As of the date of issue of this Notice, the IMO is yet to develop the detailed guidance on the end of year reporting where only partial fuel consumption information is available.

19.5 Recognising that on occasions timely submission or review of aggregated and verified data cannot be completed, the BMSR exercises a pragmatic approach in allowing the Reporting Organisation/Verifier additional time to complete the submission and issue a Statement of Compliance.

19.6 A request for a permit, as per Bulletin 008, for a conditionally issued short term IEEC should be submitted via the RO or Company for every vessel where any of the limit date(s) in Sec. 18.1 cannot be met.

19.7 In accordance with Appendix IX of MARPOL Annex VI, the following information is to be included in the annual cumulative fuel consumption data report:

.1 Identity of the vessel: IMO number, ship type, gross tonnage, net tonnage, deadweight, rated power of each main and/or auxiliary reciprocating internal combustion engine over 130 kW, Attained EEDI (where applicable), Ice Class;
.2 Every type of fuel oil consumed on board for any purpose (engines, boilers, incinerator, inert gas generators, heaters etc.), in metric tonnes. This requirement also applies to ships consuming boil-off gas (BOG) for the purpose of propulsion or shipboard operational needs ;
.3 distance travelled over ground;
.4 hours underway;
.5 information on the method used to collect fuel consumption data as required by MARPOL Annex VI Reg. 22A.

——————-

[1] The quantity of consumed BOG should be reported in metric tonnes in reference to the original quantity of liquified gas

——————-

19.8 Reporting of direct CO2 emission measurements is not mandatory. This method may however be utilised concurrently where the necessary equipment is installed on board to supplement the fuel consumption data report.

19.9 When the Reporting Organisation/Verifier has received fuel consumption data from a ship and verified that it has been collected and reported correctly per Resolution MEPC.348(78), a Statement of Compliance shall be issued to the vessel confirming the submission of the data required for the period. The format of the Statement of Compliance can be found in Appendix X of MARPOL Annex VI.

19.10 Each Statement of Compliance will remain valid for the duration of the calendar year when it was issued and for the first five months of the next calendar year.

19.11 Expired Statements of Compliance are not required to be retained beyond their expiration date, once a new statement has been issued and delivered on board.

19.12 In situations where a vessel is not in a position to obtain a new Statement of Compliance following the end of a calendar year due to lay-up, conversion of period of inactivity, the last issued Statement of Compliance shall be retained on board for inspection.

20. Operational Carbon Intensity (MARPOL VI Reg. 28)

20.1 Starting from 01 January 2024, each vessel of 5,000 GT and above which falls into one or more of the categories specified in Sec. 4.2 above shall calculate the attained annual operational Carbon Intensity Indicator (CII) over a 12-month period from 1 January to 31 December for the preceding calendar year, using the data collected in accordance with MARPOL Annex VI Reg. 27.

20.2 The attained annual operational CII for the preceding year shall be reported by the Reporting Organisation/Verifier by 01 April each year.

20.3 Notwithstanding the above, in the event of a change of flag of a ship completed after 1 January 2023, the vessel shall, after the end of the calendar year in which the transfer takes place, calculate and report the attained annual operational CII for the full 12- month period from 1 January to 31 December in the calendar year during which the transfer took place, for verification by the RO.

20.4 The attained annual operational CII shall be verified by the Reporting Organisation/Verifier against the required annual operational CII to determine an operational carbon intensity rating of A, B, C, D or E, indicating the ship’s preceding year performance level, as outlined in MARPOL Annex VI Reg. 28.6.

20.5 A ship rated as D for three consecutive years, or when rated as E, shall develop a plan of corrective actions to achieve the required annual operational CII.

20.6 The SEEMP shall be reviewed to include the above plan of corrective actions accordingly. The revised SEEMP shall be submitted to the Reporting Organisation/Verifier for verification, not later than 1 month after reporting the attained annual operational CII. Implementation of corrective actions shall commence immediately following the verification by the Reporting Organisation/Verifier.

21. EU/UK MRV Reporting

21.1 The EU requires the monitoring, reporting and verification (MRV) of carbon dioxide emissions from maritime transport as applicable, for vessels above 5,000 GT on EU related voyages and to be in compliance with Regulation (EU) 2015/757.

21.2 As a result of the United Kingdom leaving the EU, the EU MRV no longer applies to the UK. However, the UK has adopted with SI 2018/1388 UK MRV regulations, based on the EU MRV, which are applicable for vessels above 5,000 GT trading in or out of any UK ports and reporting shall be done as per UK Marine Information Notice MIN 669 (M+F).

21.3 The EU and UK MRV are in addition to the provisions of MARPOL Annex VI.

21.4 It is anticipated that the EU/UK MRV and MARPOL Annex VI fuel consumption data submission requirements will eventually be aligned to reduce administrative burden, as some vessels will need to report the same data twice. However, so far there are no firm indications of the timescale for alignment of the EU/UK MRV and MARPOL Annex VI requirements.

21.5 Fuel consumption data for voyages between ports in the UK, whilst at berth in any UK ports, between ports in the UK and non-EEA ports and vice-versa shall be included in UK MRV reporting.

21.6 To avoid duplication, fuel consumption data covering voyages between the UK and EEA ports and vice versa shall not be reportable under the UK MRV regulations and shall continue to be submitted as part of EU MRV data.

21.7 Where a Barbados RO acts as a Reporting Organisation/Verifier (DCS) and has been accredited as an MRV verifier, the BMSR has no objection to fuel consumption data and MRV reporting being combined, provided that the combined reports provide all of the information required by MARPOL Annex VI Reg. 22A.

21.8 A Document of Compliance covering the EU/UK MRV fuel consumption data submission shall be provided on board every applicable vessel.

 

Revision No

Description Of Revision

1.0

First Issue -superseded Information Bulletins 298/281/302/316/345

1.1

Amended reference 1.v and added references 1.w and 1.x; Amended sec. 8.10 and 8.11 headings; added whole new section 17.

 

 

 

 

 

 

 

 

 

 

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Bulletin 051 – Laid up Vessel Requirements

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

 

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) IACS PR 1C “Procedure for Suspension and Reinstatement or Withdrawal of Class in Case of Surveys, Conditions of Class or Recommendations Going Overdue”.
c) International Safety Management Code (ISM Code).
d) International Ship and Port Facility Security Code (ISPS Code).
e) Maritime Labour Convention, 2006.
f) Form 12 – Minimum Safe Manning Document Application.
g) Checklist 02 – Ship Registration.

2. Purpose

2.1 This Bulletin describes the requirements for lay-up of Barbadian vessels.

3. Application

3.1 This Bulletin applies to all vessels that are to be laid up temporarily and not in commercial operations for any reason.

4. General

4.1 The term laid up vessel refers to a vessel that is temporarily idle due to lack of cargo, or which are temporarily phased out of commercial operations.
4.2 There are two different ways to lay up vessels: “Hot lay-up” and “Cold lay-up”.
4.3 During “hot lay-up“ the vessel is idle but can be brought back into service at short notice. The machinery is kept in operation for the sake of fast re-commissioning, but measures may be taken to reduce various operational costs. Vessels should normally be laid-up without cargo. Adequate manning for the safe operation of the machinery should be kept.
4.4 During “Cold lay-up“ the vessel is taken out of service due to lack of employment and is moored or anchored at a safe place waiting for new employment. The machinery is taken out of service and the vessel is kept “electrically dead” with the exception of emergency power. Minimum manning covering fire, leakage, moorings and security watches should be kept. Power will be kept to minimum level to ensure emergency equipment and operation of windlass and mooring winch are operational.
4.5 Without a notification of lay-up, vessels are implied to be trading normally and maintaining a full regime of certification, surveys, and inspections, including normal manning for such operations. Therefore, Managers shall advise the BMSR when a vessel is in lay-up.
4.6 The BMSR only requires notification of the vessel being laid up. Failure to notify the BMSR and the relevant Recognised Organisation(s) (ROs) of the vessel entering lay-up and failure to maintain a safe lay-up, will be regarded as a Majon Non-Conformity (MNC) and might result in the vessel being deleted from the registry.
4.7 The Managers are to advise the BMSR of the proposed length of the lay-up and the state of readiness of the vessel to resume trade. The Company should take appropriate advice on lay-up procedures as necessary, including that of the ROs, insurers, and local authorities etc.

5. Statutory and Class Certification

5.1 Statutory certification is normally only required when vessels are trading, while class is to be maintained at all times, as a requirement for continuous registration.
5.2 However, Classification Societies have procedures for laying up vessels and class suspension, which are based on the IACS PR 1C.
5.3 Depending upon the proposed length of the lay-up and taking into account any requirements of the port or coastal State of the lay-up location, the Managers should consider whether to maintain or suspend the statutory and Class certification.
5.4 Any statutory and Class certificates, for which the periodical survey/audit/inspection window has expired during lay-up, is to be considered invalid.
5.5 The Managers and/or ROs shall notify BMSR of suspension or cancellation of class certificates after a decision has been taken by the RO on such suspension or withdrawal.

6. Suspending and Reinstating the Vessel during Lay-up

6.1 If any statutory and class certification are suspended as per above, then the vessel is also suspended from the registry.
6.2 During suspension, all flag certificates and permits issued by the BMSR will be automatically withdrawn and voided and the vessel is prohibited from proceeding to sea.
6.3 When a vessel is suspended from the registry due to lay up, the BMSR will issue the relevant suspension certificate and, for vessel which are required to hold a Continuous Synopsis Record (CSR), the BMSR will issue a CSR with laid up status where the date of entering laying up will be used a date of ceased registration with the BMSR.
6.4 At the end of the lay-up, recommissioning is generally a matter for the Company and the Recognised Organisation to consider. While recommissioning the vessel, the manning must be kept under review, taking into account the reactivation of machinery and equipment and the associated hazards, including potential fire risk.
6.5 All previously cancelled, suspended, or outdated certificates, audits and inspections are to be revalidated and the manning restored to that required by the Minimum SMD before the vessel sails from her port of lay-up.
6.6 The BMSR will re-issue all flag certificates upon submission of all relevant documents and statutory certificates, as applicable, listed in Checklist 02.

7. Safety Management Certificates (SMC)

7.1 If the care of a vessel during lay-up is handed over to an organisation which is not the ISM Manager (e.g. dedicated lay-up providers), the BMSR will accept the suspension of the ISM Code certification of the vessel provided that the company provides evidence that:
.1 all requirements of the coastal State are met;
.2 all requirements of the RO are met; and
.3 the contact details of the organisation that holds responsibility for the safety of the vessel during lay-up.
7.2 if the vessel has been laid up more than 6 months, the SMC becomes invalid and an interim verification audit will be required upon re-commissioning, with the vessel being treated as a new vessel to the company. Upon successful completion of the verification, an interim SMC will be issued.
7.3 If the lay-up period is less than 6 months, but the periodical audit window has expired during lay-up, the SMC will be considered invalid. The vessel will then be required to undergo an interim audit upon recommissioning and an interim SMC will be issued.
7.4 If the vessel has been laid up for less than 6 months and the periodical audit window has not expired, the SMC will still be valid.

8. International Ship Security Certificate (ISSC)

8.1 The continued validity of the vessel’s ISPS Code certification is an important element in the reactivation of the vessel. It is strongly recommended that the ISSC is maintained throughout lay-up and at least the Ship Security Plan (SSP) provisions related to security measures.
8.2 The SSP might need the addition of specific procedures depending upon the extent or “depth” of the lay-up. The Managers are to establish measures within the SSP to address risks associated with security breaches during vessel lay-up periods.
8.3 Where the circumstances described in Sec. 7.1 above, the company must communicate with the Recognised Security Organisation (RSO) to ensure that the SSP Plan covers that operation.
8.4 If the vessel is integrated into the port facility security system, the records of suspension and subsequent reactivation of the ISSC should clearly reflect that, to demonstrate continuity of security.
8.5 If the vessel has been laid up for more than 6 months, the ISSC becomes invalid. An interim verification will be required upon re-commissioning, with the vessel being treated as a new vessel to the company. Re-approval of SSP may be required. Upon successful completion of the verification, an interim ISSC will be issued.
8.6 If the lay-up period is less than 6 months, but the periodical audit window has expired during lay-up, the ISSC will be considered invalid. The vessel will then be required to undergo interim verification upon recommissioning.
8.7 If the vessel has been laid up less than 6 months and the periodical audit window has not expired, the ISSC will still be valid.

9. Maritime Labour Certificate (MLC)

9.1 The Company shall take into account any obligations for medical care and repatriation specified in the CAP 296 or Maritime Labour Convention.
9.2 Any failure to provide a basic level of welfare facilities will be regarded as a failure of the vessel Safety Management System and may lead to further measures by the BMSR, in addition to any action which may be taken by the port or coastal State.
9.3 For ships staying in lay-up more than 6 months, an additional MLC inspection is required on reactivation to confirm continued compliance with DMLC Part II with an additional endorsement.
9.4 If the lay-up period is less than 6 months, but the intermediate inspection window expires during lay-up, the MLC will be considered invalid. The vessel will then be required to undergo interim verification upon recommissioning and an interim MLC will be issued.
9.5 If the vessel has been laid up less than 6 months and the intermediate inspection has not expired the MLC will still be valid.

10. Long Range Identification and Tracking (LRIT)

10.1 Normal procedures for LRIT apply.
10.2 If the LRIT equipment is deactivated or switched off, the BMSR is to be advised so that reporting can be suspended correctly.

11. Insurance

11.1 Relevant hull and machinery underwriter and P&I club should be consulted for guidance prior to removal of the vessel from service.
11.2 P&I club rules for protection and indemnity cover will vary, but the owner may, upon negotiation, apply for lay-up return for certain idling period provided the vessel is declared safely laid up.
11.3 If the vessel is laid-up for an extended period of time, most P&I clubs will reserve the right to inspect the condition of the vessel on re-commissioning.
11.4 Most port authorities will require a letter from local P&I club representatives to confirm that the laid-up vessel is covered for port risks, e.g. oil pollution, wreck removal, salvage costs, etc.

12. Manning
12.1 The Minimum Safe Manning Document (SMD) does not apply to ships in lay-up.
12.2 When a vessel is laid up, normal manning may be reduced appropriate to the status and operational requirements of the vessel. Any reduction in manning should be considered in consultation with the relevant port or coastal State Authority.
12.3 If the managers and/or the port or coastal States wish to have a lay-up SMD issued by the BMSR, Form 12 is to be sent to registry@barbadosmaritime.com.
12.4 The BMSR recommends that a suitably qualified person should remain in charge of the vessel for the proposed lay-up period and that the manning available should include a sufficient number of trained persons to meet any emergency situation. In such circumstances, communication must be maintained with the local authorities so that further assistance may be immediately obtained when required.

13. Flag Inspections

13.1 If the duration of lay-up includes the window for the annual flag inspection, the anniversary date may be suspended until the vessel is being prepared for reactivation.

 

 

Revision No

Description Of Revision

1.0

First Issue

1.1

Amended Sec. 5.5

 

 

 

 

 

 

 

 

 

 

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Bulletin 016 – Life Saving Appliances Maintenance and Inspections

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

 

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) SOLAS, International Convention for the Safety of Life at Sea.
c) Resolution MSC.402(96) Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear.
d) Resolution MSC.404(96) Amendments to SOLAS Ch’s II-2 and III.
e) Bulletin 041 – Barbadian Authorisation of Service Provider.
f) Resolution A.761(18) Recommendation on Conditions for the Approval of Servicing Stations for Inflatable Liferafts.
g) Bulletin 08 – Permits Exemptions and Equivalences.
h) International Life-Saving Appliance Code (LSA Code).
i) MSC.1/Circ.1490/Rev.1 Revised unified interpretation of SOLAS regulation III/31.1.4 (MSC.1/Circ.1490)

2. Purpose

2.1 This Bulletin is to establish a uniform, safe and documented standard for maintenance, inspections and servicing of Life Saving Appliances (LSA) in compliance with SOLAS III/Reg. 20 and Reg. 36 and with IMO Resolution MSC.402(96) and Resolution MSC.404(96), which both took effect on the 1st of January 2020.

3. Application

3.1 This Bulletin applies to all LSA installed on board all Barbadian vessels.

4. Competent Person

4.1 A “competent person” is one possessing the knowledge and experience necessary to enable them to satisfactorily perform the duties required by SOLAS III/Reg.20 and Reg. 36. Such knowledge and experience can be obtained in a variety of ways. For example, a “competent person” might obtain the necessary knowledge through training provided by the manufacturer of equipment or by “inhouse” or “on the job” training provided within the organisation or on the vessel.

4.2 SOLAS does not define who can be considered a “competent person”. It is for the Company to decide who is a “competent person” for a particular duty. A member of the vessel’s crew might, if they have the appropriate knowledge and experience, be considered a “competent person” for the purpose of carrying out routine inspections, whereas a “competent person” able to carry out tests of lifting equipment may need to be provided by a company specialising in such testing. It should also not be assumed that possession of a Certificate of Competency means that the person holding that Certificate is automatically a “competent person” for the purposes of this bulletin. Much will depend on the work to be undertaken, the qualifications required to undertake it and the individual’s knowledge of the particular equipment.

4.3 The Company are responsible for assessing and selecting a suitable “competent person”. Appropriate procedures relating to this activity must be established within the Company’s Safety Management System (SMS). Documentary evidence of personnel competence must be available on board for verification by Barbados Appointed Nautical Inspectors (ANIs) and Recognised Organisations (ROs).

5. Equipment Servicing

5.1 SOLAS III/Reg. 20.8 requires inflatable life rafts, inflatable life jackets, marine evacuation systems, and inflated rescue boats to be serviced at approved servicing facilities.

5.2 Before endorsing or issuing the Cargo Ship Safety Equipment Certificate, the RO surveyors must be satisfied that the servicing has been completed satisfactorily. The surveyor’s attendance during servicing is not mandatory because they are taken ashore.

5.3 The servicing interval and procedures for inflatable rescue boats must be according to the manufacturer’s requirements. The facility performing the servicing must be an approved service provider by a Barbados RO, as detailed in Resolution A.761(18).

5.4 It may be necessary to temporarily carry on board more persons than currently authorised. When physically possible, the installed lifeboats must be recertified to provide the necessary capacity. If the existing lifeboats are already certified to their maximum capacity, the BMSR may allow with a permit, as per Bulletin 008, substituting inflatable life raft capacity to increase the required lifeboat complement for legitimate, verifiable reasons. The permit will be limited to the minimum time required for the additional persons to be on board and, in general, will not exceed two months.

6. Inspections and Maintenance

6.1 Weekly and monthly inspections, routine maintenance of life-saving appliances, including lifeboat equipment as specified in the equipment maintenance manual can be conducted by a competent person, in accordance with the maintenance manual(s), and such activities do not require BMSR authorisation.

6.2 Monthly inspections of LSA, including lifeboat equipment, shall be carried out using a checklist as required by SOLAS III/Reg. 36.1 and a report of the inspection shall be entered in the official log-book.

6.3 SOLAS III/Reg. 20.11 requires annual and five-year thorough examinations, any overhaul and overload operational tests to be carried out for:

.1 Lifeboats (including free-fall lifeboats), rescue boats and fast rescue boats; and
.2 Launching appliances (including primary and secondary means of launching appliance for freefall lifeboats), and release gear for all lifeboats type, rescue boats, fast rescue boats and davit launched liferafts.

6.4 The annual and five-year thorough examination, any overhaul or overload operational tests of equipment listed in Sec. 6.3 above shall be conducted ONLY by a service provider with a Barbados Approved Service Provider (BASP) authorisation document issued by the BMSR as per Bulletin 041.

6.5 Instructions, maintenance and record keeping shall be implemented through the vessel’s instructions for on-board maintenance of life saving appliances or a planned maintenance system which meets the requirements of SOLAS III.

6.6 Records must clearly state that the annual periodical inspection has been carried out and the results of the examination. If end-for-end turning of wires has been carried out this should also be recorded. The renewal of falls at the required intervals (according to the maintenance procedure adopted) must be included. These records must be verified by the surveyor attending for the Safety Equipment Survey.

6.7 There are no provisions in SOLAS III to postpone the 5 yearly service and load test. The Company shall make arrangements for the 5-yearly service to be carried out, including the dynamic load test, prior to the expiry of the 5-year term.

6.8 In exceptional cases where it is not possible to conduct the 5-yearly service within the required period, the BMSR may consider short postponements of up to 3 months to allow the service to be completed. In such cases, the BMSR will issue a permit as per Bulletin 008.  

7. Maintenance of LSA falls

7.1 As required by SOLAS III/Reg. 20.4, falls used for launching lifesavings appliances must be inspected periodically with special regard for areas passing through sheaves. Deteriorating falls must be renewed as necessary or at intervals of not more than five (5) years, whichever is the earlier. The intermediate turning of the falls end for end is no longer required.

7.2 Wire rope grips, such as bulldog grips, are not acceptable for any primary load-bearing terminations. Where wire rope grips are found to have been used on primary load-bearing terminations, arrangements must be made for their replacement.

7.3 If the Company chooses to end-for-end fall wires, special attention must be paid to the method of joining and terminating wires. The BMSR recognises that there are a number of alternative methods that can be used to form these terminations and that the suitability of each type of connection for the intended service is varied. The Company shall ensure the correct method of joining and terminating the wires, taking into consideration any design or manufacturers’ requirements.

7.4 The periodic inspection shall be carried out by a competent person within the window before, or at the time of, the Safety Equipment survey.

8. Lifeboats

8.1 Vessels must be fitted with lifeboats on-load release mechanisms compliant with Sec. 4.4.7.6.4 to 4.4.7.6.6 of LSA Code as required by SOLAS III/Reg. 1.5.

8.2 The vessel’s Master must ensure that when a lifeboat on-load release hook with a secondary safety system is fitted, this is used during all drills (both launch and recovery) and when the lifeboat has crew or other personnel aboard. After the drill finishes, the secondary safety system must be removed or disengaged.

8.3 When any lifeboat is damaged, declared unseaworthy, or needs repair and if no replacement boat is readily available, life raft(s) capacity for all the persons on board may be substituted as a temporary measure. This substitution may only take place with a permit as per Bulletin 008, which, in general, will not exceed three (3) months. The minimum survival craft capacity prescribed by SOLAS III must be maintained.

9. Rescue Boats

9.1 SOLAS and the LSA Code do not require boats used solely for rescue to be fitted with on-load release mechanisms; however, many are fitted with these devices. The BMSR recommends that all on-load release mechanisms should meet the same standards, regardless of whether installed on a lifeboat or rescue boat. Accordingly, the rescue boat on-load release mechanisms should also comply with Sec. 4.4.7.6 of the LSA Code.

10. Liferafts

10.1 Liferafts provided under SOLAS III/Reg. 31.1.4 may be stowed in protected positions, provided they are always readily available. Care must be given to their accessibility when deck cargoes are carried.
10.2 For Barbadian vessels, IMO MSC.1/Circ.1490/Rev.1 must be applied to liferafts as required by SOLAS III/Reg. 31.1.4. This unified interpretation covers:

.1 stowage arrangements;

.2 embarkation and embarkation ladders;

.3 illumination; and

.4 lifejackets and immersion suits.

 

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Bulletin 049 – Pilot Transfer Arrangements

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

1. References

a) SOLAS, International Convention for the Safety of Life at Sea.
b) Resolution A.1045(27) Pilot Transfer Arrangements, adopted 30 November 2011.
c) MSC.1/Circ.1375/Rev.1 – Unified Interpretation of SOLAS Regulation V/23, issued 28 May 2012.

2. Purpose

2.1 This bulletin sets out to ensure that the use and maintenance of pilot transfer arrangements onboard Barbadian ships, complies with the standards set out in IMO Assembly Resolution A.1045 (27) and SOLAS V Reg. 23.

2.2 To ensure that all pilot/personnel transfers, using pilot transfer arrangements, are carried out safely.

3. Application

3.1 This bulletin applies to all Barbadian vessels that at any time may require the services of pilots. This includes but is not limited to entering or leaving port, as required during a deep sea passage, when transiting a strait and/or river, or as required by the Coastal State.

4. Pilot Transfer Requirements

4.1 Equipment and arrangements for pilot transfer which are installed on or after 1 July 2012 shall comply with the requirements of SOLAS V/ Reg. 23, with reference to the unified interpretation as per IMO Circular MSC.1/Circ.1375/Rev.1, and as set out in IMO Assembly Resolution A.1045(27).

4.2 These minimum requirements refer to the positioning, construction, rigging and securing of pilot transfer arrangements, as well as the related equipment, lighting, and access.

4.3 Equipment and arrangements for pilot transfer which are provided on ships before 01 July 2012 shall at least comply with the requirements of SOLAS V/ Reg. 23, as was in force prior to that date.

4.4 Further visual, explanatory notes are given in Annex I to this bulletin, as issued by the International Maritime Pilot’s Association (IMPA).

4.5 Owners shall ensure that the vessel is provided with equipment, and has procedures in place, that complies with Resolution A.1045(27) and SOLAS V/ Reg. 23, that appropriate manuals for pilot transfer arrangements are available on board the ship, and that suitable positions are available on each side of the ship for compliant pilot transfer arrangements to be rigged.

4.6 The Master shall ensure that a responsible officer supervises the rigging, testing and use of the pilot transfer arrangements and shall ensure that the crew members engaged in rigging and use of the pilot arrangements have been properly instructed.

4.7 The Master shall also ensure that the pilot transfer equipment and arrangements are accessible, kept clean, properly maintained, properly stowed, and regularly inspected.

Annex I – Required Boarding Arrangements for Pilot

 

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Bulletin 011 – Minimum Safe manning Requirements Rev 3.2

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

1. References
a) Barbados Merchant Shipping Act (CAP 296).
b) Barbados S.I 2001 No. 44 – Shipping (Safe Manning, Watchkeeping and Hours of Work) Regulations, 2001.
c) SOLAS, International Convention for the Safety of Life at Sea.
d) IMO Assembly Resolution A.1047(27), Principles of minimum safe manning, adopted 30 November 2011.
e) Maritime Labour Convention 2006 (MLC).
f) The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, (STCW Convention).
g) The Seafarers’ Training, Certification and Watchkeeping Code (STCW Code).
h) The International Ship and Port Facility Security Code (ISPS Code).
i) Form 159 – Table of Shipboard working Arrangements.
j) Form 12 – Application for Safe Manning Document.
k) IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements and formats of records of seafarers’ hours of work or hours of rest.

2. Purpose

2.1 This Bulletin sets out the measures adopted by the Barbados Maritime Ship Registry (BMSR) to ensure Barbadian vessels comply with Barbados CAP 296 Section 211, Barbados S.I 2001 No. 44 , SOLAS Regulation V/14, IMO Assembly Resolution A.1047(27), MLC, STCW Convention Regulation VIII/2 and STCW Code Section A-VIII/2.

2.2 The requirements of this Bulletin are to ensure that Barbadian vessels are sufficiently, effectively, and efficiently manned to provide safety and security of the vessel, safe navigation and operations at sea, safe operations in port, prevention of human injury or loss of life, the avoidance of damage to the marine environment and to property, and to ensure the welfare and health of seafarers through the avoidance of fatigue.

3. Application

3.1 The safe manning requirements of Section 4 and the Barbados shipboard working arrangements requirements of Section 5, apply to all Barbadian vessels.

3.2 The requirements for a Safe Manning Document (SMD) of Section 5 apply to vessels engaged on international voyages and commercial yachts of 500 GT and greater.

3.3 The requirements for a Safe Manning Document (SMD) of Section 5 do not apply to :
.1 Ships of war and troopships.
.2 Cargo ships of less than 500 gross tonnage.
.3 Vessels not propelled by mechanical means.
.4 Wooden ships of primitive build.
.5 Pleasure yachts not engaged in trade.
.6 Fishing vessels.

4. Safe Manning Requirements

4.1 The Company and the Master shall ensure that all persons joining a vessel or unit are immediately given appropriate familiarization training with respect to the vessel for emergency, safety, security and environmental responsibilities in addition to their respective duties and functions.

4.2 The Company and the Master of a vessel shall ensure that watch standards and arrangements as outlined in STCW Convention Chapter VIII are always maintained.

4.3 The Company and the Master shall meet the relevant requirements of MLC 2006 and STCW Convention Chapter VIII with respect to periods of rest and prevention of alcohol abuse for any person assigned or performing designated safety, prevention of pollution and security duties.

4.4 Vessel’s Cook

.1 In all cases where the total manning consists of 10 persons or more, there shall be a dedicated certified cook.

.2 As per MLC A3.2.5, on vessels operating with a prescribed manning of less than 10 the company should have one person designated as the Cook. If the appointed person does not hold a vessel’s cook certificate, then the person is to be trained or instructed in areas including food and personal hygiene as well as handling and storage of food on board vessel.

4.5 Ship Security Officer (SSO)

.1 All persons, onboard vessels to which the International Code for the Security of Ships and Port Facilities (ISPS Code) applies, shall have received security training in accordance with STCW Convention Regulation VI/6. One appropriately trained person shall be designated as the Ship Security Officer (SSO) as required under the ISPS Code.

.2 The SSO may be the Master, or any other person designated by the Company. The designated officer shall meet the training requirements in accordance with the provisions of STCW Regulation VI/5 and shall be directly responsible to the Master (if the SSO is not the Master) and the Company Security Officer (CSO) in compliance with vessel’s SMS.

.3 The Company shall ensure that one of the capacities proposed to be included on the SMD is also able to carry out the duties of the SSO.

4.6 Persons Assigned Electronic and Electrical Duties

.1 A vessel powered by main propulsion machinery of 750 kW propulsion power or more may carry persons who are specifically assigned the specific duties, tasks and responsibilities relating to electrical and electronic tasks. If required to be carried, these persons should be certified as Electro-Technical Officers or Electro-Technical Ratings and satisfy the requirements of STCW Regulations III/6 or III/7 respectively.

.2 The SMD need only include these persons if they are additional to the Engineering Officers and they have been assigned shipboard duties to satisfy the requirements of the maintenance of a safe engineering watch, emergency as specified in the Muster List or operation and maintenance of the vessel’s electrical, electronic and control systems.

4.7 Person Designated for Safety

.1 All vessels shall have a person, who may be the Master, who has responsibility for implementation of and compliance with the vessel’s occupational safety and health policy and programme.

4.8 Manning During Hours of Darkness and Restricted Visibility
.1 Companies shall ensure that the vessels have sufficient trained navigational watch-keeping personnel to ensure that the navigation control room/bridge is manned by at least 2 watch keepers during hours of darkness and conditions of restricted visibility. One of these watch keepers shall be a Deck Officer. 

4.9 Manning Onboard Specific Ship

.1 Vessels with propulsion power of less than 750 kW

i) Vessels with propulsion power of less than 750 kW are not required to have an engineer certificated in accordance with STCW Convention. However, such vessels must have at least one person, other than the Master, who is trained and certified to operate the machinery onboard the vessel. If the training is not in accordance with STCW Convention then the person should have documentary evidence of his training and capability to perform the assigned tasks.

.2 Vessels with Unattended Machinery Space (UMS)

i) The UMS notation assigned by a Classification Society shall be considered when determining whether the machinery space can be unattended.
ii) If the manning of a vessel with propulsion power of more than 3000kW is based on UMS notation, then the vessel shall carry an additional watch-keeping engineer officer if the UMS systems are inoperative for more than seven days. The Company shall notify affected Classification Society and the BMSR of the related equipment failure affecting the UMS notation.

.3 Tankers

i) Companies operating tankers shall ensure that all officers, ratings, and persons involved in cargo operation hold a basic training in accordance with the provisions of STCW requirements relating to the type of tanker on which the person is serving.
ii) Officer shall have the Certificate of Proficiency STCW V/1-1 and V/1-2 endorsed by the BMSR.

.4 Vessels Fitted with ECDIS

i) The Company should ensure that if the vessel is fitted with ECDIS, the Master and navigating officers have appropriate generic and type specific ECDIS training.
ii) The Master shall ensure that all affected officers have documentary evidence ECDIS training prior to be assigned their onboard navigational duties.

4.10 Employment of Additional Seafarers by the Company.

.1 A Company may decide to employ more seafarers than stipulated in the SMD. These seafarers shall be trained to a level appropriate to their duties in addition to having the minimum basic training for emergency, safety, and survival. The statutory certificates will detail the maximum number of persons on board and there must be sufficient accommodation satisfying the MLC 2006 (as amended) standards for that number.

.2 There are a number of capacities that are not identified in STCW and accordingly the SMD may not refer to them. The Company should decide on their qualification or experience in accordance with the objectives of their Safety Management System but if the persons are employed and assigned shipboard safety, security, environmental protection, cargo operations or watch-keeping duties, the person must complete STCW basic training before joining the vessel and receive shipboard familiarization training before being assigned their shipboard tasks/duties.

4.11 Employment of Seafarers for vessel with no SMD requirements

.1 On a vessel that is not required to comply with the SMD requirements, either because not engaged on international voyages or exempted as per Sec. 3.3 above, the seafarers are not required to have STCW qualifications but they shall be trained to a level appropriate to their duties in addition to having the minimum basic training for emergency, safety, and survival.
.2 The Company should decide on their qualification or experience in accordance with the objectives of their Safety Management System but if the persons are employed and assigned shipboard safety, security, environmental protection, cargo operations or watch-keeping duties, the person must complete STCW basic training before joining the vessel and receive shipboard familiarization training before being assigned their shipboard tasks/duties.
.3 The statutory certificates will detail the maximum number of persons on board and there must be sufficient accommodation satisfying the MLC 2006 (as amended) standards for that number.

5. Watchkeeping

5.1 The company responsible for the operation of the vessel shall ensure that all watch standers on board its vessels adhere to the minimum limits of hours of rest in accordance with international regulations.

5.2 For vessels of 3000 GT and above and propulsion power of 3000 KW and above the Master and the chief engineer should not be part of the vessel watches and a three-watch system should be adopted for both the deck and engine watches.

5.3 For vessels of less than 3000 GT and with propulsion power of less than 3000 KW two-watch system may be adopted provided that the requirements for work and rest hours are met.

5.4 For deck watches that are normally limited in numbers, a routine for providing additional assistance without delay shall be established and standby personnel shall be identified and immediately contactable.

5.5 On vessels with periodically unattended machinery spaces (UMS) notation and of less than 2000 KW propulsion power and in case of limited number of cabins and bunks a watch with only the Chief engineer may be adopted during the daytime (0800-2000) provided that the requirements for work and rest hours are met and that additional assistance without delay is established.

5.6 When the engine watch is only with the Chief engineer, the Company shall anticipate the number of hours that the Chief engineer must devote to unscheduled work in case of emergency. As soon as practicable after the normal situation has been restored, the Chief engineer shall have an adequate period of rest.

6. Radio Watchkeeping

6.1 On Barbadian vessels with the GMDSS, all officers with radio duties shall hold a valid BMSR endorsed GMDSS radio operators Certificate of Competency (COC), as per STCW IV/2. Therefore, a Barbadian vessel shall have on board at least two officers to carry out radio duties in their own respective watch, when a 2-watch system is in place.

6.2 In case of a 3-watch system, to ensure a continuous radio watch while at sea, the third watch should either be supported by one of the two officers as per Sec.

6.1 above or manned with a third officer who also holds a BMSR endorsed GMDSS radio operators COC.

6.3 When the officers of Sec. 6.1 above provide support for the third watch their total hours of work and rest are to be maintained at all times.

6.4 The BMSR endorsed GMDSS radio operators COC is to be adequate for the Sea Areas (A1, A2,A3, A4) on which the vessel operates.

7. The Barbados Shipboard Working Arrangements

7.1 In compliance with the Barbados S.I 2001 No. 44 and with IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements, the company shall produce a shipboard working arrangements (SWA) of hours of work and rest for all seafarers on board which includes regular watchkeeping duties and non-watchkeeping duties at sea and in port.

7.2 The SWA shall be based on the BMSR format as per Form 159 – Table of Shipboard Working Arrangements, which is to be signed by the Master and be posted or maintained to be easily accessible and capable of being verified by Barbados Appointed Nautical Inspectors and Port State Control Officers.

7.3 A Copy of the Form 159 – Table of Shipboard Working Arrangements shall be submitted to BMSR in order to verify the vessel is safely manned.

7.4 Records of each seafarers’ daily hours of work or rest shall be maintained on board and with a model format as per Appendix 4 of the IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements.

8. Safe Manning Document – Requirements

8.1 The Company shall make an application for a SMD following an assessment that takes into consideration Sections 8.2, 8.3 and 8.4 of this Bulletin.

8.2 The minimum safe manning of a vessel should be established by taking into account all relevant factors, including the following:

.1 size and type of vessel;

.2 number, size and type of main propulsion units and auxiliaries;

.3 level of vessel automation;

.4 construction and equipment of the vessel;

.5 method of maintenance used;

.6 cargo to be carried;

.7 frequency of port calls, length, and nature of voyages to be undertaken;

.8 trading area(s), waters, and operations in which the vessel is involved;

.9 extent to which training activities are conducted on board;

.10 degree of shoreside support provided to the vessel by the company;

.11 applicable work hour limits and/or rest requirements; and

.12 the provisions of the approved Ship’s Security Plan.

8.3 In determining the minimum safe manning of a vessel the following principles should be observed.

.1 The capability to:

i) Maintain safe navigational, port, engineering, and radio watches in accordance with regulation VIII/2 of the STCW Convention, as amended, and also maintain general surveillance of the vessel;
ii) moor and unmoor the vessel safely;
iii) manage the safety functions of the vessel when employed in a stationary or near stationary mode at sea;
iv) perform operations, as appropriate, for the prevention of damage to the marine environment;
v) maintain the safety arrangements and the cleanliness of all accessible spaces to minimize the risk of fire;
vi) provide for medical care on board vessel;
vii) ensure safe carriage of cargo during transit;
viii) inspect and maintain, as appropriate, the structural integrity of the vessel;
ix) operate in accordance with the approved Ship’s Security Plan;

.2 The ability to:

i) operate all watertight closing arrangements and maintain them in effective condition, and also deploy a competent damage control party;
ii) operate all onboard firefighting and emergency equipment and life saving appliances, carry out such maintenance of this equipment as is required to be done at sea, and muster and disembark all persons on board;
iii) operate the main propulsion and auxiliary machinery including pollution prevention equipment and maintain them in a safe condition to enable the vessel to overcome the foreseeable perils of the voyage.

8.4 The following onboard functions, when applicable, should also be taken into account:

.1 ongoing training requirements for all personnel, including the operation and use of fire fighting and emergency equipment, life-saving appliances, and watertight closing arrangements;

.2 specialized training requirements for particular types of vessels and in instances where crew members are engaged in shipboard tasks that cross departmental boundaries;

.3 provision of proper food and drinking water;

.4 need to undertake emergency duties and responsibilities; and

.5 need to provide training opportunities for entrant seafarers to allow them to gain the training and experience needed.

9. Safe Manning Document – Temporary Exemption

9.1 In cases of Force Majeure, where the manning level falls below that of the SMD e.g., due to crew illness, unexpected repatriation on compassionate grounds etc., the vessel may as a temporary measure, sail with one person less than that stipulated in the SMD and in exemption of SOLAS V/14 provisions. This does not apply to the capacities of Master and chief engineer.

9.2 In all such cases the Master, in consultation with the chief engineer where the shortage relates to an engineer officer, should ensure that there is a continuity of watches by duly qualified persons without affecting the statutory minimum periods of rest.

9.3 The shortage must be filled at the earliest opportunity and in any case not later than fourteen (14) days or at the next port if the intended voyage is more than fourteen (14) days.

9.4 In circumstances of exceptional necessity, as per MLC Standard A3.2.6, where a Company is unable to achieve the minimum manning due to the lack of a duly certificated Cook, a temporary exemption from the provision of MLC Regulation 3.2.3 may be granted and permitting a non-fully qualified cook to serve in a specified vessel for a specified limited period, until the next convenient port of call or for a period not exceeding 1 month, provided that the person to whom the dispensation is issued is trained or instructed in areas including food and personal hygiene as well as handling and storage of food on board vessel.

9.5 The BMSR must be notified and provided with the following information, which must also be duly recorded in the Official Logbook:

i) Name and IMO Number of the vessel
ii) Capacity and rank of the officer
iii) Reason for exemption
iv) No. of crew onboard, excluding the affected officer
v) The Port of departure and arrival with the shortage
vi) Date of departure and ETD

10. Safe Manning Document – Application

10.1 The Company shall submit of a proposal for minimum safe manning defining the nature of the operation of the vessel, taking into account the requirements of Section 8 of this Bulletin.

10.2 The minimum SMD can be issued with a designation of “Unlimited” or “Limited” trading areas, for those vessels which have operations to a limited geographical area.

10.3 “Limited” trading areas are when:

.1 The voyages do not exceed 24 hours between ports of calls; or

.2 Voyages are within 200 nm from the nearest shore; or

.3 Enclosed areas.

10.4 Enclosed areas, may include, but are not limited to:

.1 Mediterranean Sea, Red Sea, Caspian Sea, Black Sea, Azov Sea, North Sea, Gulf of Aden, Baltic Sea, Persian Gulf;

.2 Caribbean Sea (restricted areas 1, II, and/or III, as defined in CCSS Code);

10.5 A vessel which operates part of the time within a limited areas and part of the time on more extensive voyages may elect to have two (2) SMDs.

10.6 To apply for an SMD the Form 12 – Application for Safe Manning Document shall be used.

10.7 The fields of the SMD application Form are to be completed with accurate information. If an item does not apply to the vessel, “N/A” is to be placed in the space. The application is to be completed and signed by a person appointed by the Company.

10.8 A guideline of the minimum manning levels required by the BMSR for unlimited and limited trading areas is provided in Appendix A of this Bulletin.

10.9 If there are special considerations that may affect manning levels, they should be included on the form at the bottom of the second box where it says “Comments/Special Considerations or vessel configurations that may affect manning.” This could include operations such as coastal or domestic trade, number of cabins and/or bunks on the vessel, the vessel’s intended port schedule, etc.

10.10 In assessing minimum deck manning, the BMSR shall consider the vessel’s dimensions, layout of crew accommodation, and internal communications systems, all of which affect crew capabilities and response reactions, the vessel’s propulsion power, the engine room layout and proximity to boiler rooms, etc.

10.11 In this respect the BMSR may increase the scale of manning from that proposed by the Company. The BMSR will not normally reduce the manning level from that proposed by the Company unless it considers certain references in the SMD application proposed by the Company are unnecessary or inconsistent with standard practices.

11. Safe Manning Document – Validity

11.1 In compliance with the requirements of Annex 5 of the IMO Assembly Resolution A.1047(27) an SMD issued to a vessel shall have a validity of 5 years from the date of issue.

11.2 A new SMD is also required to be issued when:

i) there is a change of vessel’s name; or
ii) there is a change of trading area; or
iii) change of ISM Managers; or
iv) any other changes/alterations to the vessel, its crew, construction, machinery, equipment, operation, maintenance, or management that affects the manning level required to continue safe operations.

12. Port State Control

12.1 The STCW Convention, Regulation I/4, enables port State authorities to verify conditions on any vessel, particularly as to the qualifications and ability of personnel on board. Port State authorities may pay particular attention to the following:

.1 that all seafarers on board who are required to be certificated hold an appropriate Barbados certificate or provide documentary proof that an application for an endorsement has been submitted to the BMSR; and/or

.2 the numbers and certificates of the seafarers serving on board conform to the applicable safe manning requirements of the BMSR.

12.2 In accordance with section A-I/4 of the STCW Code, port State authorities may assess the ability of the seafarers of the vessel to maintain watchkeeping standards as required by the STCW Convention, if there are clear grounds for believing that such standards are not being maintained because of any of the following having occurred:

.1 the vessel has been involved in a collision, grounding, or stranding;

.2 there has been a discharge of substances from the vessel when underway, at anchor or at berth, which is illegal under any international convention;

.3 the vessel has been manoeuvred in an erratic or unsafe manner whereby routing measures adopted by the IMO or safe navigation practices and procedures have not been followed; or

.4 the vessel is otherwise being operated in such a manner as to pose a danger to persons, property, or the environment.

12.3 Regulation 2.7 of the MLC requires vessels to have a sufficient number of seafarers employed on board to ensure that they are operated safely, efficiently, and with due regard to security under all conditions, taking into account concerns about seafarer fatigue and the particular nature and conditions of the voyage. Port State Control (PSC) officers are entitled to verify that this is the case when there are grounds for carrying out a more detailed inspection.

Appendix A

The tables given below are provided for guidance/reference and are samples only, to assist Owners/Managers when making a proposal for minimum safe manning levels.

Deck Department

Vessel SizeCapacitySTCW Reg.N.of Persons UnlimitedN. of Persons Limited1
≥ 10,000 GTMasterII/211
Chief MateII/211
Officer of the Navigational Watch II/121(2)
Navigational Watch RatingII/4(3)32
Able Seafarer Deck II/5(3)22
Total97
≥ 3,000 GT < 10,000 GTMasterII/211
Chief MateII/211
Officer of the Navigational WatchII/111
Navigational Watch RatingII/4(3)33
Able Seafarer DeckII/5(3)10
Total76
≥ 1000 GT < 3,000 GTMasterII/211
Chief MateII/211
Officer of the Navigational WatchII/110(2)
Navigational Watch RatingII/4(3)32
Able Seafarer DeckII/5(3)00
Total64
≥ 500 GT < 1,000 GTMasterII/211
Chief MateII/210
Officer of the Navigational WatchII/10(2)1(2)
Navigational Watch RatingII/4(3)22
Able Seafarer DeckII/5(3)00
Total44
<500 GTMasterII/311
Chief MateII/300
Officer of the Navigational WatchII/111
Navigational Watch RatingII/4(3)21
Able Seafarer DeckII/5(3)10
Total53

(1) See Sec. 10.3 
(2) BMSR may request one ONW be added, following review of vessel’s operational area and type of ship.
(3) BMSR will accept alternative manning for ranks II/4 and II/5 as far as the total number is as per table.

Engine Department

Propulsion power CapacitySTCW Reg.N. of Persons Unlimited N. of Persons Limited3
≥ 3,000 kW
NOT UMS
Chief EngineerIII/211
Second EngineerIII/21(5)1
Officer in charge of the Engineering WatchIII/11(6)0(7)
Engineering Watch RatingIII/4(9)2(6),(8)2(6),(8)
Able Seafarer EngineIII/5(9)11
Total65
≥ 750 kW
< 3,000 kW
NOT UMS
Chief EngineerIII/311
Second EngineerIII/31(6)0(7)
Officer in charge of the Engineering WatchIII/10(7)1(6)
Engineering Watch RatingIII/4(9)2(6),(8),(10)1(8),(10)
Able Seafarer EngineIII/5(9)00
Total43
< 750 kW10 (11)
NOT UMS
Chief EngineerIII/31(12)1(12)
Second EngineerIII/300
Officer in charge of the Engineering WatchIII/1 1(6),(10)1(6),(10)
Engineering Watch RatingIII/4(9)0(8)0
Able Seafarer EngineIII/5(9)00
Total22

(4) See Sec. 10.3
(5) For UMS notation ONLY, BMSR might accept an OICEW in lieu of the Second Engineer III/2.
(6) Manning may be reduced by one at this rank if vessel classed with UMS.
(7) BMSR may request one additional one at this rank.
(8) Tankers of 1000 GT or more shall add one additional Engineering Watch Rating.
(9) BMSR will accept alternative manning for ranks III/4 and III/5 as far as the total number is as per table.
(10) Manning may be reduced by one see Sec. 5.5.
(11) See Sec. 4.9.1.
(12) BMSR might accept an OICEW in lieu of the Chief Engineer III/3.

Revision No Description Of Revision
1.0 First Issue
1.1 Amended hyperlinks and bulletin format
 2.0 Bulletin format and Appendix table conditions
3.0 Major revision with several amendments in all sections and replaced “wording “ship” with “vessel” in all sections. Added section 6 Radio Watchkeeping. Added footnote 9
3.1 Added new section
3.2 3.2 Added Sec. 3.3 and 4.11. Amended Sec. 3.2, 4.4.1. Amended Appendix A Deck Department table.
   

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Bulletin 007 – Maritime Labour Convention 2006

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

 

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) Maritime Labour Convention, 2006 (MLC 2006).
c) ILO “Guidelines for flag State inspections under MLC 2006”.
d) ILO “Guidelines for port State control officers carrying out inspections under MLC 2006”.
e) Bulletin 013 -Barbados Approved Providers of Insurance.
f) Form 143 – DMLC Part I Application Form.
g) Form 140 – MLC 2006 – DMLC Part II.
h) Form 34 – International Safety Management (ISM) Code Declaration

2. Purpose
2.1 This Bulletin provides information on Barbados’ policy on the application of the MLC 2006, which governs maritime labour conditions and sets minimum standards for the working and living conditions of seafarers aboard ships, as applicable.

3. MLC Shipowner

3.1 “MLC Shipowner” means the owner of the ship or another organization or person, such as the Manager, agent or bareboat charterer, who has assumed the responsibility for the operation of the ship from the owner and who, on assuming such responsibility, has agreed to take over the duties and responsibilities imposed on shipowners in accordance with this Convention, regardless of whether any other organization or persons fulfil certain duties or responsibilities on behalf of the shipowner.”

4. Application

4.1 The MLC 2006 applies to all seafarers and all vessels ordinarily engaged in commercial activities, whether publicly or privately owned, except as specified in Sec. 8 below.
4.2 Vessels constructed prior to 20 August 2013 are deemed to be existing vessels for the purposes of accommodation standards and accordingly Title 3 provisions of the MLC 2006 are not applicable to these vessels. Vessels constructed on or after 20 August 2013 shall comply with the accommodation standards specified in Title 3 MLC 2006.

5. Amendments of the MLC 2006 -Financial Security Documents

5.1 The Amendments to MLC 2006 entered into force on the 18th January 2017. From this date, vessels that are subject to MLC will be required to display certificates issued from an insurer confirming that insurance is in place for liabilities in respect of:
.1 Standard A2.5.1 – Repatriation; and
.2 Standard A4.2.1 – Shipowners’ liability (Death & Injury Compensation).
5.2 Barbados vessels were required to comply with the new amendments as soon as the amendments entered into force, but not later than the first MLC renewal survey.
5.3 The insurance cover and the associated certificates shall be issued by a Barbados Approved Providers of Insurance as listed in Bulletin 013 and displayed on board.
5.4 The Financial Security Documents have a validity of 1 year, hence every year a copy shall also be provided to the BMSR as evidence of valid financial security.
5.5 The insurance certificates must be in a model format and must include the information specified in the MLC Amendments. It should be noted that on these certificates, the assured party will normally be the registered owner, but this will not necessarily be the same as the “MLC Shipowner” named on other MLC documentation.
5.6 Where the assured party named on the insurance certificates and the MLC Shipowner are different there should be evidence of this shall be provided to the BMSR submitting Form 34.
5.7 Valid documentary evidence of financial security is to be provided with the initial application and in the following circumstances:
.1 Change of the registered shipowner whose name is recorded in the P&I records and the issued evidence of financial security.
.2 Change to ISM Manager which invalidates the existing P&I issued evidence of financial security;
.3 Change of the vessel’s gross tonnage; and
.4 Changes to exemptions or equivalent arrangements.

6. MLC 2006 Certification

6.1 Considering Sec.2.1 above , the MLC 2006 Certification is only required for vessels of:
.1 500 gross tonnage or over, engaged in international voyages;
.2 500 gross tonnage or over, flying the Barbados flag operating from a port, or between ports, outside Barbados waters.
6.2 The full Maritime Labour Certificate (MLC), the interim MLC and the Declaration of Maritime Labour Compliance (DMLC) Part I and II are to be as per the models given in the MLC 2006 Appendix A5-II.
6.3 The MLC is issued by a Barbados Recognised Organisation (RO) for a maximum period of five years, subject to an intermediate MLC inspection.
Interim MLC
6.4 An interim MLC is issued only once for a period of maximum of six months and in the cases below:
.1 For a new vessel;
.2 When the vessel is registered with the BMSR;
.3 When a new MLC shipowner assumes responsibility for the operation of the vessel.
6.5 The BMSR, in compliance with the MLC 2006, does not allow the issuance of a further interim MLC following the initial six months.
6.6 The initial MLC inspection for the issuance of the full MLC shall be carried out within the validity of the interim MLC. When the initial MLC inspection cannot be carried out for unforeseen reasons the BMSR might issue a permit for the issuance of a short-term MLC for a maximum of 3 months.
DMLC Part I
6.7 The DMLC Part I is the national declaration of MLC 2006 compliance and is to be attached to the MLC.
6.8 The MLC shipowner shall apply to the BMSR for the DMLC Part I by completing a Form 143 – DMLC Part I Application Form and sending it to registry@barbadosmaritime.com.
6.9 A new DMLC Part I will be required where there is a change of the vessel’s particulars as recorded on the DMLC Part I or any changes to the exemptions or equivalent arrangements.
6.10 A revised DMLC Part I is not required for a change of ISM Manager or owners.
6.11 The BMSR now issues electronic Declarations of Maritime Labour Compliance Part I (DMLC Part I). A valid DMLC Part I may still be maintained in original hard copy form aboard the vessel. It does not need to be re-issued in electronic form.
DMLC Part II
6.12 The DMLC Part II is developed by the shipowner to address the requirements set out in the DMLC Part I.
6.13 The DMLC Part II shall be signed by the MLC shipowner and by the attending RO surveyor at the initial MLC inspection for the issuance of the full MLC.
6.14 The copy signed by the MLC Shipowner and RO surveyor, together with the MLC, shall be sent to the BMSR.
6.15 A revised DMLC Part II is required where there is a change of MLC Shipowner or a change to the measures to ensure compliance with the provisions of the DMLC Part I.
6.16 The BMSR has its own template for DMLC Part II, Form 140.

7. Equivalency, exemption, or exception

7.1 Any applications for the acceptance of an equivalency, exemption, or exception from MLC 2006 requirements shall be submitted to the BMSR at the time of requesting the DMLC Part I by completing a Form 143 – DMLC Part I Application Form.
7.2 Applications for exemptions relating to structural requirements for vessels (i.e., provisions of Title 3 of MLC 2006) shall be submitted to the BMSR or through an RO.
7.3 The BMSR will assess the application and, where applicable, will issue a certificate of equivalence and/or exemption and will also include these in the DMLC Part I.
7.4 If, after to the issuance of the DMLC Part I, the MLC Shipowner requires consideration of an equivalency or exemption, a new application for DMLC Part I will be required and, if the application is granted, an amended DMLC Part I, DMLC Part II and inspection for an MLC will be required.
7.5 If, after to the issuance of the MLC, the MLC shipowner requires consideration of an exception, an application should be submitted and if the application is granted, an amended DMLC Part II and inspection for an MLC will be required.
7.6 Any equivalency, exemption or exception will require a re-assessment if there are any changes to the issuing conditions or change of shipowner/manager.
7.7 Where the application for an equivalency, exemption or exception is deemed to be related to a Barbados interpretation of MLC 2006 provisions (e.g., format of record keeping, determination of seafarer), the BMSR may issue a “Statement of Interpretation” to supplement the DMLC and MLC.

8. Vessel and seafarers that do not have to comply with the requirements of MLC 2006

8.1 The following type of vessels do not require to comply with MLC 2006:
.1 Vessels that are trading and/or operating exclusively between ports and facilities within Barbados’ waters;
.2 Offshore units whose primary service is in operations for the exploration, exploitation or production of resources on or beneath the seabed and are not ordinarily engaged in navigation or international voyages (e.g., MODUs, drill ships, jack-up platforms, accommodation platforms, Floating Production, Storage and Offloading units (FPSO), purpose built or permanently converted Floating Storage and Offloading/Floating Storage Units (FSO, FSU, FSRU, etc.);
.3 Objects under tow;
.4 Non-propelled barges;
.5 Charter (commercial) yachts of less than 24 meters in length;
.6 Private (non-commercial) yachts of any size.
8.2 A seafarer is a person engaged or employed onboard for the purpose of MLC 2006.
8.3 However, for the definition of seafarer other factors that are taken into consideration are:
.1 if the nature of work is not part of the routine business of the vessel;
.2 although trained and qualified in maritime skills, the persons concerned perform key specialist functions that are not part of the routine business of the vessel;
.3 the work the person performs is occasional and short term, with the principal place of employment being onshore; and
.4 all Seafarer Employment Agreements (SEA), or Collective Bargaining Agreements (CBA) forming part thereof, or Contracts of Employment, comply with MLC 2006.
8.4 Considering Sec. 8.3 above, the BMSR does NOT consider the following group of persons as seafarers:
.1 Port workers, including travelling stevedores;
.2 Pilots and port officials;
.3 Ship surveyors and auditors;
.4 Equipment repair/service technicians and riding crew whose principal place of employment is onshore;
.5 Guest entertainers who work occasionally and short term on board with their principal place of employment being onshore;
.6 Shipowner’s shore-based personnel;
.7 Chief storekeeper;
.8 Vessel HSE Officer; and
.9 Riding crew.
8.5 If the MLC Shipowner deems that there is any other category of persons who should not be considered seafarers for the purpose of MLC 2006, an application containing the following should be submitted to ops@barbadosmaritime.com.
.1 The category or capacity of the persons;
.2 The duration of the stay on board of the persons concerned;
.3 The frequency of periods of work spent on board;
.4 The location of the person’s principal place of work;
.5 The purpose of the person’s work on board;
.6 Who is responsible for the labour and social conditions for the persons;
.7 Whether an agreement is in place for the persons and if the shipowner has assessed it to ascertain if it is comparable with MLC 2006.
8.6 If the BMSR assesses a group of persons to not be a seafarer for compliance either fully or in part with the MLC 2006 requirements, BMSR will issue a “Statement of Interpretation” to supplement the DMLC and MLC.
8.7 The MLC Shipowner should note that even when a group of persons has been assessed not to be a seafarer or a vessel does not require compliance with the MLC 2006, the following minimum requirements remain applicable:
.1 The authority of the Master, (or Offshore Installation Manager where a Master is not on board) for the overall safety and security of the vessel and compliance with any relevant Barbados requirements;
.2 Minimum age: Persons shall be 16 years or older;
.3 Medical certificate: Persons who hold any STCW certificate shall have a valid medical certificate. For all other person serving onboard, the MLC Shipowner should verify that the affected person(s) is medically fit taking into consideration the shipboard environment;
.4 Training or instructions: Persons working on board shall be duly trained or instructed for their assigned shipboard duties especially those duties that are related to safety, security or environmental protection;
.5 Hours of rest: Persons assigned safety, security or environmental protection shipboard duties, shall comply with the STCW hours of rest requirements;
.6 Medical care: The person shall have access to on board medical care;
.7 Health and safety protection and accident prevention: The onboard occupational health and safety and accident prevention policies should be applicable;
.8 On board complaints: The person should have access to the on board complaints procedures;
.9 Employment period onboard: Persons should not be employed or engaged onboard for periods exceeding 12 months;
i) Repatriation: The MLC Shipowner should verify that there are measures to enable the repatriation of the persons employed or engaged onboard within 12 months of signing the SEA, CBA and/or Contracts of Employment;
ii) Wages: shall be paid for their work regularly and in full in accordance with their SEA, CBA and/or Contract of Employment.
8.8 All persons employed on board vessels shall receive safety familiarisation training and/or instruction prior to being assigned shipboard safety, security or environmental duties.

9. Regulation 2.1 – Seafarers’ employment agreements

9.1 The duration of the seafarer’s contract of employment should not be confused with the protection of the rights to repatriation and annual leave.
9.2 There is no restriction on the length of a Seafarer’s Employment Agreement (SEA) under MLC 2006. Seafarers may enter into SEAs covering periods longer than 11 months.
9.3 MLC 2006 Standard A2.1, paragraph 4(g)(i) expressly allows SEAs for an indefinite period.
9.4 Should there be a restriction on the term of an SEA in an applicable collective bargaining agreement, such a restriction shall also be applicable to the SEA for service onboard a Barbadian vessel, provided the restriction is not in conflict with MLC 2006 regulations. However, without such a restriction, the seafarer’s ability to extend their contract beyond its expiration date or 12 months, if so desired, would not be limited, subject to mutual agreement between the seafarer and the shipowner.
9.5 Regardless of contract length, all SEAs must provide for annual leave and repatriation in accordance with MLC 2006 Standards A2.4 and A2.5, respectively.
9.6 A fixed expiry date for the length of the contract need not be indicated on a SEA (containing a start date) when a valid Collective Bargaining Agreement (CBA) with a set period (e.g., 6 months ± 1 month) of contract duration is attached. See Sec. 11 below.

10. Minimum age

10.1 No person below the minimum age of 16 years shall be employed, engaged or work on a Barbados registered vessel.
10.2 No person below the minimum age of 18 years shall be employed, engaged or work on a Barbados registered vessel in the following capacities:
.1 Master;
.2 Chief Mate;
.3 Chief Engineer;
.4 Officer In charge of a Navigational and an Engineering Watch;
.5 Electro-Technical Officer;
.6 GMDSS Radio Operator;
.7 Offshore Installation Manager;
.8 Ballast Control Operator;
.9 Barge or Maintenance Supervisor;
.10 Ship Cook.
10.3 No seafarer under the age of 18 shall work at night. For the purpose of these requirements, ‘night’ means a period of at least nine (9) hours starting no later than midnight vessel’s time and ending no earlier than 05:00 vessel’s time.
10.4 The requirement for night work may be waived where:
.1 the seafarer is engaged in a training programme that has been established by the MLC Shipowner. The training program and schedule of night time work should be documented in the Safety Management System; or
.2 the specific nature of the duty or training programme, as recognised by the BMSR, requires the performance of duties at night. The Company shall undertake a shipboard assessment which should determine that the work will not be detrimental to the health and wellbeing of the person under 18, taking into consideration the hazards outlined in the section below.
10.5 No person under the age of 18 shall be employed or engaged or work on board a vessel where the work is likely to jeopardise their health or safety. The Company shall ensure that the Shipboard Occupational Health and Safety Plan (SOHSP) specifically addresses seafarers under the age of 18, including any work or activity deemed hazardous and restrictions or training requirements for such work or activity.

11. Regulation 2.4 – Entitlement to leave

11.1 Annual leave with pay is to be calculated based on a minimum of 2.5 days per completed calendar month of employment.
11.2 MLC 2006 Standard A2.4.3 prohibits any agreement to forgo the minimum annual leave with pay, except in cases provided for by the Competent Authority. The Competent Authority in this case is the flag State.
11.3 The BMSR strictly prohibits a forfeiture of paid annual leave but does allow paid annual leave to be accumulated and taken as mutually agreed by the seafarer and shipowner as detailed in the SEA, provided the requirements for accumulating paid leave and the right of repatriation are continued and met.

12. Regulation 2.5 – Repatriation

12.1 MLC 2006 Standard A2.5.1.2(b) states that the maximum duration of service periods on board following which a seafarer is entitled to repatriation is to be less than 12 months.
12.2 The BMSR’s interpretation of Standard A2.5 is that repatriation is an absolute right and deems MLC 2006 “Guideline B2.5 – Repatriation” mandatory for ensuring the repatriation of a seafarer.

13. Collective Bargaining Agreements

13.1 As defined by MLC 2006 Article II 1.(g), a SEA includes both a contract of employment and articles of agreement.
13.2 In accordance with MLC 2006 Regulation 2.1 paragraph 3:
.1 To the extent not prohibited by the laws, regulations, and practices of the BMSR, seafarers’ employment agreements shall be understood to incorporate any applicable collective bargaining agreement. Clear information, including any labour contract, shall be made available to the crew on board every vessel as to the conditions of employment thereon.
13.3 The BMSR allows the provisions of a CBA to govern the specific conditions of employment, provided they are not in conflict with the MLC 2006 regulations.

14. MLC On-board Complaints Procedure

14.1 All seafarers shall be provided with a copy of the onboard complaint procedures applicable on the vessel. This shall include the following information:
.1 The seafarer’s right to representation;
.2 Safeguards against victimisation of the seafarer;
.3 Contact information of the BMSR or the competent labour authority in the seafarers’ country of residence; and
.4 Name of a person or persons on board the vessel who can, on a confidential basis, provide seafarers with impartial advice on their complaint and otherwise assist them in following the complaint procedures available to them on board the vessel.
14.2 The MLC Shipowner and the Master are responsible to ensure that victimisation of a seafarer for filing a labour grievance under the MLC 2006 does not occur. Any claims of victimisation should be investigated by the master or shipowner and where instances of victimisation are found to occur, these must be dealt with under the Company’s disciplinary procedures in the shortest possible time.
14.3 All complaints will be treated by BMSR in confidence and will be given serious consideration. It is however essential that the person making any complaint is identified to BMSR. BMSR will not reveal the source of its information when investigating but will not deal with any anonymous complaints.
14.4 If it is appropriate, a BMSR inspector will visit the vessel to investigate the complaint. The BMSR might also request an additional MLC inspection to be carried out by an RO surveyor to investigate the complaint and check compliance with the MLC 2006.
14.5 The complaint should be addressed to the head of the department of the seafarer lodging the complaint or to the seafarer’s supervising officer, who should attempt to resolve the matter within the prescribed time limits appropriate to the seriousness of the issues involved. The MLC Shipowner should have time limits outlined in the shipboard management system and this should take into consideration the time frame noted in Sec. 14.8 below.
14.6 If the head of department or supervising officer cannot resolve the complaint to the satisfaction of the seafarer, the seafarer may refer it to the master, who should handle the matter personally.
14.7 If a complaint cannot be resolved on board, the matter should be referred ashore to the MLC Shipowner, who should be given an appropriate time limit for resolving the matter, where appropriate, in consultation with the seafarer concerned or any person who the seafarer may appoint as their representative.
14.8 If, after twenty (20) days, conciliated settlement cannot be reached, either party shall have a further 20 days to refer the complaint to the competent labour authority, to decide upon a satisfactory solution to the matter.
14.9 If the seafarer lodges the complaint to an external authority rather than the BMSR, that authority shall be provided with the contact information of the BMSR and requested to communicate the complaint to the BMSR. Any investigation or action by an external authority should take into account the extent to which the on-board complaint procedure has been utilised, and its effectiveness in dealing with the complaint.
14.10 If the seafarer is in any doubt about presenting a complaint and considers that they will be victimised due to presenting a complaint, they shall have the right to contact the BMSR for guidance or they may submit the complaint directly to the BMSR at any time.

 

Revision History

Revision No Description Of Revision
1.0 First Issue – supersedes information bulletin 219/296/303/343/341/330
   
   
   
   
   
   

 

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Bulletin 009 – Inventory of Hazardous Materials Rev 1.0

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

 

1. References

a) Hong Kong Convention, Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009.
b) EU SRR, Regulation (EU) No 1257/2013 of the European Parliament and of the Council on ship recycling.
c) EMSA Guidance on inspections of ships by the port States in accordance with Regulation (EU) 1257/2013 on ship recycling.

2. Purpose

2.1 This Bulletin provides instructions on the issue of Statements of Compliance (SoC) on Inventory of Hazardous Materials (IHM) under the Hong Kong Convention and the European Union (EU) EU SRR.

3. Application

3.1 This Bulletin applies to any ship requesting a SoC for IHM or EU SRR.

4. General – IHM

4.1 Both the EU SRR and the Hong Kong Convention require vessels to develop and maintain an IHM and undergo survey and certification to verify that the requirements are met.

4.2 A Barbadian vessel can be issued with a SoC by one of the Barbados Recognised Organisations (RO) after satisfactory initial survey including verification that the IHM Part I meets the relevant requirements.

4.3 The IHM shall be vessel specific and shall identify, as a minimum, the hazardous materials listed in Appendix I of the Hong Kong Convention or Annex I of the EU SRR, as appropriate.

4.4 The IHM shall be properly maintained and updated throughout the vessel’s operational life. It must reflect new installations that contain hazardous materials referred to in Appendix II of the Hong Kong Convention or Annex II of the EU SRR, as appropriate, and relevant changes in the vessel’s structure and equipment, taking into account the exemptions and transitional arrangements applicable to those materials under international law.

5. Hong Kong Convention

5.1 The Hong Kong Convention was adopted in 2009 and will enter into force on 26 June 2025.

5.2 Barbados is not a signatory to the Hong Kong Convention, but Barbados ROs are authorised to survey ships and issue voluntary SoC on behalf of Barbados when requested by the managers.

5.3 Vessels are to be surveyed in accordance with Regulation 10 of the Hong Kong Convention and a SoC may be issued following an initial or renewal survey. The renewal survey shall take place at intervals not exceeding five years.

5.4 The issuance and endorsement of the SoC shall be in accordance with Regulation 11 of the Hong Kong Convention and the SoC shall be based on the format of the International Certificate specified in Appendix 3 of the Hong Kong Convention.

5.5 An additional survey may be conducted at the request of the shipowner to ensure that any change, replacement, or significant repair made to the structure, equipment, systems, fittings, arrangements, and material continues to comply with the Convention requirements.

5.6 A final survey shall be conducted prior to the ship being taken out of service and before the recycling of the ship has started, except for existing vessels for which both an initial survey and a final survey are conducted at the same time.

6. EU SRR

6.1 Article 12 of the EU SRR requires vessels flying the flag of a non-EU Member State, when calling at a port or anchorage of an EU Member State, to have on board a SoC and IHM from 31 December 2020.

6.2 Barbados ROs are authorised to survey ships and issue voluntary SoC on behalf of Barbados when requested by the managers.

6.3 A vessel flying the flag of a third country may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of an EU Member State in the event that it fails to submit to the relevant authorities of that Member State a copy of the Statement of Compliance in accordance with paragraphs 6 and 7 of Article 12 of EU SRR, together with the IHM, as appropriate and on request from those authorities.

6.4 Failure to update the IHM shall not constitute a detainable deficiency, but any inconsistencies in the IHM will be reported to the BMSR by the Member State.

6.5 The EU SRR does not establish a period of validity for the SoC, unless so specified by the flag State. The BMSR requires the validity of SoC of EU SRR to have a five-year validity in line with the IHM of Hong Kong Convention. Therefore initial, renewal and additional surveys, as applicable, will need to be conducted for Barbadian vessels under the EU SRR.

6.6 The SoC shall be in the format specified in Annex 3 of the EMSA Guidance on inspections of ships by the port States.

Revision History

Revision No Description Of Revision
1.0 First Issue – Supersedes Information Bulletin 299 and 333
   
   
   
   
   
   

 

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The PR/CEO Mr. G. Ciniglio and Technical Officer Mr. R. Goodall have attended MAIIF30 held at IMO in London on the 9-13th of October 2023.

The PR/CEO Mr. Ciniglio and TO Mr. R. Goodall have attended MAIIF30 held at IMO in London on the 9-13th of October 2023.

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