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.

 

 

 

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) Res. MEPC.388(81) Amendments to the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (res. MEPC.346(78)).
r) Bulletin 008 – Permits Exemptions and Equivalences.
s) Resolution MEPC.348(78) 2022 Guidelines for Administration verification of ship fuel oil consumption data and operational carbon intensity.
t) MEPC.1-Circ.876 Sample Format for The Confirmation Of Compliance, Early Submission Of The SEEMP Part II etc.
u) Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport, and amending Directive 2009/16/EC.
v) SI 2018/1388 The Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions) (Amendment) (EU Exit) Regulations 2018.
w) MIN 669 (M+F) Amendments 1 – Reporting Emissions Data into the UK MRV Regime.
x) 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.
y) 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)).
z) IACS recommendation 175 – SEEMP/CII Implementation Guidelines.
aa) Resolution MEPC.347(78) Guidelines for the verification and company audits by the Administration of part III of the Ship Energy Efficiency Management Plan (SEEMP).
bb) Res. MEPC.389(81) Amendments to the 2022 Guidelines for Administration verification of ship fuel oil consumption data and operational carbon intensity (resolution MEPC.348(78)).
cc) Res. MEPC.385(81) Amendments to MARPOL Annex VI, regulations 2, 13, 14, 18, 27, appendices I and IX (Low-flashpoint fuels and other fuel oil related issues, marine diesel engine replacing steam system, accessibility of data and inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS)).
dd) MEPC.1/Circ.913 Guidance on the application of the amendments to Appendix IX of MARPOL ANNEX VI on inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS) as adopted by Resolution MEPC.385(81).

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. As of the date of issue of this Bulletin , the IMO is yet to develop guidance of the year reporting and the IMO GISIS Module “MARPOL Annex VI” does not allow yet notification required by MARPOL Annex VI Reg. 23 and 25.

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) and MEPC.388(81).

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          According to the resolution MEPC.347(78) the SEEMP Part III verification process should involve initial verification, periodical verifications and additional verifications (where applicable) :

.1                        Initial verification shall be carried out for each vessel to which regulation 26.3 of MARPOL Annex VI applies;

.2                         Periodical verification shall be carried out if any of the elements in regulation 26.3.1 of MARPOL Annex VI is updated and, in any case, every three (3) years;

.3                        Additional verification shall be carried out in case of one or more vessels rated as D for three (3) consecutive years or one or more vessels rated as E in any calendar year.

18.10           Additionally, periodical and additional company audits should be performed to verify that the vessel is being operated in accordance with the SEEMP Part III as per the following :

.1                        Periodically at least once every 3 years; and

.2                        When one or more vessels in the company obtain an E rating in any calendar year (20XX), an additional company audit should be performed within 30 Nov of the year 20XX + 1; and

.3                        When one or more vessels in the company obtain a D rating in three (3) consecutive years (20XX, 20XX + 1, 20XX + 2) an additional company audit should be performed within 30 Nov of year 20XX + 3.

18.11 Upon successful verification of SEEMP part III, as per above, the RO shall issue to the vessel the Confirmation of Compliance as per Annex of MEPC.347(78).

18.12 Res. MEPC.385(81) will enter into force on 1st August 2025 and, as per MEPC.1/Circ.913, and, for Barbadian vessels which implement the amendments the entry-into-force date (1 August 2025):
.1 Vessels for which MARPOL Annex VI Reg. 27 ( Sec. ) applies shall update their SEEMP to align with the revised reporting requirements. SEEMP should undergo revision and verification by the RO to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2026. Those planning to retrofit flow meters or employ other methodologies should complete these actions within the same time frame;
.2 Data will be collected with the existing level of granularity throughout the entire year of 2025 and, therefore, the data reported at the beginning of 2026 will be based on this consistent level. Data will be collected and reported with the enhanced level of granularity from 1 January 2026 and beyond; and
.3 Vessels delivered on or after 1 August 2025 should collect data at the enhanced level of granularity from the date of delivery and the data reported at the beginning of 2026 will be based on appendix IX of MARPOL Annex VI in the annex to resolution MEPC.385(81), as this provides consistent data collection and reporting for such ships on or after the entry-into-force date.

18.13 For Barbadian vessels which voluntarily implement the amendments early (1 January 2025):
.1 The SEEMP should undergo revision and verification by the RO to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2025 or the delivery date for ships delivered on or after 1 January 2025. Those planning to retrofit flow meters or other methodologies should complete these actions within the same time frame; and
.2 Data will be collected and reported with an enhanced level of granularity throughout the entire year of 2025 and beyond.

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 19.3, 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 Bulletin , 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 or review of aggregated and verified data cannot be completed due to missing data from previous shipowners and flag States, the BMSR exercises a pragmatic approach in allowing the Reporting Organisation/Verifier additional time to complete the submission and issue a Statement of Compliance based on partial data, with the following conditions:

.1 The SOC shall clearly state that the calculation is based on partial data;
.2 The RO shall records emails sent from the new shipowners to previous shipowners, flag State, and RO/Verifier for request of the data under their responsibility.

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 .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 (the quantity of consumed BOG should be reported in metric tonnes in reference to the original quantity of liquified gas);
.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.

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 as per Resolution MEPC.348(78) and MEPC.389(81), 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.
1.2	Sec. 1.b) amended Sec. 17.11 added new text for reporting to the IMO Secretariat. Sec. 19.4 Amended reference to 18.3 with 19.3 and replaced wording “Notice” with “Bulletin”. Sec. 19.5 amended all the section. Sec 19.7.2 footnote 1 removed and added as part of the section.
1.3	Amended numbering sequence of all Sec. 1 and added 1.q, 1.z, 1.aa, 1.bb, 1.cc; Amended 18.1, 18.9, 19.9; Added Sec.18.10, 18.11, 18.12.
1.4	Amended Sec. 18.9. and added new Sec. 18.10. old sec. 18.10,18.11 & 18.12 have been renumbered with 18.11, 18.12 & 18.13 respectively.

 

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.

 

 

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.