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

1. References

• a) International Telecommunication Union Convention (ITU Convention);
• b) ITU-T Recommendation D.90 (ITU D.90);
• c) Form 144 – Application for Radio Accounting Authority Acting on Behalf of Barbados;
• d) Maritime Service Activation Registration Form (SARF);
• e) Maritime mobile Access and Retrieval System (MARS).

2. Purpose

• 2.1 This Bulletin explains:
• .1 the radio message accounting procedures required by Barbados Maritime Ship Registry (BMSR) and the lists of the Radio Accounting Authorities (RAAs) approved by the BMSR .
• .2 the procedures required by the Point of Service Activation (PSA) to activate, deactivate, and update information regarding Inmarsat Mobile Earth Stations (MESs) on Barbadian vessels;
• .3 the procedures to obtain Maritime Mobile Service Identity (MMSI) numbers and Call Signs for Barbadian vessels.

3. Application

• 3.1 This Bulletin applies to all Barbadian vessels:
• .1 Equipped with a Radio Ship Station;
• .2 Installed, or will be, with an Inmarsat MESs.

4. RAA Requirements

• 4.1 The ITU Convention currently in force provides for RAAs to settle maritime radiocommunication accounts for ships licensed by the BMSR.

• 4.2 Due to the many problems occurring in international radio maritime accounting, no ship is entitled to be registered or to maintain registration under the Barbados flag unless the owner shall have entered into a valid contract with an authorized radio service company pursuant to the terms of which the latter assumes the accounting obligation and may assume responsibility for obtaining the vessel’s Radio Ship Station License (SSL).

• 4.3 It is mandatory that all international maritime radio traffic charges for radiocommunications from ship to shore, both terrestrial and satellite, shall be settled by the approved RAA pursuant to the contract with the owner of the vessel.

• 4.4 Application for RAA on behalf of the BMSR shall be submitted with Form 144, which is to be sent to registry@barbadosmaritime.com.

• 4.5 The ITU D.90 limits the number of RAAs based in other countries that the BMSR may recognize to 25. The RAAs approved by the BMSR are listed in section 4 below.

• 4.6 The RAA shall notify the BMSR of the vessels for which it has assumed full responsibility for the payment of the radiocommunication incurred through its maritime mobile station, ensuring, as required by the ITU Convention, that these payments are made in accordance with the ITU D.90 and will not accrue to the account of the Barbados Government. It is imperative that all radio traffic charges be sent to the RAA only and not to any third party.

5. List of RAAs

#	AAIC	RAA Name
1	AA07	Sratos Global Corporation
2	BE02	Marlink S.A.
3	CA03	Inmarasat Inc.
4	CY03	Telaccount Overseas Ltd.
5	CY05	Tototheo Maritime Ltd.
6	DP03	Marlink GmbH
7	DP05	SPEEDCAST GERMANY GMBH
8	GB01	A-N-D Group PLC
9	GB06	SIRM UK Marine Limited
10	GB08	SIRM UK Marine Limited
11	GB11	NSSLGlobal, Airtime Billing Department
12	GB14	Inmarsat Global Limited
13	GR01	OTESAT-Maritel
14	GR03	HECOSAR, Accounts Settlement for mobile and mobile-satellite
15	KE01	Communication Authority of Kenya
16	LE01	MURR Marine Electronics S.A.R.L.
17	NL01	Stratos B.V.
18	NO01	Marlink AS
19	PG18	BRIGHTNORTH CORP.
20	PG19	RADIO LLOYD, S.A.
21	SW01	Telemar Scandinavia B
22	UX02	SE MSRS

• 5.1 AAIC, means Accounting Authority Identification Code.

• 5.2 The Barbados RAAs Particulars can be retrieved on MARS by selecting Administration “BRB – Barbados” and pressing “submit query”.

6. PSA Requirements

• 6.1 Inmarsat is the internationally recognized body that sets the rules and oversees “service activation” or formal registration/re-registration of MES for all vessels. Deactivation and reregistration/activation of equipment must take place when a vessel changes Flag, changes owner or when changes occur with the equipment. In order to effect the change, the terminals must first be deactivated by the former PSA that activated the equipment.

• 6.2 A PSA is an entity authorized by Inmarsat to accept and process for Barbadian vessels applications for MES service activation, assign Inmarsat Mobile Numbers and transmit customer service activation information to the Inmarsat Customer Activation group.

• 6.3 In many cases, the PSA will also be the RAA or Inmarsat Service Provider (ISP) for the terminal, and works directly with the customer on service activation, in particular, and Inmarsat systems and services in general.

• 6.4 Any enquiries related to commissioning or decommissioning of Inmarsat terminals should be addressed to the PSA or Inmarsat.

• 6.5 To obtain the authorisation to activate the MES, the SARF, which is to be completed and signed by the owner of the MES who will ultimately be responsible for the payment of traffic charges incurred by the MES, is to be submitted either directly to the PSA or to the ISP. If applying for more than one MES, the customer must prepare separate SARFs for each MES to be activated. For further information on PSAs and ISPs please contact the Inmarsat Global Customer Support at the following address:
• Inmarsat Global Customer Support
• Inmarsat Global Limited
• 99 City Road
• London EC1Y 1AX,
• United Kingdom
• Telephone +44 207 728 1020/1777
• Email address: globalcustomersupport@inmarsat.com

• 6.6 It is imperative that this procedure be understood and followed by the PSA, shipowner, and ship operator so that registration/deregistration of systems may be quickly accomplished for Long Range Identification and Tracking (LRIT) compliance.

• 6.7 PSA shall inform the BMSR of all additions, deletions, and modifications to BMSR MESs as quickly as possible with a change of flag by email to registry@barbadosmaritime.com.

• 6.8 The PSAs authorised by Inmarsat can be obtained by contacting Inmarsat Global Customer Support above.

7. MMSI numbers and Call Sign

• 7.1 A MMSI is effectively an international maritime telephone number issued by the BMSR.

• 7.2 The BMSR continues to allocate MMSI numbers and Call Signs to Barbados vessels on behalf of the Barbados Ministry of Industry, Innovation, Science and Technology (MIST).

• 7.3 The Call Signs are allocated based on the guidelines of the ITU Convention – Radio Regulations Article 19.54 -19.56. The BMSR assigns Call Signs with one digits and 3 letters in the order: digit – letter- letter – letter – digit

• 7.4 Any enquiries related to MMSI numbers should be addressed to the BMSR registration department at registry@barbadosmaritime.com.

Revision History

Version	Description of Revision
1.0	New Issue.

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

1. References

• a) Guidelines for the Use of Electronic Certificates – FAL.5/Circ.39/Rev.2.

2. Purpose

• 2.1 This Bulletin establishes the requirements for electronic documents issued by the BMSR. It contains information for their features, conveyance, and verification.

• 2.2 All electronic certificates issued, in compliance with the IMO Facilitation Committee FAL.5/Circ.39, by the BMSR or by a Barbados Recognised Organisation (RO) shall be deemed valid in accordance with all applicable international conventions and instruments to which Barbados is a Party.

• 2.3 A copy of this Bulletin should be placed on board Barbadian vessels to facilitate the acceptance of electronic certificates by other relevant authorities.

3. RO Statutory Certificates

• 3.1 Several ROs are now able to issue electronic certificates to ships in lieu of traditional paper certificates.

• 3.2 The use of electronic certificates is accepted by the BMRS, provided that are issued in compliance with the provisions of FAL.5/Circ.39.

4. BMSR Documents

• 4.1 The BMSR has now moved to full implementation of electronic documents for vessel certificates and seafarers’ documents.

• 4.2 The electronic documents issued by the BMSR contain all elements required by FAL.5/Circ.39.

• 4.3 Original hardcopy documents issued by the BMSR shall remain valid (up until the indicated expiry date) and be carried on board until they have been reissued electronically or otherwise superseded, and the new electronic certificates are available on board.

• 4.4 Hard copy documents may be issued in exceptional circumstances and may have either a manual signature or a scanned signature printed on the document. Paper documents are generally printed on BMSR headed paper (with the exception of Certificates of Inspection).

• 4.5 All documents and certificates issued electronically by the BMSR must be able to be viewed and printed out onboard the vessel when required.

• 4.6 Electronic documents are issued in Portable Document Format (PDF), and a suitable PDF viewer, such as Adobe Reader, or similar, is required to view and print the electronic documents.

• 4.7 Adobe Reader can be downloaded free of charge from www.Adobe.com.

5. List of Electronic Documents issued

• 5.1 Provisional Certificate of Registry (COR).

• 5.2 Permanent Certificate of Registry (COR).

• 5.3 Carving and Marking Note (CMN).

• 5.4 Maritime Labour Certificate (MLC).

• 5.5 Declaration of Maritime Labour Compliance (DMLC I).

• 5.6 Safe Manning Document (SMD).

• 5.7 Continuous Synopsis Record (CSR).

• 5.8 Ship Station Licence (SSL).

• 5.9 Certificate of Insurance for Civil liability for bunker oil pollution damage (Bunker Certificate).

• 5.10 Certificate of Insurance for Civil liability for oil pollution damage (CLC Certificate).

• 5.11 Certificate of Insurance or other financial security in respect of liability for the death of and personal injury to passengers (Athens Convention Certificate).

• 5.12 Exemptions and Dispensations (Permits).

• 5.13 Barbadian Authorisation of Service Prover (BASP).

• 5.14 Transcript.

• 5.15 Officer Certificate of Receipt of Application (CRA).

• 5.16 Officer Endorsements.

• 5.17 The lists above is not exhausted of all electronic documents issued by the BMSR.

6. BMSR Document Validation

• 6.1 Electronic documents either in printed or electronic form may be verified online in two ways:
• 1. by using the Quick Response (QR) Code found in in the bottom right-hand corner; or
• 2. via the online BMSR Portal.

• 6.2 For the validation of an electronic document the Document Control Number (DCN) is located in the bottom of the document.

• 6.3 Once the DCN has been entered, the “Document Authenticity Checked” page shows the details of the vessel or seafarer and on the bottom of the page the “Document Expiry Date” (if applicable) and the “Document Validity.”

• 6.4 Queries regarding the validation of electronic documents may be addressed to registry@barbadosmaritime.com.

7. BMSR Document Validity

• 7.1 When a document or a vessel is deleted from the registry, the validation of the electronic documents gives “VALIDATION FAILED: Barcode for that document type does not exist in our system.”

• 7.2 When a vessel is suspended from the registry the electronic documents still remain valid unless they have been deleted.

• 7.3 Withdrawn and expired electronic documents “Document Validity” reads “Superseded”.

Revision History

Version	Description of Revision
1.0	Supersedes Bulletin 336 & 342

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

1. References

• a) International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS); Fire Safety Systems (FSS) Code;
• b) IMO Circular MSC.1/Circ.1432 Revised Guidelines on maintenance and inspection of fire protection systems and appliances;
• c) IMO Circular MSC.1/Circ.1318/Rev.1 Revised Guidelines for the maintenance and inspections of fixed carbon dioxide fire-extinguishing systems;
• d) IMO Circular MSC.1/Circ.1318/Rev.1 Revised Guidelines for the maintenance and inspections of fixed carbon dioxide fire-extinguishing systems;
• e) IMO Assembly Resolution A.951(23) Improved Guidelines for Maintenance for Marine Portable Fire Extinguishers;
• f) IMO Assembly Resolution A.1156(32) Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2021;
• g) IMO Circular MSC/Circ.775 – Ships with Reduced Halon Quantities;
• h) The International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code);
• i) IMO Circular MSC.1/Circ.1275 Unified interpretation of SOLAS chapter II-2 on the number and arrangement of portable fire extinguishers on board ships, as corrected by MSC.1/Circ.1275/Corr.1;
• j) IMO Circular MSC/Circ.1002 Guidelines on alternative design and arrangements for fire safety, as corrected.
• k) IMO Circular MSC.1/Circ.1395/Rev.4 Lists of solid bulk cargoes for which a fixed gas fire- extinguishing system may be exempted or for which a fixed gas fire-extinguishing system is ineffective;
• l) IMO Circular MSC/Circ.670 Guidelines for the performance and testing criteria and surveys of high-expansion foam concentrates for fixed fire-extinguishing systems;
• m) IMO Circular MSC/Circ.798 Guidelines for the performance and testing criteria and surveys of medium-expansion foam concentrates for fire-extinguishing systems;
• n) IMO Circular MSC.1/Circ.1312 Revised guidelines for the performance and testing criteria, and surveys of foam concentrates for fixed fire-extinguishing systems, as corrected by MSC.1/Circ.1312/Corr.1;
• o) IMO Circular MSC.1/Circ.1555 Unified interpretation of SOLAS chapter II-2;
• p) IMO Circular MSC/Circ.1081 Unified interpretation of the Revised SOLAS chapter II-2;
• q) IMO Circular MSC/Circ.849 Guidelines for the performance, location, use and care of emergency escape breathing devices (EEBDs);
• r) IMO Resolution MEPC.269(68) 2015 Guidelines for the Development of the Inventory of Hazardous Materials.

2. Purpose

• 2.1 This   Bulletin        provides      instructions for     inspection,   maintenance,        testing          and    survey requirements of fire protection systems, appliances, and equipment.
• 2.2 The maintenance and inspection provisions for fixed carbon dioxide (CO2) fire-extinguishing systems reflects the latest requirements of MSC.1/Circ.1318/Rev.1.

3. Application

• 3.1 This Bulletin applies to all Barbadian vessels, except pleasure yachts.

4. Operational Readiness and Temporary Permits

• 4.1 All fire protection systems and appliances must be in good order and available for immediate use while the vessel is in service.
• 4.2 If a fire protection system is under maintenance, testing, repair, or not working, then the ISM Mangers have to provide suitable arrangements to ensure fire protection capability is not diminished by providing alternative fixed or portable fire protection equipment or other measures. The ISM Managers must request a Temporary Permit at ops@barbadosmaritime.com while the vessel is underway, or before it sails.

5. Onboard Maintenance and Competent Persons

• 5.1 As per MSC.1/Circ.1432 and MSC.1/Circ.1318/Rev.1, certain maintenance procedures and inspections may be performed by competent crew members who have completed an advanced fire-fighting training course meeting the requirements of Section A-VI/3 of the STCW code, while others should be performed by persons specially trained in the maintenance of such systems. The onboard maintenance plan should indicate which parts of the recommended inspections and maintenance are to be completed by trained personnel.
• 5.2 For the purpose of section 5.1, a “competent person” is defined as someone who has achieved a level of technical skill (incorporating theoretical knowledge and practical experience) to be able to complete a task or activity safely and to the specified standard. The ISM Managers 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.
• 5.3 Onboard maintenance and inspections are to be carried out in accordance with the vessel’s maintenance plan, which should include the minimum elements listed in sections 4 to 10 of MSC.1/Circ.1432.

6. Specific Requirements for Fire Detection Systems

• 6.1 As per MSC.1/Circ.1432 sample of fire detectors and manual call points should be tested monthly, so that all devices have been tested at least once every 5 years.
• 6.2 Testing of manual call-points should be conducted at the same time as the detector tests.
• 6.3 The monthly testing schedule is be prepared such that alternative detectors are physically tested at every monthly test. Remaining detectors must still to be visually inspected and/or tested with internal electronic self-test function, where provided.
• 6.4 For very large systems (1,000+ detectors), at least one detector should be physically tested in each large compartment, or one detector tested within several smaller compartments in the same locality within the same fire zone (e.g., multiple sleeping rooms on the same side of the ship located on the same deck and within the same fire zone). Whilst undertaking testing, all accessible detectors should be visually inspected for evidence of tampering, obstruction, etc.
• 6.5 At least one detector located along each cable line of the fire detection system and within each fire zone should be tested.
• 6.6 Where a fire detection system operating on an atmosphere sample extraction principal is installed the entire system should be physically tested every month. Where a ship fitted with such fire detection system undertakes laden voyages of longer than 1 month, the sample extraction fire detection system covering cargo compartments should be tested before loading cargo.

7. Specific Requirements for Fixed Gas Fire-Extinguishing Systems

• 7.1 Fixed gas fire-extinguishing systems have to be carefully and critically reviewed, routinely inspected, and maintained, verified, and tested to ensure that they will correctly operate during an emergency.
• 7.1 Monthly and annual inspections are to be carried out as per MSC.1/Circ.1432.
• 7.2 Flexible hoses have to be replaced at the intervals recommended by the manufacturer and in any case at intervals not exceeding 10 years.
• 7.3 Flexible hoses have to be replaced at the intervals recommended by the manufacturer and in any case at intervals not exceeding 10 years.
• 7.4 Every two years (during the second or third periodical survey), fixed gas fire-extinguishing systems, except fixed carbon dioxide (CO2) extinguishing systems (see section 8 below), have to be checked by an authorised service facility acceptable to the vessel’s RO.
• 7.5 Every two years all high-pressure extinguishing agents, cylinders, and pilot cylinders have to be weighed or have their contents verified by other reliable means to confirm that the available charge in each is above 95% of the nominal charge. Cylinders containing less than 95% of the nominal charge have to be refilled.
• 7.6 Every year, blow dry compressed air or nitrogen through the discharge piping or otherwise confirm the pipe work and nozzles are clear of any obstructions. This may require the removal of nozzles, if applicable.
• 7.7 At least once every 10 years, a hydrostatic test and internal examination of 10% of the system’s extinguishing agent and pilot cylinders has to be conducted. If one or more cylinders fail, a total of 50% of the onboard cylinders have to be tested. If further cylinders fail, all cylinders have to be tested.
• 7.8 With cylinders for fixed-gas fire-fighting systems (except Halon) that have been date stamped before vessel delivery, the first 10-year hydrostatic test may be harmonized with drydocking at the second renewal survey under the HSSC. This is contingent on the initial date stamp (month/year) on the cylinder not exceeding 12 months before the vessel delivery date.

8. Specific Requirements for Fixed CO2 Systems

• 8.1 Monthly and annual inspections are to be carried out as per MSC.1/Circ.1318/Rev.1.
• 8.2 At least once in every 5-year period, control valves of fixed CO2 systems are to be internally examined to ensure they can operate freely.
• 8.3 At least biennially (at intervals of 2 years ± 3 months) in passenger ships, or at each intermediate, periodical or renewal survey (as per HSSC) in cargo ships, the following maintenance is be carried out (to assist in carrying out the recommended maintenance, examples of service charts are set out in the appendix of MSC.1/Circ.1318/Rev.1):
  • .1 all high-pressure cylinders and pilot cylinders must be weighed or have their contents verified by other reliable means to confirm that the available charge in each is above 90% of the nominal charge. Cylinders containing less than 90% of the nominal charge should be refilled. The liquid level of low-pressure storage tanks must be checked to verify that the required amount of carbon dioxide to protect the largest hazard is available;
  • .2 the hydrostatic test date of all storage containers must be checked. High-pressure cylinders and pilot cylinders should be subjected to periodical tests at intervals not exceeding 10 years. At the 10-year inspection, at least 10% of the total number provided must be subjected to an internal inspection and hydrostatic test. If one or more cylinders fail, a total of 50% of the onboard cylinders must be tested. If further cylinders fail, all cylinders must be tested. Before the 20-year anniversary and every 10-year anniversary thereafter, all cylinders must be subjected to a hydrostatic test. Flexible hoses must be replaced at the intervals recommended by the manufacturer and not exceeding every 10 years. When cylinders are removed for testing, the cylinders must be replaced such that the quantity of fire-extinguishing medium continues to satisfy the requirements of 2.2.1 of chapter 5 of the (FSS) Code, subject to SOLAS regulation II-2/14.2; and
  • the discharge piping and nozzles must be tested to verify that they are not blocked. The test should be performed by isolating the discharge piping from the system and blowing dry air or nitrogen from test cylinders or suitable means through the piping.
• 8.4 For the purpose of section 8.3.2 above, the BMSR interprets MSC.1/Circ.1318/Rev.1 as follows:
  • .1 at the 10-year anniversary of the initial hydrotest, 10% of all CO2 cylinders are to be hydrotested. If one or more cylinders fail, a total of 50% of the onboard cylinders must be tested. If further cylinders fail, all cylinders must be tested;
  • .2 prior to the 20-year anniversary of the initial hydrotest, all CO2 cylinders are to be hydrotested, however cylinders tested satisfactorily at the 10-year anniversary need not be tested;
  • .3 at every 10-year anniversary thereafter, all CO2 cylinders are to be hydrotested.
• 8.5 For vessels aged between 20 and 30 years as of May 2021, all CO2 cylinders have to be hydrotested at the first drydock.
• 8.6 The ISM Managers can request a Temporary Permit from the BMSR to allow all hydrotests to be completed at the same time. Applications for the permit is to be submitted to BMSR at ops@barbadosmaritime.com by the ISM Managers and include:
  • .1 The reason for not completing the hydrotest at 20 years;
  • .2 The proposed testing schedule, which should ensure that all cylinders are hydrotested at the earliest opportunity, taking into account the vessel’s operations;
  • .3 Most recent service reports for the untested cylinders, including content check (by weighing or ultrasonic level detection);
  • .4 A statement from the Master attesting to the condition of the untested CO2 cylinders.
• 8.7 The above provisions apply equally to ships using a low-pressure high volume refrigerated vessel for liquified CO2 storage.
• 8.8 At least biennially (intervals of 2 years ± 3 months) in passenger ships or at each renewal survey in cargo ships, the following maintenance should be carried out by service technicians/ specialists:
  • .1 where possible, all activating heads should be removed from the cylinder valves and tested for correct functioning by applying full working pressure through the pilot lines. In cases where this is not possible, pilot lines should be disconnected from the cylinder valves and blanked off or connected together and tested with full working pressure from the release station and checked for leakage. In both cases this should be carried out from one or more release stations when installed. If manual pull cables operate the remote release controls, they should be checked to verify the cables and corner pulleys are in good condition and freely move and do not require an excessive amount of travel to activate the system;
  • .2 all cable components should be cleaned and adjusted as necessary, and the cable connectors should be properly tightened. If the remote release controls are operated by pneumatic pressure, the tubing should be checked for leakage, and the proper charge of the remote releasing station pilot gas cylinders should be verified. All controls and warning devices should function normally, and the time delay, if fitted should prevent the discharge of gas for the required time period; and
  • .3 after completion of the work, the system should be returned to service. All releasing controls should be verified in the proper position and connected to the correct control valves. All pressure switch interlocks should be reset and returned to service. All stop valves should be in the closed position.

9. Specific Requirements for Halon Gas Systems

• 9.1 In accordance with Regulation of SOLAS II-2/10.4.1.3, fire extinguishing systems using Halon 1211, Halon 1301, Halon 2402, and perfluorocarbons are prohibited on all new buildings and on new installations on existing vessels.
• 9.2 In an existing installation and in the event of the discharge or loss of pressure of Halon gas cylinder(s), the BMSR might accept the replenishment of the discharged cylinder(s), if they remain in satisfactory condition.
• 9.3 The contents of the Halon cylinders should be weighed or have their contents verified by other reliable means at least every two years, plus or minus three months, as part of the survey for issuing the SOLAS Safety Equipment Certificate (SEC). This is to confirm that the available charge in each is above 95% of the nominal charge as far as reasonably practicable, as determined by the BMSR. Cylinders with less than 95% of the nominal charge should be refilled.
• 9.4 All Halon cylinders have to be hydrostatically tested:
  • .1 after each 20 years of service;
  • .2 before recharging a discharged cylinder; or
  • .3 when visual inspection reveals a potential defect.
• 9.5 Hydrostatic test dates have to be stamped on the cylinders. Hydrostatic testing have to be performed by an authorised servicing facility certified by a government agency or RO. The facility must be acceptable to the attending RO surveyor. The same facility should recharge the cylinders after testing to demonstrate their serviceability.
• 9.6 Visual inspection and non-destructive testing (NDT) of Halon cylinders may be performed instead of hydrostatic testing by an authorised servicing facility which has been certified by a government agency or RO.
• 9.7 The safety of the vessel and its crew remains paramount and if Halon gas is not readily available, the ISM Managers have to ensure that the affected space has adequate temporary firefighting capability prior to departure from port.
• 9.8 The adequacy of any temporary arrangements and procedures is to be assessed by the RO prior to application for acceptance by the BMSR.
• 9.9 Application for acceptance of any temporary arrangements is to be made to the BMSR by the RO and, as per MSC/Circ.775, shall establish procedure to enable the ship to safely depart the port, call at specified ports for discharge or loading of cargo, and arrive at the port for rectification of the deficiency. Where, such a procedure should specify the “port and date of departure”, the “port of rectification of the deficiency”, the “maximum duration of the voyage” and the “ports of call and operations approved en route”.
• 9.10 There is currently no internationally agreed date for the phasing out of Halon gas in existing installations, however there may be local or regional regulations that impose restrictions on the use and/or phase out of Halon. The BMSR recommends that ISM Managers of affected Barbadian ships make themselves aware of any restrictions that may be applied by the country or region in which the ship is trading.
• 9.11 ISM Managers operating ships with existing Halon systems should note that the worldwide stock of Halon is diminishing, and it is strongly recommended that a plan is implemented for the replacement the Halon system on board.
• 9.12 It should be further noted that where Halon replenishment is not permitted by the country or region in which the ship is operating, the ship may be detained and/or prohibited from leaving port until a new fixed firefighting system is installed.
• 9.13 Details of any proposed replacement of a system containing Halon must be forwarded to the BMSR for review by the RO.
• 9.14 As per MEPC.269(68), the Halons are Ozone Depleting Substances (ODS) and the Supplement to the International Air Pollution Prevention Certificate may identify the presence of onboard. The ODS Record Book must be kept up to date and may form part of an existing logbook or electronic record book.

Specific Requirements for Fixed Dry Chemical Powder Fire-Extinguishing Systems

• 10.1 Monthly and annual inspections are to be carried out as per MSC.1/Circ.1432.
• 10.2Every 10 years fixed dry chemical powder fire-extinguishing systems have to be serviced and tested in accordance with the manufacturer’s and the RO’s requirements. Particular attention must be paid to the powder condition for any signs of moisture ingress and that its properties remain as per the type approval.
• 10.3 In accordance with MSC.1/Circ.1432, two-yearly inspections have to be carried out on fixed, dry chemical powder systems by an authorised service facility acceptable to the vessel’s RO or the attending RO surveyor(s), who have to perform a general distribution piping and installation examination of the dry chemical powder fire-extinguishing system to confirm, to the extent possible, that the system has not been modified from its original installation.
• 10.4 This verification should also include the following minimum requirements:
  • .1 the piping distribution system have to be blown through with nitrogen (N2) or dry air to ensure it is free of any obstruction. The nozzles, if any, have to be removed to ensure that they are free and not blocked during the blow-through operation;
  • .2 operational testing of local and remote controls and section valves;
  • .3 the contents verification of propellant gas cylinders containing N2, including remote operating stations, must be confirmed;
  • .4 flexible discharge hoses have to be inspected to confirm that they are maintained in good condition and have not perished, especially when located on open decks. In case of any doubt, the hoses have to be subjected to a full working pressure test;
  • .5 the dry chemical powder containment tank and its associate safety valves have to be inspected for signs of corrosion or deterioration which may affect the safety of the system. In case of any doubt, the tank has to be tested, and safety valve set points adjusted and confirmed by the authorised service facility.

11. Specific Requirements for Alternative Fixed Gas Firefighting Media

• 11.1 Alternative firefighting systems referred in Chapter II-2 of SOLAS and the IGC Code for protection of machinery and accommodation spaces, pump rooms and cargo spaces may be fitted on board, subject to the approval, including any attached conditions, of a Barbados RO or a SOLAS contracting Government in accordance with the requirements for alternative fire- fighting systems and relevant guidance stated in IMO Circular MSC/Circ.1002. The BMSR must receive prior notification of intention to fit an alternative system which has not been previously accepted by the BMSR.
• 11.2 The BMSR accepts the use of (non-asphyxiating) fire extinguishing agents in machinery spaces for which no specific provisions for fire-extinguishing appliances are prescribed under the provisions of Chapter II-2 of SOLAS, (such as “NovecTM 1230” fluid, INERGEN, FM 200, etc.). Acceptance of such agents is subject to conditions, agreed on a case-by-case basis, appropriate to the space in question and provided that the space is not connected to an accommodation space.

12. Specific Requirements for Alternatives to Ineffective Fixed Gas Firefighting Systems

• 12.1 Water supplies as defined in SOLAS Regulation II-2/19.3.1.2 are considered an alternative for the ineffective fixed gas fire-extinguishing system, when ships are allowed to carry cargoes contained in MSC.1/Circ.1395/Rev.4, Table 2. Such an arrangement has to be verified for compliance by the vessel’s RO.

13. Specific Requirements for Foam Concentrates: Fixed Fire-Extinguishing Systems and Portable Applications

• 13.1 The first periodical control for foam concentrates (except protein-based, alcohol-resistant ones) should be performed not more than three years after being supplied to the ship, and after that, every year. These tests should be conducted by laboratories or authorised service suppliers acceptable to the RO.
• 13.2 Protein-based, alcohol-resistant foam concentrates should be subjected to a chemical stability test before delivery to the vessel and annually thereafter.
• 13.3 Guidance on performance and testing criteria and surveys of low, medium, and high-expansion concentrates for fixed fire-extinguishing systems are found in IMO Circulars MSC/Circ.670, MSC/Circ.798, and MSC.1/Circ.1312.
• 14.4 In accordance with MSC.1/Circ.1432 portable containers or portable tanks containing foam concentrate (excluding protein-based ones), less than 10 years old, that remain factory sealed, may normally be accepted without carrying out the periodical foam control tests referred to in MSC.1/Circ.1312.
• 13.5 Protein-based foam concentrate portable containers and portable tanks have to be thoroughly checked. If more than five years old, the foam concentrate has to be given the periodical foam control tests required or renewed, as referred to in MSC.1/Circ.1312.

14. Specific Requirements for Portable Fire Extinguishers and Spare Charges

• 14.1 All portable fire extinguishers have to be periodically inspected in accordance with the manufacturer’s instructions.
• 14.2 Where recharged on board, all portable fire extinguishers should be provided with a visual discharge indicator. The manufacturer’s instructions for recharging should be available onboard.
• 14.3 All portable fire extinguishers must be serviced at intervals not exceeding one year.
• 14.4 At least one extinguisher of each type, manufactured in the same year and kept on board a ship, should be test discharged at five-year intervals as part of a fire drill.
• 14.5 All fire extinguishers, together with propellant cartridges, must be hydrostatically tested in accordance with the recognized standard or the manufacturer’s instructions at intervals not exceeding 10 years.
• 14.6 A hydrostatic test may be also required by the RO Surveyor or BMSR Appointed Nautical Inspector (ANI) if visual examination indicates a potential defect in the cylinder.
• 14.7 Service and inspection should only be undertaken by, or under the supervision of, a person with demonstrable competence, based upon the inspection guide in A.951(23) (Table 9.1.3).
• 14.8 The hydrostatic test date must be permanently and clearly marked on the bottles.
• 14.9 The servicing facility performing the hydrostatic tests have to
  • .1 be: certified by a government agency or an RO; and
  • .2 accepted by the vessel’s RO or the extinguisher manufacturer
• 14.10 The same facility should recharge the cylinder after testing to demonstrate serviceability.
• 14.11 The number of portable fire extinguishers on board should be determined as follows:
  • .1 Vessels built prior to 01 January 2009 – the number of portable fire extinguishers provided is to satisfy the requirements of the relevant Classification Society. In accommodation spaces, service spaces and control stations on vessels of 1,000 gross tonnage and upwards, no less than five (5) portable fire extinguishers are to be provided. ISM Managers are encouraged to apply the provisions of MSC.1/Circ.1275 where practicable.
  • .2 Vessels built on or after 01 January 2009 – the number of portable fire extinguishers to be provided should be determined in accordance with MSC.1/Circ.1275. In accommodation spaces, service spaces and control stations on ships of 1,000 gross tonnage and upwards, no less than five (5) portable fire extinguishers are to be provided.
• 14.12 The minimum number of spare charges carried on board for portable & semi-portable extinguishers shall be in accordance with SOLAS Chapter II-2, namely:
  • .1 100% for the first ten (10) extinguishers; and
  • .2 50% for the remaining extinguishers up to a maximum of sixty (60).
• 14.13 Additional extinguishers of the same type and capacity shall be carried in lieu of spare charges for any extinguishers which cannot be charged on board.

15. Specific Requirements for Ten-Year Servicing: Water Mist, Water Spray, and Sprinkler Systems

• 15.1 The hydrostatic test and internal examination for gas and water pressure cylinders has to be conducted in accordance with EN 1968:2002+A1, Transportable Gas Cylinders – Periodic Inspection and Testing of Seamless Steel Gas Cylinders, or equivalent RO requirements. See also section 7.8 above of this Bulletin about harmonization with drydocking.

16. Specific Requirements for Self-Contained Breathing Apparatus

• 16.1 Self-Contained Breathing Apparatus (SCBA) Cylinders should be inspected weekly to ensure that they are in the correct pressure range.
• 16.2 A responsible ship’s officer must inspect SCBAs at least once a month.
• 16.3 All SCBAs and their onboard means of recharging (if fitted) have to be inspected and tested at least annually by competent crew members unless manufacturers require annual servicing by an authorised agent.
• 16.4 The tests and examinations required by the HSSC must be carried out in the presence of an RO surveyor.
• 16.5 Hydrostatic testing of SCBA cylinders has to be carried out once every five years.
  • .1 Where: the hydrostatic test date must be permanently marked on the bottles;
  • .2 intervals for hydrostatically testing cylinders of the ultra-lightweight type may vary and will depend upon the requirements of the cylinder manufacturer and the ship’s RO.
  • .3 cylinder servicing has to be performed to the satisfaction of the RO surveyor.
• 16.6 In cases where SCBA cylinders have been date stamped before a vessel’s delivery, the first five-year hydrostatic test may be harmonised with drydocking at the First Special Survey under the HSSC. This is possible provided that the initial date stamp (month/year) on the cylinder is not more than six months before the vessel delivery date.
• 16.7 Two interchangeable spare charges suitable for SCBA use have to be provided for each required apparatus.
• 16.8 In accordance with SOLAS II-2/10, only one interchangeable spare charge is needed for each required apparatus on passenger ships carrying not more than 36 passengers and cargo ships. A suitably located means for fully recharging breathing air cylinders, free from contamination, is required for passenger ships constructed on or after 01 July 2010 carrying more than 36 passengers.
• 16.9 All vessels, unless provided with an onboard means of recharging breathing apparatus cylinders, are required to have a suitable number of spare cylinders to replace those used during training or drills. The BMSR does not prescribe any minimum number. The shipboard SMS should include provisions to ensure that sufficient spares are available onboard (see also IMO Circular MSC.1/Circ.1555) corresponding to the number of breathing apparatuses being used during drills.

17. Specific Requirements for Emergency Escape Breathing Devices

• 17.1 The BMSR considers the Guidelines contained in MSC/Circ.849 to be mandatory.
• 17.2 Only control spaces and workshops that are remotely located from the machinery space escape routes should be considered to comply with MSC/Circ.849, paragraph 4.6.
• 17.3 To comply with MSC/Circ.849, paragraph 4.6, a minimum of two EEBDs should be located on each level of the machinery space. If a machinery space contains an enclosed primary escape trunk with a door at each level, only one EEBD need be located on each level.
• 17.4 With reference to section 17.3 above, the term level should be interpreted as meaning a deck where watchstanding personnel reside, workshops and control stations are located, or the crew may be employed during routine maintenance. In essence, two EEBDs are required only on those deck “levels” where people are likely to be employed. Platform decks that serve to divide long ladders into segments and partial decks where personnel are not likely to be employed for any significant period of time are not considered as “levels” and do not require EEBDs.
• 17.5 An EEBD must not be used under any circumstances to enter an enclosed shipboard space in which the atmosphere is known or suspected to be oxygen-depleted or enriched, toxic, or flammable.
• 17.6 EEBDs have to be examined and maintained in accordance with the manufacturer’s instructions, including those for hydrostatic testing.
• 17.7 It should be noted that when an EEBD is fitted with a small capacity oxygen cartridge (two inches (50.8mm) or less in diameter), some manufacturers specify a fixed service life without scheduled hydrostatic pressure testing. In the absence of manufacturer’s instructions, hydrostatic testing has to be carried out at intervals not exceeding five years, unless specifically prohibited by the manufacturers.
• 17.8 In cases where EEBD cylinders have been date stamped before delivery of a vessel, the first hydrostatic test may be harmonized with drydocking at the First Special survey under the HSSC. This is provided that the initial date stamp (month/year) on the cylinder is not more than six months before the vessel delivery date.
• 17.9 Maintenance requirements, manufacturer’s trademark and serial number, shelf life with accompanying manufacture date, and name of the approving authority have to be printed on each EEBD as per MSC/Circ.849, paragraph 5.3.
• 17.10 Sufficient spare EEBDs should be on board to replace units that are used, reach their expiry date, or otherwise become unserviceable. MSC/Circ.1081 addresses the number of EEBDs, including spares, required under SOLAS II-2.

18. Additional Survey Requirements

• 18.1 In surveying the safety equipment on a vessel, the RO has to verify that:
  • .1 all firefighting equipment has been inspected and maintained in accordance with the manufacturer’s instructions and the foregoing requirements; and
  • .2 the manufacturer’s maintenance instructions are on board; and
  • .3 records of inspections, maintenance and pressure tests are maintained as per section 18.3 below; and
  • .4 spare charges or extinguishers are provided in accordance with sections paragraphs 14.12 and 14.13 above.
• 18.2 The RO has to refer to the BMSR, with relevant recommendations, any cases where a Barbados vessel does not satisfy the foregoing requirements, prior to the issue or endorsement of a Cargo Ship Safety Equipment Certificate, Passenger Ship Safety Certificate or any other statutory certificate that relates to safety equipment.
• 18.3 The following records have to be maintained on board:
  • .1 Weekly testing and inspections;
  • .2 Monthly testing and inspections;
  • .3 Quarterly testing and inspections;
  • .4 Annual testing and inspections;
  • .5 Two-year testing and inspections;
  • .6 Five-year service;
  • .7Ten-year service.

Version	Description of Revision
1.0	Supersedes old INFORMATION BULLETIN No. 230
1.1	Amended effective date from 25/May/2021 to 23/Sep/2022.

IMOFUEL OIL CONSUMPTION DATA COLLECTION

Application: Owners and operators of ships that are subject to air emission controls under MARPOL Annex VI

Amendments to MARPOL Annex VI requiring mandatory fuel oil consumption data collection and reporting were adopted in 2016 and will enter into force on 1 March 2018, with the first reporting period being for the 2019 calendar year. The LR notice describing this process is concise and is reproduced below:

IMO has previously agreed to address ship energy efficiency through a three-step approach:

• 1. Data collection
• 2. Data analysis
• 3. Deciding on what further measures, if any, are required

The recent IMO MEPC 70 meeting worked on the data collection stage and adopted amendments to MARPOL Annex VI, Chapter 4. These mean that:

Ships of 5,000 GT and above will be required to submit to their Administration annual reports on fuel consumption and transport work parameters, via a methodology to be included in the Ship Energy Efficiency Management Plan (SEEMP).

Upon verification of the submitted data, the Administrations will issue to the ships a Statement of Compliance related to fuel oil consumption.

Finally, the Administrations will submit aggregate data to the IMO, which will maintain an anonymised IMO Ship Fuel Oil Consumption Database.

Ships will need to use a standardised reporting format, developed by the IMO, to submit data on: Identity of the ship

• IMO number

Technical characteristics of the ship

• ship type
• gross tonnage (GT)
• net tonnage (NT)
• deadweight tonnage (DWT)
• power output (rated power) of main and auxiliary reciprocating internal combustion engines over 130 kW (kW)
• Energy Efficiency Design Index (EEDI) (if applicable)
• Ice class (if applicable)

• Fuel oil consumption, by fuel oil type, in metric tonnes, and methods used for collecting fuel oil consumption data
• Distance travelled
• Hours under way

Shipowners and operators will need to start considering the means for collecting the fuel oil consumption data that is most appropriate for each ship and updating the SEEMPs of their ships to reflect this process.

Additional IMO guidance

MEPC 70 adopted the text of a resolution on 2016 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) which supersedes the 2012 Guidelines (MEPC.213(63)).

The IMO is also developing Draft Guidelines for Administration data verification procedures in order to assist Administrations with the verification of the reported data and the issuance of the Statement of Compliance. MEPC 71 finalised and adopted these guidelines

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New format of Officer’s Endorsement/CRA and Application form

As from the 15th of June 2015 we will have a new Barbados Online Seafarers System (BOSS) in place, which will issue all Endorsements/CRAs more effectively and efficiently. The Ship Security  Officer  (SSO) endorsement will now be a separate endorsement like the GMDSS. A fee of USD 125.00 will be charged for each endorsement issued. A CRA and a receipt will be sent via email for each endorsement application.

The application now contains boxes where the applicant is to sign and the signature must be contained within the box, as per the acceptable example below:

To all Yacht owners, managers, operators

Manning Scales for Commercial Yachts over 24m Load Line Length and under 3000 GRT

COMMERCIAL YACHTS UNDER 500 GRT

Any change to the minimum numbers and/or minimum qualifications shown above must be submitted to Barbados Ships’ Registry for consideration and approval.

A deck officer with an AEC or MEOL qualification will be accepted for the engineering post requiring that qualification providing he is not the Master and minimum safe manning numbers are maintained.

For Yachts under 500 GRT of 3000kW, the requirements for engineers will be as shown above provided there is a simple engine room layout and engine configuration. Where engine power is over 3000 kW and engine room layout and engine configuration are complicated, these requirements may be re-assessed by BMSR.

Manning Scales for Commercial Yachts over 24m Load Line Length and under 3000 GRT

COMMERCIAL YACHTS OVER 500 GRT

Any change to the minimum numbers and/or minimum qualifications shown above must be submitted to Barbados Ships’ Registry for consideration and approval.

All officers holding recognised STCW certificates of competency may apply to Barbados Ships’ Registry for issue of a Barbados Endorsement.

Application: All shipowner/operators, masters and officers of merchant ships and authorised classification societies

Background

Further to BMSR Bulletins 264, 272 and 272 (Update) on Ballast Water Management. The revised 2016 Guidelines (G8) in MEPC Resolution 279(70), now the BWMS Code, entered into force on 13 October 2019 and ballast water management systems installed on ships on or after 28 October 2020 shall be approved in accordance with the BWMS Code.

BWMS Commissioning and Testing Survey

A commissioning test to verify the performance shall be carried out after installation of any BWMS. MEPC 74 has approved a draft amendment to the Ballast Water Management Convention (BWMC) to conduct additional testing at commissioning to demonstrate through representative sampling and indicative analysis, that the BWMS is performing correctly and this amendment has been adopted at MEPC 75.

Sampling and Analysis Testing at the Commissioning Test

At MEPC 75 held virtually between 16-20 November 2020, draft amendments to Regulation E-1 requiring commissioning testing of ballast water management systems and draft amendments to the form of the International Ballast Water Management Certificate (Appendix 1) in the Annex to MEPC 75/3/1, were adopted by the IMO and are expected to enter into force on 1st June 2022. Refer to the two IMO Circulars below:

• BWM.2/Circ.70/Rev.1 dated 9th December 2020, Guidance for the Commissioning and Testing of Ballast Water Management Systems, contains detailed requirements for commissioning and testing of BWMS to D-2 standards, including indicative and representative sampling and analysis, following installation onboard.
• BWM.2/Circ.42/Rev.2 dated 9th December 2020, Guidance on Ballast Water Sampling and Analysis for Trial Use in Accordance with the BWM Convention and Guidelines (G2), contains general recommendations on methodologies and approaches to sampling and analysis to test for compliance with Regulations D-1 and D-2 of the BWM Convention.

The commissioning and testing of the BWMS after installation onboard is to be performed by the approved RO in accordance with the BWM Code, Regulation E-1, as part of the installation process. However, the additional representative sampling and indicative testing and analysis required under BWM.2/Circ.70/Rev.1 and BWM.2/Circ.42/Rev.2 is not yet mandatory, and may either be voluntarily applied or deferred until the adoption of the draft amendments to MEPC 75/3/1, expected on 1st June 2022.

BMSR 21/06/2021

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Application: All ship-owners, operators, Barbados approved nautical inspectors, masters and officers of merchant ships and authorised Classification Societies

Ministry of Infrastructure of Ukraine ref, No. 2196/46/14-21 letter to IMO of 18 June 2021 whereby extension of validity of seafarers’ documents is authorised.

In view of the Covid-19 pandemic, the Ministry of Infrastructure of Ukraine have applied measures to extend the validity of seafarers’ qualification documents for crew serving onboard to 31 December 2021 subject to certain conditions.

Part III, section 1.1 of the annex to the letter issued requires Flag states to recognize such an extension as granted by Ukraine.

It is hereby confirmed that Barbados Maritime Ship Registry agrees to the measures set down in the letter ref. No. 2196/46/14-21 of 18 June 2021.

BMSR 25/06/2021

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Application: All shipowner/operators, masters and officers of merchant ships and authorised classification societies

Introduction

This Notice provides guidance on examination, testing, servicing, maintenance, and repairs to life saving appliances including survival craft, rescue boats and launching appliances aboard Barbados flagged vessels. For additional details, please refer to the list of references attached to this bulletin.

BACKGROUND

In MSC.1/Circ.1206/Rev.1 dated 11th June 2009, the IMO noted an unacceptably high number of accidents in which crew members were being injured whilst participating in routine lifeboat drills and/or inspections. The IMO identified the following leading categories of causes:

Failure of lifeboat release mechanisms.

Inadvertent operation of lifeboat release mechanisms.

Inadequate maintenance of lifeboats, survival craft, launching appliances and release gear. Communication failure.

Lack of familiarity with the lifeboats, launching appliances, equipment, and associated controls. Unsafe practices during lifeboat drills and inspections; and

Design faults other than release mechanism.

• Maintenance, Thorough Examination and Testing of Life Saving Appliances (LSA)Consequently, during the Maritime Safety Committee’s 96th session (MSC 96), the IMO adopted amendments to SOLAS Regulations III/3 and III/20 through Resolutions MSC.402(96) and MSC.404(96). These amendments introduced mandatory requirements for maintenance, thorough examination, operational testing, overhaul, and repair of lifeboats including free-fall lifeboats, rescue boats, fast rescue boats, launching appliances and release gear for all ships on/after 1st January 2020.

• Lifeboat Release MechanismsSeveral accidents have been attributed directly to defective lifeboat on-load release hooks. As a result, IMO’s MSC adopted IMO Resolution MSC.317 (89), which added paragraph 5 in SOLAS 1974 Chapter  III/1,  requiring  that  lifeboat  release mechanisms not complying with the new requirements found in the LSA Code, shall be replaced by the first scheduled dry docking after 1st July 2014, but not later than 1st July 2019. Ships must be fitted with LSA Code compliant on-load release mechanisms as required  by  SOLA  Chapter III/1.5, taking into consideration MSC.1/Circ.1392 and Corr.1The MSC adopted amendments to the LSA Code in paragraph 4.4.7.6 related  to  the  requirements  for  release  mechanisms  of lifeboats launched by a fall/falls to require new subparagraphs .2 to .6, representing important safety improvements of the release mechanisms. In the interim, to help protect the seafarer from injury due to defective on load release hooks, IMO developed MSC.1/Circ. 1327, recommending the use of Fall Preventer Devices (FPD) when needed.

REQUIREMENTS

1. Authorization of Life Saving Equipment (LSA) Service ProvidersAn authorized service provider is

an entity authorised by the flag Administration in accordance with the requirements given in IMO Resolution MSC.402(96). Refer to Barbados Maritime Ship Registry Bulletin 322 – Authorized Service Providers – Lifeboats, Appliances etc.

• Maintenance, Examination, Testing, Servicing and Repair of Life Saving Appliances (LSA)The maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and  rescue boats, launching appliances and release mechanisms, shall be conducted in accordance with the requirements given in Resolution MSC.402(96) and the instructions for onboard maintenance as required by regulation 36 of SOLAS 74 Chapter III (as amended). Weekly and monthly inspections and routine maintenance as specified in the equipment maintenance manual(s), shall be conducted by authorized service providers, or by shipboard personnel under the direction of a senior ship’s officer, in accordance with the manufacturer’s maintenance manual(s).As of  1st  January  2020,  the  annual servicing and five yearly thorough examination of lifeboats, rescue boats, and the associated launching appliances including the release mechanisms, shall be carried out by service providers authorized by the flag Administration for each make and model in accordance with Resolution MSC 402(96). Authorizations previously provided to third party lifeboat service providers  under  Annex  I of MSC.1 Circ. 1206/Rev.1 are no longer permitted.Annual thorough examination and operational testing shall be carried out by certified personnel employed by the manufacturer, or service providers authorized by the Administration in accordance with Resolution MSC  402(96).Five-yearly  thorough  examinations, any overhaul, overload operational tests  (as  described  in  section  6.3,  of Resolution  MSC.402(96)), and repair, shall be conducted by certified personnel of either the manufacturer or a service provider authorized by the Administration The five yearly thorough examination, any overhaul, overload or operational tests test, must always be conducted in the presence of a class surveyor.A copy of valid documents of certification of personnel and authorization of the service provider shall be included with the statement issued by the manufacturer or authorized service provider who conducted the work. Personnel who perform the annual thorough examinations and operational test and five yearly through examinations, any overhaul, overload tests and repairs must be certified by the manufacturer or authorized service provider, for each make/type of the equipment to be worked on in accordance with the specified minimum capabilities, education, training and quality system requirements.
• HSSC and Harmonizing Servicing Intervals of LSAAs Barbados has implemented the Harmonized System of Survey and Certification (HSSC) for ships registered under  the  Barbados  flag  and  in pursuance of the HSSC’s objectives to “simplify survey requirements, thereby reducing the burden on Administrations, operators of ships and the crews of ships” as outlined in MSC/Circ.955, the servicing intervals of inflatable life rafts and marine evacuation systems for ships may be in concert with the terms of the HSSC annual, periodical and renewal survey stipulated in the 1988 SOLAS Protocol notwithstanding regulation III/20.8 of the 1974 SOLAS Convention (as amended), which requires inflatable life rafts and MES to be serviced at intervals not exceeding 12 months. Therefore, the annual servicing interval may be carried out up to -/+ 3 months of the due date for a ship implementing the HSSC and extended to 17 months for a ship not implementing the HSSC, where it is impracticable to carry out the service. In all cases a dispensation is required from the Administration when servicing of inflatable life rafts and/or MES will exceed the 12-month period.
• Examinations and Tests of Launching AppliancesLaunching appliances shall be subjected to thorough examination at the annual surveys required by regulations 1/7 and 1/8 of SOLAS 74 Chapter III (as amended), and upon completion of the examination, subjected to a dynamic test of the winch brake at maximum lowering speed. The load applied shall be the mass of the survival craft or rescue boat without persons on board, except that, at intervals of at least once every five years, the test shall be carried out with a proof load equal to 1.1 times the mass of the survival craft or rescue boat and its

full complement of persons and equipment.

• Examination and Tests of Lifeboat and Rescue Boat Release GearLifeboat and rescue boat release gear including fast rescue boat and free-fall lifeboat release systems, shall be subjected to a thorough examination and operational test during the annual surveys required by regulations 1/7 and 1/8 of SOLAS 74, Chapter III (as amended). On-load release gear shall be operationally tested under a load of

1.1 times the total mass of the boat (loaded with its full complement of persons and equipment) whenever the release gear is overhauled. Such overhauling and operational testing shall be carried out at least once every five years.The operational testing of free-fall lifeboat release mechanisms shall be performed either by free fall launching with only the operating crew on board, or by a test without launching the lifeboat carried out based on the requirements in Resolution MSC. 402(96).

1. Examination and Tests of Davit-Launched Life Raft Automatic Release HooksShall be subjected to a thorough examination and operational test during the annual surveys required by regulations 1/7 and 1/8 of SOLAS 74 Chapter III (as amended) and operationally tested under a load of 1.1 times the total mass of the life raft when loaded with its full complement of persons and equipment whenever the automatic release hook is overhauled. Such overhauling and operational test shall be carried out at least once every five years.
2. Examination and Tests of Lifeboats and Rescue Boats, including Fast Rescue BoatsLifeboats and rescue boats, including fast rescue boats, shall be subject to a thorough examination and operational test during the annual surveys required by regulations 1/7 and 1/8 of SOLAS 74 Chapter III (as amended).
3. Examination and Tests of Lifeboat Air Support SystemsIn accordance with the manufacturer’s instructions and guidelines, the air support system shall be subject to periodic inspection carried out by the vessel’s crew monthly, as required by Regulation 20.7 of SOLAS 74 Chapter III (as amended). All lifeboat air support systems and bottles shall be examined at least annually by the attending class society surveyor, as part of the annual Safety Equipment Survey. If the air pressure in the cylinders should fall below ten percent (10%) of the normal air pressure, they should be recharged in accordance with the manufacturer’s instructions and guidelines. When applicable, the on-board air recharging systems should be checked for air quality as part of the annual statutory survey for the SEC or MODU Code certificate. If the ship is not equipped with such an air compressor then the cylinders must be sent ashore to an authorized service facility for recharging or exchange.Hydrostatic testing of lifeboat air support cylinders shall be carried out once every five years or in accordance with the recommendations of the cylinder manufacturer, whichever is due first. The air receivers shall be hydrostatically tested prior to refilling a discharged receiver. The hydrostatic test date must be permanently stamped on the receiver or on a tag indicating the hydrostatic test date, securely attached to the cylinder.
4. Operation and Maintenance ManualsOwners/managers are encouraged to develop manuals for operation and maintenance of lifeboat systems including launching appliances. These manuals should be easy to understand and reflect the equipment used on board the ship. The use of video materials in conjunction with printed manuals is advised. The manual for a lifeboat system including launching appliance should be developed with the collaboration of the manufacturers and preferably be a single document.
5. General Safety Precautions Concerning LifeboatsOfficers and crewmembers should be confident that they will be able to safely use the lifesaving appliances. When servicing davits in the stowed position, the harbour safety pins or other similar safety devices, shall be in place to ensure the davits cannot be accidentally moved. When personnel are in the stowed lifeboats, the hanging-off pendants should be used to prevent the boat from being accidentally released.All launching appliances should receive regular maintenance by persons who are familiar with and able to follow the manufacturer’s

instructions. Checklists should be used to ensure that all safety precautions are  in  place  before personnel perform maintenance or inspections and that operating procedures are followed including proper stowing/securing after use.No additional securing arrangements should be used which are not included in the lowering/free-fall instructions except for additional securing devices during extreme heavy weather, which must be removed as soon as the weather moderates. These standard procedures should be included in each vessel’s safety management system as applicable.

References

1. MSC.402(96) – Requirements for Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair of Lifeboats and Rescue Boats, Launching Appliances and Release Gear.
2. MSC.404(96) – Amendments to the International Convention for the Safety of Life at Sea 1974 (as amended).
3. MSC.317(89) – Adoption of Amendments to the International Convention for the Safety of Life at Sea 1974 (as amended).
4. MSC.1/Circ.1392 and Corr,1 – Guidelines for Evaluation and Replacement of Lifeboat Release and Retrieval Systems
5. MSC.1/Circ.1327 – Guidelines for the Fitting and Use of Fall Preventer Devices (FPDs)
6. MSC.1/Circ.1206/Rev.1 – Measures to Prevent Accidents with Lifeboats.
7. MSC/Cir.955 – Servicing of Life-Saving Appliances and Radio Communications Equipment Under the Harmonized System of Survey and Certification (HSSC).
8. The International Convention for the Safety of Life at Sea 1974 (as amended).
9. The International Life Saving Appliances Code (as amended).

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Application: All shipowner/operators, masters and officers of merchant ships and authorised classification societies

Introduction

The IMO global sulphur cap requirements entered into force on 1st January 2020. Refer to Barbados Maritime Ship Registry Bulletin 316, “Fuel Oil Sulphur Cap”, which describes the applicable regulatory requirements. PSC inspections are carried out in accordance with the 2019 guidelines for PSC under MARPOL Annex VI (MEPC 74/18/Add.1, Annex 15) to establish whether a ship complies, PSC inspectors are likely to focus their attention on documents and procedures maintained on board. In certain jurisdictions however, PSC inspectors may carry portable sulphur testing kits and if the results of these tests are inconclusive or indicate potential non-compliance, additional sampling will take place for verification ashore. Questions have arisen in conjunction with these sampling tests and the purpose of this bulletin is to provide additional guidance.

Bunker Delivery Notes (BDNs) and MARPOL Samples

Details of fuel delivered on board for combustion purposes shall be recorded by means of a suppliers Bunker Delivery Note (BDN). The BDN shall be accompanied by a representative sample of the fuel delivered (the MARPOL Sample). Refer to Part 1 in MEPC.1/Circ.882, “MARPOL Delivered Fuel Oil Sample”. Acceptance criteria for the MARPOL sample are given in Appendix VI, Table 1 “Summary of Part 1, MARPOL Delivered Fuel Oil Sample Procedure”. On completion of bunker delivery, the MARPOL sample is to be sealed and signed by the supplier’s representative and the Master or senior officer in charge of the bunker operation and kept onboard until the fuel has been substantially consumed, but for a period of not less than twelve months from the date of delivery. BDNs and associated samples should be easily identifiable, filed properly and retained on board for at least three years after the fuel has been received.

Additional Sampling of Fuel Oil

In addition to the official MARPOL sample, commercial samples may also be taken. New sample categories of “in-use” and “onboard” samples have been introduced to allow competent authorities of parties to MARPOL to determine whether the fuel oil used onboard meets the sulphur content limits specified in Regulation 14.1 or 14.4.

PSC Fuel Sampling

The PSCO will normally investigate whether a ship carries compliant fuel oils, based on the documents listed in paragraph 2.1.2 of the 2019 PSC Guidelines. Additionally, records required to demonstrate compliance may also be viewed. However, results from remote sensing could be used to trigger inspections and portable devices could be used during the initial inspections. Remote sensing and portable devices are however, of indicative nature and should not be regarded as the evidence of non compliance but may be considered clear grounds for expanding the inspection.

When the PSCO identifies clear grounds of suspected non-compliance based on initial inspections, they may require samples of fuel oils to be analysed. The samples to be analysed may be either the representative samples provided with the BDN in accordance with regulation 18.8.2, (MARPOL delivered samples), or samples from designated sampling points in accordance with the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1 – in-use fuel oil samples, or other samples obtained by the port State). There are two locations where fuel sampling might be required by the PSCO:

• downstream of the fuel oil service tank
• the storage tanks, “in use” and “on-board” respectively.

In detecting suspected non-compliance, the sample analysis should be conducted in a uniform and reliable manner. The verification procedure for MARPOL delivered samples should be in accordance with appendix VI of MARPOL Annex VI. For the “in-use” and “onboard” samples, the sample should be deemed to meet the requirements, provided the test result from the laboratory does not exceed the specification limit +0.59R (where R is the reproducibility of the test method) and no further testing is necessary. Refer to MEPC.1/Circ.882, Annex, table 2, summary of in-use or onboard FO sample procedures.

In accordance with ISO 4259-2: 2017, and allowing for a 95% confidence limit, the maximum amount of sulphur allowed in these samples is 0.11% m/m for ECA fuel and 0.53% m/m for global fuel. In situations where the commercial samples taken during bunkering, indicate a higher sulphur content than noted on the BDN, then the flag administration and PSC at destination need to be notified in writing without delay. (Note that the ship will have likely sailed by the time these test results are known). In the event of any further investigation by PSC, the Representative Sample (MARPOL sample) will be used by PSC for further verification procedures and the ship may be ordered to de-bunker the fuel at the next port.

If a non-compliance is established, consistent with regulation 18.2.3, the port State may prevent the ship from sailing until the ship takes any suitable measures to achieve compliance which may include de bunkering all non-compliant fuel oil. In addition, the port State should report the information of the ship using or carrying for use non-compliant fuel oil to the Administration of the ship and inform the Party or non-Party under whose jurisdiction a bunker delivery note was issued of cases of delivery of non compliant fuel oil, giving all relevant information.

Additional documentation and procedural requirements during PSC Inspections

The following documents and information should also be available during PSC inspections.

• International Air Pollution Prevention Certificate (IAPPC)
• Written procedures for fuel change-over
• Shipboard Implementation Plan
• Tank plans and piping diagrams
• Fuel Oil Non-Availability Report FONAR
• Voyage records: ECDIS and navigation charts
• Oil Record Book Part I – all entries for internal fuel transfers, bunkering, retention, disposal should be entered appropriately and signed
• Engine logbooks
• Tank sounding records.
• Equivalent arrangements or alternate fuel.
• IAPPC and Supplement

References

• 1. MEPC.1/Circ.882 Early Application of the Verification Procedures for a MARPOL Annex VI Fuel Oil1. Sample (Regulation 18.8.2 or Regulation 14.8).
  2. Resolution MEPC.320(74), 2019 Guidelines for Consistent Implementation of the 0.5% Sulphur Limit2. Under MARPOL Annex VI.
  3. MEPC 74/18/Add.1, Annex 15, Resolution MEPC.321(74) 2019 Guidelines for Port State Control Under3. MARPOL Annex VI, Cha

BMSR 16/06/2021

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