Bulletin 008 – Permits, Permanent Exemptions and Equivalences Rev.2.0

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

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1. References

    • a) International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS);
    • b) International Convention on Load Lines, 1966, as modified by the Protocol of 1988 (LLC);
    • c) International Convention for the Prevention of Pollution from Ships, as amended (MARPOL);
    • d) International Convention for the Control and Management of Ships’ ballast water and Sediments (BWMC);
    • e) IMO Circular SLS.14/Circ.1151 “Issue of Exemption Certificates under the 1974 SOLAS Convention and Amendments thereto”

Purpose

      • 2.1 This Bulletin explains the process for applying for:
      •      .1 Temporary and Permanent Exemption from an IMO Convention or National requirement;
      •      .2 Extension of statutory survey period or validity of a certificate issued under an international convention; or
      •      3. Postponement of a survey, servicing period or any other applicable national or international requirement; or
      •      4. Equivalent arrangement to an IMO convention requirement.
      •      5. Where the vessel does not correspond with the particulars of the affected certificate owing to failure of equipment, damage, etc.;
      •      6. Where detainable deficiencies are identified and cannot be permanently repaired or rectified immediately.
  • 3. Application
  • 3.1 This Bulletin applies to all Barbadian vessels.

4. Introduction

    • 4.1 As per SLS.14/Circ.115 the BMSR concurs that in various SOLAS regulations the words “exemptions”, “relaxations”, “dispensations”, and “waivers” are used with apparently no intended difference in their meaning.
    • 4.2 A Permit is a temporary release from a statutory requirement for a limited time period where a vessel is, temporarily, unable to comply with statutory provisions and are generally limited to the minimum period of time necessary for the vessel to reach a port where rectification of the deficiency can be accomplished. This includes extension and/or postponement of statutory surveys, audits, verifications, and inspections.
    • 4.3 An Exemption is a permanent release from compliance with a statutory convention requirement, due to the existence of specific circumstances as sanctioned by the provisions of that Convention.
    • 4.4 An Equivalence is a permanent arrangement which provides the same general level of safety or intent of a Convention requirement without meeting all criteria for full compliance. Such arrangements can be accomplished, either independently or in combination with, alternative equipment, additional procedures/precautions, operational restrictions, etc.

5. Application for a Permit, Exemption and Equivalence

    • 5.1 Barbados Recognised Organisations (ROs) are not authorised to issue a Permit, Permanent Exemption or Equivalence without the agreement of the BMSR.
    • 5.2 Applications are to be submitted to the BMSR directly or via the RO that has issued the relevant Statutory certificate. The application should include, but not be limited to, the following:
        •      .1 Reason and justification;
        •      .2 Temporary measures in place;
        •      .3 Corrective action plan to rectify the deficiency
        •      .4 Supporting documentation.
        • 5.3 When the application is submitted though the RO , the RO shall review the application and provide the BMSR with:
        •      .1 Provisions contained in any applicable IMO convention, code, or IMO circulars;
        •      .2 Provisions contained in Barbados national regulations.
        •      .3 Recommendations and justifications

6. Application for a Permanent Exemption and Equivalence

6.1 Barbados Recognised Organisations (ROs) are not authorised to issue a permanent exemption or equivalence without the agreement of the BMSR.
6.2 Applications are to be submitted to the RO that has issued the relevant Statutory certificate.
6.3 Then the RO shall review the application and provide the BMSR with:
.1 The rule under the which the exemption can be granted;
.2 The rule from which the exemption is sought;
.3 Conditions/mitigating measures.

7. BMSR Documents of Approval

  • 7.1 Approval of an application for Permit, Permanent Exemption or Equivalence is officially granted
    by the BMSR with the issuance of one of the below documents:
         .1 Single Voyage Permit;
         .2 Temporary Permission;
         .3 SOLAS Exemption Certificate;
         .4 Load Line Exemption Certificate;
         .5 Permanent Exemption;
         .6 Permanent Equivalence;
  • 7.2 The Temporary Permission and Single Voyage Permit are both a permit as defined in section 4.2 above.
  • 7.3 A Temporary Permission, unless otherwise stated in a convention or code, is generally issued for a maximum period of three (3) months, but may be re-issued if the defect is not rectified in time. In some circumstances (e.g., if repairs need to be carried out in a dry dock or spare parts are unavailable) a Temporary Permission is issued for longer periods.
  • 7.4 A Single Voyage Permit is a permit with validity only for the single voyage.
  • 7.5 A Permanent Exemption, SOLAS Exemption Certificate and International Load Line Exemption Certificate are all exemptions, as defined in section 4.3 above, and are linked to, and retained with, its associated statutory certificate.
  • 7.6 A SOLAS Exemption Certificate is issued for an exemption from a provision of SOLAS, as listed in Annex of SLS.14/Circ.115, and based on the form provided in SOLAS.
  • 7.7 A Load Line Exemption Certificate is issued for an exemption as per Article 6 of the LLC, and based on the form provided in the LLC.
  • 7.8 A Permanent Exemption is issued for an exemption from provision of any other IMO convention, such as MARPOL, BWMC etc.
  • 7.9 A Permanent Equivalence is issued for an equivalence to any IMO convention.
  • 7.10 Exemptions and Equivalences are communicated to the IMO, through the IMO Global Integrated Shipping Information System (GISIS2).
  • 7.11 As per SLS.14/Circ.115, when a Permit, an Exemption or an Equivalence is issued, port State authorities should interpret this as meaning that the vessel complies with the provisions of the Convention.
  • 7.12 Port State authorities, whenever needed, can check validity of a BMSR Permit, Exemption or Equivalence on the BMSR portal Validate a Document3 or using the barcode on the electronic certificates issued by the BMSR.
  • 7.13 For a BMSR Permit, Exemption or Equivalence without a barcode, Port State authorities can contact BMSR by email to ops@barbadosmaritime.com.

Revision No

Description Of Revision

1.0

Replaces Information Bulletin No. 318

2.0

Amended bulletin format and added new section 6.

  
  
  
  
  
 

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Bulletin 004 – Flag State Inspections Rev.2.3

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

 

1.             References

a)              Barbados Merchant Shipping Act, 2024

b)              United Nations Convention on the Law of the Sea (UNCLOS).

c)              International Safety Management (ISM) Code.

d)              IACS Procedural Requirements PR17 Reporting on deficiencies possibly affecting the implementation of the ISM Code on board.

e)              MLC Maritime Labour Convention, 2006.

2.             Purpose

2.1           This Bulletin sets out the measures for Flag State Inspections as required under the Barbados Merchant Shipping Act, 2024 and Articles 94 and 217 of the United Nations Convention on the Law of the Sea (UNCLOS).

3.             Application

3.1           This Bulletin applies to all Barbados registered vessels engaged in international voyages.

3.2           Pleasure (Private) yachts and unmanned barges are exempt from Flag State Inspections.

4.             Flag State Inspections – General

4.1           The Flag State Inspections are to ensure that the arrangements, materials, and scantlings of the items below are in all respects satisfactory for the service for which the Barbadian vessel is intended:

.1              The hull;

.2              The boilers and other pressure vessels;

.3              The main and auxiliary machinery;

.4              The electrical installation;

.5              All other equipment;

4.2           The Flag State Inspections also verify that:

.1              The vessel complies with the standards of the applicable international conventions and codes.

.2              The vessel is effectively managed by the company, and that the safety management system is effective and implemented properly as per the International Safety Management (ISM) Code.

.3              That Barbados national requirements, particularly those relating to the official logbook, crew articles, seafarer endorsements, and certificates, are being followed.

.4              That the standard of work conducted by Recognised Organisations continues to meet the standards required by the BMSR.

4.3           The scope of the Flag State Inspections is not necessarily as the Annual, Periodic or Renewal Statutory Surveys conducted by Barbados Recognised Organisations (ROs).

4.4           Certain aspects of the inspection may be conducted by a sampling process. Therefore, the absence of deficiencies identified during the inspection does not mean deficiencies do not exist.

4.5           All Flag State Inspections can be conducted only by Barbados Appointed Nautical Inspectors (ANI), who must always contact the BMSR to request an authorisation code and specific instructions.

4.6           A maximum of 2 consecutive Flag State Inspections may be carried out by the same ANI Company.

4.7           Regional Registrars cannot inspect Barbadian vessels registered via their office.

4.8           The BMSR has a large network of ANIs who cover all major ports, details of which can be found on the BMSR website under List of Appointed Nautical Inspectors.

4.9           ANIs are not restricted to a specific area or region so may inspect a vessel in any location.

4.10       The cost of an inspection is set independently by the ANI.

4.11       All costs relating to a Flag State Inspection are to be agreed between the shipowners/managers and the ANI and payment is made directly to the ANI.

4.12       Failure to carry out a Flag State Inspection is considered by the BMSR as evidence of a failure of the safety management system of the vessel and company, hence as a Major Non-Conformity (MNC) under paragraphs 3 and 5 of the International Safety Management (ISM) Code. An additional external DOC or SMS audit may be requested to address this.

4.13       Flag inspection cannot be carried out when the vessel is in lay-up ( either hot or cold) and/or in drydock. For flag inspection, the vessel shall be afloat, fully operational and manned.

5.             Flag State Inspections – Documentation 

5.1           On the completion of a Flag State Inspection, the ANI submits the inspection report, a list of deficiencies and/or observations to the BMSR and the Master.

5.2           On completion of both Initial Inspection and AFSI, the ANI also issues a Certificate of Inspection (CoI) with validity until the anniversary date of the vessel.

5.3           The CoI must be displayed onboard in a prominent location, typically in the accommodation or on the bridge.

5.4           Failure to display a valid CoI may result in a deficiency being raised during the next inspection.

6.             Flag State Inspections – Type of Inspection

6.1           Pre-Registration Inspection

.1              All vessels over 12 years of age are required to undergo a pre-registration inspection before they can be accepted for provisional registration. However, this requirement may be waived at the Principal Registrar’s discretion.

.2              No vessel can be approved for provisional registration until the pre-registration inspection report has been reviewed by the BMSR and deficiencies addressed as per the BMSR request.

.3              Shipowners and managers must consider the potential of delays to the registration process should the pre-registration inspection report not be received and reviewed by the BMSR and should ensure the inspection is carried out at least 7 days before they intend to register the vessel.

.4              In exceptional circumstances, the BMSR may accept a recent (within 1 month) pre-purchase inspection report in lieu of a Pre-Registration Inspection.

.5              In cases where a seller does not allow additional pre-purchase survey and/or in case the vessel is at a port where a Pre-Registration Inspection cannot be undertaken, the Alternate Entry Scheme may be utilised.

.6              Under the Alternate Entry Scheme, a vessel may be provisionally registered, subject to satisfactory assessment by the Principal Registrar, for a maximum period of thirty (30) days. Within this period the vessel must undergo the Pre-Registration Inspection.

6.2           Initial Inspection

.1              The Initial Inspection is to be conducted within the period of provisional registration (normally 6 months).

.2              The vessel can only be permanently registered once the vessel has undergone a satisfactory Initial Inspection.

.3              Failure to arrange the Initial Inspection within the period of Provisional Registration may result in the vessel being refused permanent registration.

6.3           Annual Flag Safety Inspection (AFSI)

.1              All vessels registered with the BMSR have an anniversary date, which is the annual anniversary of the registration date indicated on the Certificate of Registry (COR).

.2              The AFSI is to be conducted within the period of 3 months on either side of the vessel’s anniversary date.

6.4           Follow-up Inspection

.1              A Follow-up Inspection might be carried out where the vessel incurs more than 3 deficiencies or is detained during Port State Control Inspection (PSCI).

.2              The scope of a Follow-up Inspection is to verify that all deficiencies have been properly rectified, and measures put in place to prevent recurrence of the deficiencies.

6.5           Additional Inspection

.1              A vessel may be requested to undergo an Additional Inspection based on, but not limited to:

i)            Persistent failure to rectify deficiencies by the due dates or recurrence of deficiencies;

ii)          PSCIs and AFSIs;

iii)         Class and Statutory Surveys;

iv)         International Safety Management Code (ISM) audit(s);

v)          IACS Procedural Requirements PR17 Reporting on deficiencies possibly affecting the implementation of the ISM Code on board;

vi)         Information on serious defects or substandard conditions received from the BMSR Inspectors, Recognised Organisation surveyors and auditors, other Administrations, etc.;

vii)       Information received from the BMSR ANIs, PSCOs, ROs surveyors, crew members, etc., of serious breaches of the MLC Maritime Labour Convention, 2006.

.2              The Additional Inspection is a one-off Flag State Inspection.

7.             Special Inspection Program (SIP)

7.1           The SIP applies to those vessels where there is evidence of declining standards of operation and/or maintenance, or evidence of a significant lack of compliance with international Conventions and/or national requirements, or where a trend towards general non-compliance has been identified.

7.2           A vessel is placed automatically under the SIP when detained on more than one occasion in a 24-month period by a Port State Control Officer (PSCO).

7.3           A vessel may also be placed under the SIP based on one of the reasons listed in paragraph 6.5.1 above.

7.4           When a vessel is placed under the SIP, the shipowners/managers are to be notified by the BMSR with the reasons for the decision and with the time schedule of the SIP.

7.5           The first Special Inspection due date is one (1) month from the vessel being placed under the SIP.

7.6           The subsequent Special Inspection due dates are at three (3) month intervals thereafter.

7.7           When a vessel is under the SIP a new CoI is issued after each Special Inspection and valid for three (3) months.

7.8           The next Special Inspection is to be carried out within one (1) month before or after the due date.

7.9           After the first and any following Special Inspection if the BMSR is satisfied that the vessel has no deficiencies and proper corrective actions have been taken the vessel is removed from the SIP and will revert to the standard AFSI with the anniversary date as defined in paragraph 6.3.1 above.

7.10       If the BMSR is not satisfied with the rectification of the deficiencies and corrective actions the vessel is maintained under the SIP.

7.11       The SIP is intended to achieve satisfactory improvements within a twelve (12) month period from the date of inclusion (4 special inspections).

7.12       Where a vessel changes shipowners and/or managers while under the SIP, the vessel is meant to continue with the SIP. However, the vessel may be considered for removal from the SIP at the Principal Registrar’s discretion.

7.13       A vessel that has not addressed deficiencies and/or has not reached standards of operation and/or maintenance improvement after twelve (12) months is reviewed by the Principal Registrar and may incur deletion from the register.

7.14       During a Special Inspection, new additional deficiencies may be raised, and it is particularly important that all deficiencies are proactively dealt with by the master and crew. Documentary evidence of this process is essential.

8.             Deficiencies

8.1           The BMSR may add, remove, or amend deficiencies following a review of the Flag State Inspection reports and the list of deficiencies issued by the ANI.

8.2           All deficiencies must be closed out and evidence of rectification must be provided directly to the BMSR by email to ops@barbadosmaritime.com and by the due date given.

8.3           Acceptable evidence to close out a deficiency may include, but is not limited to:

.1              Pictures;

.2              Classification Society or RO survey report;

.3              Certificate of maintenance;

.4              Invoice or delivery notes;

.5              Non-conformity reports or Corrective Action Plan (CAP).

8.4           Failure to rectify a deficiency within the due dates is considered by the BMSR as evidence of a failure of the safety management system of the vessel and company, hence as a Major Non-Conformity (MNC) under paragraphs 3 and 5 of the International Safety Management (ISM) Code. An additional external DOC or SMS audit may be requested to address this.

8.5           Persistent failure to rectify deficiencies by the due dates or repeat occurrence of deficiencies may result in the vessel being:

.1              Required to undergo an Additional Inspection as per paragraph 6.5 above;

.2              Placed under the SIP as per paragraph 7 above;

.3              Suspended ( flag State detention);

.4              Deleted from the Registry.

9.             Observations

9.1           Observations give the ANI the opportunity to bring to the BMSR and shipowners/managers attention items which are not considered deficiencies but that may be:

.1              Worthy of further improvement (e.g., onboard procedures, training, etc); or,

.2              Worthy of praise (e.g., certain on-board working practices, maintenance levels, etc).

9.2           Observations are recorded in the inspection report and may be considered as suggestions for improvement by the Company.

9.3           Observations do not need to be formally closed out, but the Company may advise the BMSR of any follow-up action taken.

10.         Suspension of AFSIs

10.1       When a vessel is out of service, in layup or on bareboat charter out to a Secondary Registry the requirement for AFSIs during this period may be suspended if the BMSR is advised.

10.2       When the vessel re-enters service or returns to the BMSR from bareboat charter out and in case the due AFSI has not been completed on time and is overdue by more than 3 months an Additional Inspection within one month of the vessel re-entering or returning is to be carried out.

10.3       In all cases the anniversary date does not change and is as defined in paragraph 6.3.1 above.

Revision No

Description Of Revision

1.0

First Issue

2.0

Re-issued with a new template and amended Section 4.

2.1

Amended Sec. 1,4.1, 4.11,4.13, 6.1.1,6.3,6.4,7.13,8.3,8.5.2,9.1.1,9.3

Added Sec. 4.13.

2.2

Amended section 10.2 – “a new Initial” (inspection) was replaced by “an Additional”

2.3

Updated references to the Barbados Merchant Shipping Act, 2024 in 1 a) and 2.1

  
  
 

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Bulletin 040 – Medical Care and Medical Oxygen Cylinders 1.2

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

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1.             References

a)              Barbados Merchant Shipping Act, 2024

b)              Barbados S.I. 2025 No. 32: Merchant Shipping (Ships’ Medical Stores) Regulations, 2025

c)              Maritime Labour Convention, 2006 (MLC, 2006)

d)              SOLAS, International Convention for the Safety of Life at Sea.

e)              WHO International Medical Guide for Ships, 3rd edition

f)               PPO01-F14 Ship Masters Medical Report Form

g)              PPO01-F17 Controlled Drugs Requisition

h)              Bulletin 021 – BMSR Certificates of Endorsements

i)                International Maritime Dangerous Goods Code (IMDG Code)

j)                Medical First Aid Guide for Use in Accidents Involving Dangerous Goods (MFAG)

k)              Seafarers’ Training, Certification and Watchkeeping Code (STCW Code)

l)                Code of Signals, Edition 2005

2.             Purpose

2.1           This Bulletin provides guidance on implementing the MLC, 2006 Reg. 4.1 requirements for medical care on board, the Barbados Merchant Shipping Act, 2024 and the S.I. 2025 No. 32., and adopts the WHO International Medical Guide for Ships, 3rd edition as guidance for Barbadian vessels.

3.             Application

3.1           This Bulletin applies to all Barbados vessels engaged in international voyages other than pleasure yachts.

4.             Vessel Medical Stores

4.1           All vessels shall carry medical stores, medical equipment and a medical guide, which shall be maintained and inspected at intervals not exceeding twelve (12) months.

4.2           The medical stores shall conform to the standards and requirements of the British National Formulary, the British Pharmacopoeia, the European Pharmacopoeia or the United States Pharmacopoeia, and to the requirements of Chapter 33 of WHO International Medical Guide for Ships, 3rd edition.

4.3           The exact inventory of medicines, medical equipment and supplies should be determined by the shipowner or operator in consultation with a qualified medical practitioner, such as the vessel’s doctor or pharmacist.

4.4           The medical stores, packing, and labelling shall be as per Sec. 20 of S.I. 2025 No. 32 and stored as per Sec. 21 of S.I. 2025 No. 32.

4.5           Drawers or medicine cabinets should be large enough to store medicines and equipment in an orderly manner so that they are easily identified and available for immediate use. This is particularly important for medicines and equipment used in emergencies: these should be kept separately in the most accessible place. Generally, items of the same type or category should be stored in a box, shelf or drawer, properly labelled.

4.6           All medicines shall be kept in good condition and protected against humidity and temperature extremes. They should be stored at room temperature (15–25 °C) when not otherwise specified. A refrigerator should be available nearby for items that must be kept at 2–8 °C. This refrigerator should not be used for any other purpose and should be equipped with a lock.

5.             First Aid Kits

5.1           In addition to the medical stores under Sec. 4 above, vessels with a crew of more than 10 shall carry first aid kits distributed in appropriate locations on the vessel, such as in the galley and engine, as per Sec. 3 of the Third Schedule of S.I. 2025 No. 32.

6.             Medical Doctor and Person designated to provide Medical Care

6.1           Vessels, including Passenger Ships, carrying 100 or more persons and ordinarily engaged on international voyages of more than three days’ duration, are required to have a qualified medical doctor responsible for providing medical care.

6.2           For mobile offshore drilling units and mobile offshore units, the requirement for a doctor on board may be met with a qualified medic or nurse where the unit is within helicopter range of shore medical services and facilities.

6.3           Vessels, which do not carry a medical doctor shall be required to have either at least one designated seafarer on board who is in charge of medical care and administering medicine as part of their regular duties or if the vessel is ordinarily capable of reaching qualified medical care and medical facilities within eight (8) hours, the vessel shall have at least one (1) seafarer on board competent to provide medical first aid.

6.4           The person in charge of medical care on board who is not a qualified medical doctor shall have satisfactorily completed training in medical care that meets the requirements of STCW Code. Seafarers designated to provide medical first aid shall have satisfactorily completed training in medical first aid that meets the requirements of the  STCW Code, with  the latest edition of MFAG, and the medical section of the International of Code of Signals.

6.5           Persons referred to in Sec. 6.3 and 6.4 above, and other seafarers with medical assigned tasks should undergo refresher courses at intervals not exceeding five (5) years to enable them to maintain and increase their knowledge and skills and to keep up-to-date with new developments, as per MLC, 2006 Guideline B4.1.1.3. Documentary evidence of this refresher training should be maintained.

7.             Vessels carrying Dangerous Cargoes

7.1           In addition to the medical stores under Sec. 4 above, when a Barbados-registered vessel is carrying a dangerous substance in quantities in excess of those defined in Vol 1, Section 18 of IMDG Code shall comply with the IMDG Code and the guidance in the latest edition of MFAG.

7.2           Medicines and equipment already available in the IMGS list may be counted toward the MFAG numerical requirement, if appropriate and should be stored and registered together with the regular medicines and medical supplies carried on board.  

7.3           Where a cargo, classified as dangerous, has not been included in the most recent edition of MFAG, the necessary information on the nature of the substances, the risks involved, the necessary personal protective devices, the relevant medical procedures, and specific antidotes should be made available to the seafarers via the vessel’s occupational safety and health policies.

8.             Medicines for Passenger Ships

8.1           In addition to the medical stores under Sec. 4 above, Passenger Ships that do not normally carry a medical doctor, particularly Ro-Ro Passenger Ships, are required to carry a Doctor’s Bag as per the Second Schedule of S.I. 2025 No. 32.

8.2           The Doctor’s Bag should be clearly labelled as follows:

.1                        “The medicines in this case are only to be used by a qualified medical practitioner, qualified nurse with maritime-situational healthcare competence, qualified paramedic, or someone under the direct supervision of a medical practitioner on board the vessel”.

8.3           Passenger Ships shall carry one first aid kit as per Sec. 5 above, for every 100 passengers or a fraction of that number, subject to a maximum requirement for 3 kits, e.g. 250 persons require three kits. A first aid kit is to be included in the Doctor’s Bag.

9.             Medical Guides and Maritime TeleMedical Assistance Services

9.1           The Master of every vessel shall carry on board the guides to the use of medical stores listed in the Fourth Schedule of S.I. 2025 No. 32, including instructions for the use of antidotes, and The Admiralty List of Radio Signals, Volume 1 (NP281)—Maritime Radio Stations (Parts 1 & 2) lists and all Maritime TeleMedical Assistance Services (TMAS) worldwide.

10.         Precautions against Malaria

10.1       The Master of every vessel voyaging in an area susceptible to malaria shall provide a copy of the advice set out in the Fifth Schedule of S.I. 2025 No. 32 to all passengers and crew.

11.         Controlled Drugs

11.1       Controlled drugs are graded according to the harmfulness attributed to them when misused. There are three drug categories:

.1                        Class A includes heroin, morphine, and opium;

.2                        Class B includes barbiturates and codeine; and

.3                        Class C includes, among other drugs, anabolic steroids.

11.2       A vessel shall not carry excess quantities of Class B and C drugs unless required by a doctor or authorised by the BMSR.

11.3       Morphine Sulphate is the only controlled Class A drug authorised to be carried aboard Barbados vessels and in the doctor’s bag.

11.4       Controlled drugs shall be obtained only from a retail pharmacist or other person licensed to supply drugs, through the use of an order, signed by the vessel’s owner or its Master, or by a person authorised by him, in the form PPO01-F17 Controlled Drugs Requisition or an equivalent with the same wording.

11.5       Every vessel shall have a lockable medical cabinet for the storage of medicines and drugs. The cabinet shall have an inner cupboard solely for the storage of controlled drugs, fitted with a door and a separate lock that cannot be opened with the key to the medical cabinet. Only the Master or a person authorised by him may open the inner cupboard.

11.6       A Controlled Drugs Register as per Sec. 13.5 below shall be maintained by the Master and shall be kept onboard for 2 years after the date of the last entry.

12.         Inspection and Certification Requirements

12.1       MLC, 2006 Standard A4.1.4(a) requires a competent authority to inspect the vessel’s medical stores at regular intervals not exceeding 12 months.

12.2       The inspection can be carried out by a competent person or the authorities of a country where Barbados has an STCW Recognition Agreement, as listed in Sec. 5 of Bulletin 021 and shall ensure that the vessel is carrying the required medical stores, that these stores are correctly stored, and that any perishable medicines have been replaced. The labelling, expiry dates, and conditions of storage of all medication, along with directions for their use, are to be checked, and all equipment shall function as required.

12.3       Annual Flag State inspections will verify that the medical stores are adequate and have been certified within the last 12 months.

12.4       Inspection and certification of the medical stores can be carried out on board or remotely. Where physical attendance on board is not feasible, the Master shall:

.1                        Ensure that the medicines have not been expired and their packaging and supplies are not damaged;

.2                        Ensure that the medical equipment is usable and free from any damage;

.3                        Provide the inspecting authority with the updated medicine list;

.4                        Provide information to the authority conducting the inspection of whether the ship falls into WHO Category A, B, or C based on ship type and distance from shore and whether the medical stores are stocked in accordance with Sec. 4 above;

.5                        Confirm with the inspecting authority the number of persons allowed on board by the Cargo Ship Safety Equipment Certificate;

.6                        Inform the inspecting authority whether the vessel carries dangerous goods or chemicals.

12.5       If the review shows that the medicine chest is stocked appropriately for the particular vessel’s route, operation, and number of persons on board, then documentation certifying this shall be obtained from the inspecting authority.

12.6       This documentation shall include a statement that all required contents of the medical store are present and will not expire during the period covered by the issued documentation. The documentation (which could be in a certificate form) shall also include, to the extent possible:

.1                        IMO Number;

.2                        Name of Vessel;

.3                        Registry of Vessel;

.4                        Unique serial number or ID code on the document; and

.5                        Issuing and expiry dates.

12.7        The document or certificate shall be signed and stamped by the authority carrying out the inspection, and it should display their full name and title.

12.8       If the review results indicate that the medical stores are not suitable for the specific vessel’s route, operation, and number of persons on board, the Master shall take corrective action. The Master shall secure signed and stamped documentation from the authority conducting the inspection once the medical stores are considered appropriate. The authority conducting the inspection shall include its full name on the document.

13.         Recordkeeping and Reporting Requirements

13.1       Electronic Records

.1                        All records required under this section may be kept and managed electronically.

13.2       Inventory of Medicines

.1                        A list of medicines and medical supplies shall be maintained on board all Barbados vessels.

.2                        The list shall be regularly updated and contain the expiration date, storage conditions, quantities remaining after purchase or use, and disposal information for each item.

.3                        The medical stores shall be inventoried no less than once a year. All items in the medical stores should have an expiration date and be resupplied as necessary by the expiry date.

13.3       Ship Master Medical Report Form

.1                        The Master or designated and certified onboard medical care provider shall complete the PPO01-F14 Ship Masters Medical Report Form when a seafarer’s treatment aboard a vessel needs to be rendered on shore, send it to the BMSR at Ops@barbadosmaritime.com, and it shall be kept by the Shipowner for a period of two years.

.2                        The purpose of the PPO01-F14 Ship Masters Medical Report Form is to facilitate the exchange between the vessel and shore regarding a seafarer’s medical condition and related information in cases of illness or injury.

.3                        The information shall be kept confidential and only used to facilitate the treatment of seafarers.

13.4       Medical Log

.1                        Each vessel shall keep a medical logbook wherein every case of illness or injury happening to any member of the crew, passenger or other persons engaged in the business of the vessel, the nature thereof, and the medical treatment shall be entered.

13.5       The Controlled Drugs Register shall: 

.1                        Detail why, when, and in what quantity the Master purchased controlled drugs, as well as the history of their dispensing or disposal; 

.2                        Be retained for two years after the date of the last entry. 

14.         Disposal of Medicines and Medical Supplies

14.1       Medicines and medical supplies shall be disposed of properly as per all applicable local and national laws and regulations of the State where disposal occurs and any appropriate international requirements.

14.2       Disposal of Non-Controlled Medications and Medical Supplies:

.1                        Expired medicines and medical supplies should be returned to the supplier, where possible, or sent to an approved shoreside contractor for disposal.

.2                        If disposal is not possible, expired medicines and medical supplies may be incinerated at sea where a vessel has in place a written waste disposal policy and a program that includes incineration at appropriate temperatures by exclusively authorised personnel. Records of these incinerated medicines and medical supplies shall be kept as part of the medical inventory.

.3                        There are licensed pharmaceutical distribution centres that supply and dispose of prescription and non-prescription medications for marine vessels globally.

14.3       Disposal of Controlled Drugs:

.1                        There are various methods to dispose of controlled drugs lawfully. They include:

i)            Giving them to a person who may lawfully supply them, such as a qualified doctor or pharmacist;

ii)          Incineration;

iii)         waste encapsulation;

iv)         inertisation.

.2                        Whatever disposal method for a controlled drug is used, the following conditions shall be met:

i)            The method used shall be properly implemented; and

ii)           The entire process from unpacking through to the controlled drug’s final destruction shall be witnessed by at least two persons and documented in the Controlled Drugs Register of Sec. 13.5 above.

15.         Carriage of Defibrillators

15.1       There is no statutory requirement under international or national legislation for vessels to carry defibrillators. It is a matter for individual operators to decide whether to include a defibrillator with the medical stores or the Doctor’s Bag.

16.         Hospital

16.1       Vessels carrying 15 or more persons engaged in a voyage of more than three days shall provide separate hospital accommodation which is to be used exclusively for medical purposes.

17.         Medical Oxygen

17.1       Under MLC Regulation 4.1, vessels shall maintain adequate medical oxygen to address crew health needs.

17.2       The medical oxygen cylinders or systems shall be sufficient for the vessel’s size, crew complement, and voyage duration and shall meet the International Pharmacopoeia or WHO International Medical Guide for Ships, 3rd edition standards.

17.3      The Oxygen cylinders can be located either inside or outside of the hospital. If located inside the hospital, it shall be ensured that the space is properly ventilated in case of escape of the oxygen from the cylinder, and that the cylinders are located so that they cannot be easily damaged or disturbed. If located outside of the hospital, the cylinders shall be stored in a protected location that they cannot be easily damaged or disturbed and not exposed to excessive heat, flammable materials, corrosive atmosphere, and direct sunlight. The systems shall be regularly inspected for integrity, with valves and regulators maintained to prevent accidental release.

17.4       Systems shall be regularly inspected for integrity, with valves and regulators maintained to prevent accidental release

17.5       For certain cargoes, the IMDG Code requires the carriage of oxygen resuscitation equipment as specified in the MFAG.

17.6       Vessels subject to MFAG Column A or B are required to carry a minimum of 44 litres/200 bar oxygen as follows:

.1                        one 40 litre/200 bar medical oxygen cylinder located in the vessel’s hospital, assembled for direct use, equipped with one flowmeter unit (with two ports) for supplying oxygen for two persons simultaneously; and

.2                        one complete portable set, ready for use, with a 2 litre/200 bar medical oxygen cylinder and a 2 litre/200 bar spare cylinder.

17.7       The single 40 litre/200 bar medical oxygen cylinder of Sec. 17.6.1 above may be substituted with either two 20 litre/200 bar cylinders or four 10 litre/200 bar cylinders, provided the equipment/flowmeter units are arranged to supply oxygen to two persons simultaneously.

17.8       Medical oxygen cylinders with less than a 200 bar filling pressure may be used, provided that the total volume of oxygen delivered by multiple cylinders is at least equal to that contained in a 40 litre/200 bar cylinder or  2 litre/200 bar cylinders, as required by 17.6.1 and 17.6.2 above.

17.9       Medical oxygen cylinders shall be hydrostatically tested every five years or at an interval specified by the manufacturer, whichever occurs sooner.

17.10    The contents of the medical oxygen cylinders shall be checked and changed as required by the manufacturer’s instructions, and the entire system shall be inspected annually by a competent person in accordance with the manufacturer’s instructions.

17.11    Vessels issued with a valid Document of Compliance for Dangerous Goods do not need to carry the additional medical oxygen cylinders as requested by MFAG and as listed in Sec. 17.6 above when not loading, carrying, or discharging dangerous goods.

17.12    The shipboard Safety Management System shall include provisions to ensure that the cylinders and system will be provided onboard before the vessel begins any of these operations with dangerous goods.

 

Revision No

Description Of Revision

1.0

First Issue

1.1

Amended Sec.17.6 and 17.11

1.2Sec. 17.3 rewritten
  
  
  
  

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MC 062025 – GPS Spoofing and Enhancing Cybersecurity

Notice to: Shipowners, Operators, Officers, and Recognised Organisations.

Download Marine Circular 

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

1. Background

1.1 The Maritime Safety Committee, at its 104th session (4th to 8th October 2021), through MSC.1/Circ.1644, considered the deliberate interference with Global Navigation Satellite Systems (GNSS) and the United States’ Global Positioning System (GPS), as reported in various locations throughout the world. The Committee recalled that satellite navigation system signals are vulnerable to deliberate interference intended to disable or deceive signal receivers and integrated navigational and communications equipment.
1.2 The Committee noted that these incidents of deliberate interference have been reported in several locations and were evaluated by certain organisations having specialised equipment and expertise necessary to analyse the cause and impacts to maritime shipping.
1.3 The Committee also noted that the deliberate interference with satellite navigation system signals possess a substantial risk to the safety of navigation, the safety of life and property, and the protection of the marine environment.
1.4 The Committee reminded Member States of their responsibility to refrain from interfering with GPS and GNSS signals.

2. Purpose

2.1 As of the current date, the International Maritime Organization (IMO) has not issued any specific guidelines solely for mitigating GPS spoofing on ships. However, the maritime industry acknowledges the significant threat posed by GNSS jamming and spoofing, which can disrupt critical positioning, navigation, and timing (PNT) data essential for maritime safety.
2.2 This Marine Circular provides for the issue of warning notices to minimise negative effects upon maritime operations as per MSC.1/Circ.1644 and for advice on best practices on mitigating GPS spoofing and enhancing cybersecurity in maritime operations.
2.3 By implementing these measures, maritime organisations can significantly enhance their cybersecurity posture and can better protect their operations from cyber threats.
2.4 Operators are advised to contact the vessel’s Recognised Organisation and the provider of the systems and services installed on board the vessel for better and more detailed action.

3. GNSS Jamming and Spoofing

3.1 To Address GNSS Jamming and Spoofing Threats:
.1 Monitoring and Detection:
i) Remain vigilant for position loss alarms and any unexpected deviations on the Electronic Chart Display and Information System (ECDIS);
ii) Regularly compare radar data with ECDIS to identify inconsistencies that could indicate spoofing.
.2 Response Procedures:
i) In case of confirmed GNSS disruptions, switch to Dead Reckoning mode;
ii) Commence manual position plotting, using all other available means, including radar and celestial observations, to maintain navigational accuracy;
iii) Implement enhanced monitoring using additional visual lookouts and radar-based navigation techniques to mitigate the risks of GNSS unreliability.
.3 Training and Awareness:
i) Ensure crew members are trained to recognise signs of GNSS spoofing and understand appropriate response protocols;
ii) Incorporate GNSS disruption scenarios into regular safety drills and training programs.
.4 Technological Measures:
i) Consider investing in anti-jamming and anti-spoofing technologies to enhance the resilience of navigation systems against such threats;
ii) By integrating these measures into standard operating procedures, shipping companies can better safeguard their vessels against the risks associated with GPS spoofing.

4. Enhancing Cybersecurity

4.1 For Enhancing Cybersecurity in Maritime Operations:
.1 Risk Assessment and Management:
i) Conduct regular risk assessments to identify potential vulnerabilities and areas needing improvement;
ii) Develop a comprehensive cybersecurity risk management plan tailored to specific maritime operations.
.2 Access Control:
i) Implement strict access control measures to ensure only authorised personnel can access sensitive systems and data;
ii) Use multi-factor authentication and robust password policies to enhance security.
.3 Network Security:
i) Segregate networks to limit the impact of potential breaches and prevent unauthorised access between different systems;
ii) Deploy firewalls, intrusion detection systems, and intrusion prevention systems to protect against external threats.
.4 Regular Software Updates and Patch Management:
i) Keep all software and systems up to date with the latest security patches and updates to protect against known vulnerabilities.
.5 Training and Awareness:
i) Conduct regular cybersecurity training for crew members and shore-based staff to raise awareness and educate them about potential threats and best practices;
ii) Develop a culture of cybersecurity awareness where everyone understands their role in maintaining security.
.6 Incident Response Planning:
i) Develop and regularly update an incident response plan to ensure a swift and effective response in the event of a cybersecurity incident;
ii) Conduct drills and simulations to test the effectiveness of response plans and improve preparedness.
.7 Data Encryption:
i) Use encryption to protect sensitive data both in transit and at rest, ensuring confidentiality and security.
.8 Physical Security:
i) Implement physical security measures to protect IT infrastructure and equipment from unauthorised access or tampering.
.9 Collaboration and Information Sharing:
i) Collaborate with industry partners, government agencies, and cybersecurity experts to share information about threats and best practices;
ii) Participate in cybersecurity initiatives and forums to stay informed about emerging threats and solutions.
.10 Compliance with Regulations and Standards:
i) Adhere to relevant international and national cybersecurity regulations and standards, such as the IMO’s guidelines on maritime cybersecurity.

5. Useful Links

5.1 A list of useful links, although not exhaustive, is provided below for more information on the subject.
.1 https://britanniapandi.com/2024/10/navigational-risks-at-sea-the-growing-threat-of-gnss-jamming-and-spoofing/
.2 https://north-standard.com/insights-and-resources/resources/articles/gps-jamming-spoofing-and-hacking
.3 https://www.imo.org/en/mediacentre/pressbriefings/pages/joint-imo-icao-itu-statement-satellite-interference.aspx
.4 https://wwwcdn.imo.org/localresources/en/MediaCentre/PressBriefings/Documents/ICAO-IMO-ITU%20Joint%20Statement.pdf

6. Validity

6.1 The validity of this circular is until withdrawn or superseded.

For any inquiries or clarifications for this marine circular, please contact:
ops@barbadosmaritime.com
Operations Department
Barbados Maritime Ship Registry

 

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Barbados Maritime Ship Registry Celebrates Four Years of Giovanni Ciniglio

We proudly celebrate Giovanni Ciniglio four-year anniversary as CEO and Principal Registrar of the Barbados Maritime Ship Registry.

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Bulletin 018 – Marine Accident Reporting 2.0

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

 

1. References

a) Barbados Merchant Shipping Act, 2024
b) S.I. 2025 No. 33 MERCHANT SHIPPING (MARITIME ACCIDENT AND INCIDENT INVESTIGATION) REGULATIONS, 2025
c) IMO Resolution MSC.255(84) Code of the International Standards and Recommended practices for a safety investigation into a Marine Casualty or Marine Incident (Casualty Investigation Code)
d) The International Safety Management Code (ISM Code)
e) Bulletin 035 – Piracy and Armed Robbery
f) Bulletin 010 – Barbados Reporting Requirements
g) IMO Resolution A.1056(27) Guidelines on Fair Treatment of Seafarers
h) PPI01-F01 Accident Report Form

2. Purpose

2.1 This Bulletin provides information on BMSR’s reporting requirements for reporting Marine Accidents and Marine Safety Investigations.
2.2 This Bulletin does not cover reporting of Piracy incidents, which are addressed in Bulletin 035.
2.3 This Bulletin does not cover the reporting of Piracy incidents, which are addressed in Bulletin 035.

3. BMSR Contact Details

3.1 In case of emergency the BMSR contact details are as per below:
.1 Email: accidents@barbadosmaritime.com
.2 Emergency 24-hour phone: +44 (0) 7494 116 754

4. Application

This Bulletin applies to all Barbadian vessels engaged in international voyages.

5. Definitions

For the purposes of Section 229 of the CAP 296, “marine accident” refers to both a marine casualty and a marine incident as defined in this section.
5.1 For the purposes of Section 2(1) of the S.I. 2025 No. 33, “marine accident” refers to both a marine casualty and a marine incident as defined in this section.
.1 The death of, or serious injury to a person. In this context, a serious injury renders the person unable to perform their usual duties for >72 hours and includes occupational accidents;
.2 The loss of a person from a vessel;
.3 The loss, presumed loss, or abandonment of a vessel;
.4 Material damage to a vessel or marine infrastructure. In this context, material damage means the structural integrity, performance or operational characteristics of the vessel or infrastructure are significantly affected and require major repair or replacement of a major component or components.
.5 The vessel is unfit to proceed or requires flag state approval or a condition of class before it is allowed to proceed.
.6 At sea, a breakdown of the vessel, required towage.
.7 The stranding or disabling of a vessel, or the involvement of a vessel in a collision.
.8 Damage to marine infrastructure external of a vessel that could seriously endanger the safety of the vessel, another vessel or any individual.
.9 Pollution, caused by damage to a vessel or vessels.
5.2 A very serious marine casualty means a marine casualty involving the total loss of the vessel or the death of a person or severe damage to the environment.
5.3 A marine incident, is an event or sequence of events, which has occurred directly in connection with the operation of a vessel that does not meet the criteria to be classified as a marine casualty (as in Section 5.1 above) but that endangered or, if not corrected would endanger, the safety of the vessel, its occupants or any other person or the environment.
5.4 A marine incident or marine casualty does not include a deliberate act or omission, with the intention to cause harm to the safety of a vessel, an individual or the environment.

6. Marine Accident Reporting

6.1 The Master or senior surviving officer of a Barbadian vessel must notify the BMSR of any marine accident, regardless of location.
6.2 The vessel’s owner or manager must notify the BMSR of any marine accident unless they are satisfied that the Master or senior surviving officer has made the report.
6.3 All notifications are treated confidentially, and a reporter’s identity will not be released.
6.4 Any notification of a marine accident made to the BMSR does not remove any obligation to notify other Organisations, such as Coastal and Port State authorities.
6.5 The BMSR should be informed immediately if a port or coastal State initiates an investigation or takes any other action in relation to an accident.
6.6 An Initial Report of any accident must be sent to the BMSR within 24 hours of the occurrence, via telephone or email. The Initial Report should provide brief details of the incident, such as:
.1 vessel’s name and IMO number;
.2 the nature of the accident, date, and time;
.3 vessel’s location, and next port of call if at sea;
.4 confirmation that port or coastal State authorities have been notified; and,
6.7 Notification must not be delayed until the completion of an internal company investigation.
6.8 And follow up to the initial report, PPI01-F01 Accident Report Form must be submitted within 24 hours.

7. What not to Report

7.1 There is no requirement to report:
.1 Defects to equipment and vessel detentions unless they are related to a marine casualty or marine incident.
.2 Injuries to passengers that did not result from activities connected with the operation of the vessel. For example: a passenger suffering a fall on board a vessel, where the vessel’s movement, design, or acts or omissions by crew were not contributing factors.
.3 Damage or injuries occurring ashore, which do not involve the vessel’s equipment.
7.2 Notwithstanding the list of serious marine casualties contained in Section 6.1, Owners and the Master are encouraged to report to the BMSR any accident which may fall within the scope of their ISM Code reporting requirements.

8. Evidence

8.1 Following a marine accident, the BMSR may require access to additional information and evidence. Therefore, all charts, logbooks, recorded data (hard copy or electronic) relating to the period prior to, during and after the marine accident, and all other documents, records and equipment which may be pertinent to the marine casualty or marine incident must be preserved.
8.2 Where a vessel is fitted with a Voyage Data Recorder, the data recorded by it must be saved immediately and steps taken to prevent the data becoming overwritten. Preservation is mandatory for marine casualties.

9. Accident follow up and Marine Safety Investigation

9.1 Following a preliminary review of the facts provided in the initial reporting and PPI01-F01 Accident Report Form (when applicable), the BMSR may seek to obtain such information as it considers necessary concerning the marine accident and any remedial action taken. A description of actions taken and/or recommendations made to prevent recurrence may be requested. In some cases, the Company’s investigation report will be sufficient, but the BMSR may seek further details if required.
9.2 A Marine Safety Investigation (MSI) will be conducted for all the very serious marine casualties, as defined in Sec. 5.2 above.
9.3 A marine safety investigation might be conducted into marine casualties (other than very serious marine casualties) and marine incidents if it is considered likely that an MSI will provide information that can be used to prevent marine accidents in the future.
9.4 The purpose of an MSI is to help prevent further avoidable accidents from recurring, it does not seek to apportion blame or establish liability. Instead, it works alongside shipowners to help ensure that lessons learned from a casualty are implemented and the likelihood of recurrence is reduced.
9.5 When an MSI is carried out, the BMSR publishes the MSI report that includes safety recommendations and safety learning to improve safety at sea.

10. Offences

10.1 Under Section 19(1) of the S.I. 2025 No. 33 it is an offence not to report a marine accident or provide information required without reasonable cause. This may result in the suspension of the certificate of registry (COR) of the vessel until the contravention is rectified, or in the deletion of the vessel from the register.
10.2 A person who commits an offence as per Section 19(1) of the S.I. 2025 No. 33 is liable on summary conviction to a fine of USD 25,000. A person who fails without reasonable cause to comply with Section 19(1) of the S.I. 2025 No. 33 commits an offence and is liable on summary conviction to a fine of USD 12,500 or, on conviction on indictment, to a fine of USD 37,500.

11. Rights and Fair Treatment during MSIs

11.1 MSIs are conducted in accordance with Resolution A.1056(27) and witnesses have the right to:
.1 nominate a person to be present during interviews (with BMSR approval);
.2 receive legal advice if there’s risk of self-incrimination;
.3 and access their own written statements upon request.
11.2 BMSR may exclude accompanying persons if their presence hinders the investigation.

12. MSI Draft Reports and Comments

12.1 Substantially interested States or parties are given the opportunity to comment on a draft report prior to final publication. BMSR will:
.1 allow 30 days for comments;
.2 address significant objections in the final report; and
.3 require assurance that drafts will not be circulated or disclosed.
12.2 This process supports transparency and ensures factual accuracy before public release.

13. Confidentiality and Independence

13.1 All investigation materials—including VDR data, medical info, and witness statements—are confidential. These are not disclosed for purposes other than the MSI unless ordered by a court or otherwise authorised by BMSR.
13.2 Statements remain the property of the individual and may only be shared with their explicit consent.
13.3 BMSR ensures that MSIs are conducted independently, without external influence. Investigators operate free from commercial, political, or legal pressures. The process is impartial and confidential.

Revision History:

 

Revision No

Description Of Revision

1.0

First Issue – supersede:  Bulletin 317 : Casualty and Accident/Incident Reporting Requirements Rev.1.0

Content moved from Bulletin 010

1.1

Amended phone number in sec. 3.1.2

1.2

Amended email address in sec. 3.1.1

1.3

Amended Sec. 1. b, 2.3, 3.1, 5.1.4, 5.1.5, 5.1.6, 5.2, 5.3, 5.4, 6.2, 6.8, 7,9, 9.2, 9.5 and 10.2

2.0

• Amended Sec.1 All references with hyperlinks
• Amended Sec. 2.3, 5.1, 10.1 wording and cross-reference fields
• Rewritten Sec. 10.2
• Amended Sec. 6.8, 9.1 with new reporting form
• Added new sections: 11,12 and 13.

 

 

 

 

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