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

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

1. Purpose

1.1 This Marine Circular is issued by the Barbados Maritime Ship Registry (BMSR) to address registration of vessels subject to sanctions imposed by international community and bilateral partners with respect to the reported operation of a “dark fleet” or “shadow fleet” in the international maritime sector.
1.2 The Government of Barbados being a Member State of the International Maritime Organization (IMO), has a
duty to uphold maritime safety, security and marine environmental protection standards of the IMO, and
to this end, is undertaking administrative and legislative measures to promote actions to prevent illegal operations
in the maritime sector by the “dark fleet” or “shadow fleet”, to implement IMO Resolution A.1192(33) Adopted on 6 December, 2023 – Urging Member States and All Relevant Stakeholders to Promote Actions to Prevent Illegal Operations in the Maritime Sector by the “Dark Fleet” or “Shadow Fleet”.

2. Application

2.1 This Marine Circular applies to any vessel that is intended to register with the BMSR or that is already registered with the BMSR.

3. Background

. 3.1 The BMSR has been instructed by the Government of Barbados not to register any vessel linked to sanctions imposed in respect of paragraphs 1.1 and 1.2 above.
3.2 When a registration request is sent to the BMSR, the BMSR will check for any sanctions against the vessel and will proceed with registration only after verifying that the vessel is not subject to the sanctions mentioned above.
3.3 For a vessel that becomes sanctioned while registered under the Barbados flag, the BMSR will first exercise due diligence to verify that the registered vessel is indeed sanctioned, and once confirmed to be a sanctioned vessel, remove the said vessel from the Register.
3.4 From the effective date of this Marine Circular, an administrative penalty of 25,000 USD (50,000 BBD) will be imposed on any Barbados-registered vessel that is sanctioned.
3.5 The administrative penalty specified at 3.4 shall be paid during the vessel’s de-registration process.

4. Recommendations

4.1 Shipowners and managers wishing to register a vessel with the BMSR must ensure that the vessel is not subject to the sanctions mentioned above.
4.2 Shipowners and managers of vessels that risk being subject to the mentioned sanctions are strongly recommended to deregister the vessel from BMSR at the earliest to avoid the administrative penalty.
4.3 If a vessel is de-registered due to the sanctions above, the BMSR will not release the deletion certificate or the ceased CSR until the administrative penalty and BMSR fees are paid in full.

5. Validity

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

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

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

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1.             Purpose

1.1           This Marine Circular is issued by the Barbados Maritime Ship Registry to address:

i)           The new regulations on sulphur content of fuel oils used on board in the Mediterranean Sea Emission Control Area for Sulphur Oxides and Particulate Matter, from 1 May 2025; and

ii)          The discharge requirements of regulations 15.3, 15.5 and 34.3 to 34.5 of MARPOL Annex I in respect to the Red Sea and the Gulf of Aden Special Areas, in force from 1 January 2025, in accordance with the requirements set out in regulation 38.8.1 of MARPOL Annex I.

iii)        The discharge requirements of Regulation 6 of MARPOL Annex V with respect to the Red Sea Special Area in accordance with Regulation 8.2 of MARPOL Annex V, in force from 1 January 2025.

2.             Application

2.1           This Marine Circular shall be read in conjunction with:

i)           MEPC resolution MEPC.361(79) amending MARPOL Annex VI, Regulation 14

ii)          BMSR Bulletin 027 – MARPOL Annex VI Rev.1.4

iii)        Resolution MEPC.381(80)

iv)        Resolution MEPC.382(80)

3.             Technical Requirements

3.1           From 1 May 2025, all Barbadian vessels subject to MARPOL Annex VI and operating in the Mediterranean Sea are, in principle, required to use on board fuel oils with a sulphur content of maximum 0.10 % m/m in accordance with MARPOL Annex VI regulation 14, or use alternative emission reduction and control technologies to comply with the emission standard.

3.2           For all Barbadian vessels 400 gross tonnage and above, after 1 January 2025, any discharge into the sea of oil or oily mixtures shall be prohibited within the Red Sea and Gulf of Aden Special Areas, except when all of the following conditions are satisfied:

i)           The ship is proceeding en-route;

ii)          The oily mixture is processed through an oil filtering equipment meeting the requirements of regulation 14.7 of Annex I;

iii)        The oil content of the effluent without dilution does not exceed 15 parts per million;

iv)        The oily mixture does not originate from cargo pump room bilges on oil tankers; and

v)          The oily mixture, in case of oil tankers, is not mixed with oil cargo residues.

3.3           For Barbadian Oil tankers, after 1 January 2025, any discharge into the sea of oil or oily mixtures from the cargo area of an oil tanker shall be prohibited while in the Red Sea and Gulf of Aden Special Areas.   This requirement shall not apply to the discharge of clean or segregated ballast.

3.4           For all Barbadian vessels, after 1 January 2025, discharge of garbage into the sea within the Red Sea Special Area shall only be permitted while the ship is en-route and as prescribed by Regulation 6 (Discharge of garbage within special areas) of MARPOL Annex V.

3.5           The boundaries of the above Sulphur Emission Control Area and Special Areas are as set forth in the relevant MARPOL Appendices.

4.             Recommendations

4.1           All shipowners, managers, vessel operators and masters of all relevant Barbadian vessels are urged to ensure strict compliance with the new additional MARPOL regulations as per this Marine Circular. 

5.             Validity

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

 

 

For any inquiries or clarifications for this marine circular, please contact: ops@barbadosmaritime.com

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

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1.             Purpose

1.1           The Barbados Maritime Ship Registry (BMSR) issued this marine circular to provide instructions for bottom surveys of cargo vessels registered with the BMSR and the interval between bottom surveys.  

2.             Application

2.1           These instructions apply to all cargo vessels registered with the BMSR.

3.             Technical Requirements

3.1           For cargo ships, as per SOLAS I/10(a)(iv) and Survey guidelines under the harmonised system of survey and certification (HSSC), 2023 (resolution A.A.1186(33)) Sec. 4.6, a minimum of two inspections of the outside of the ship’s bottom during the five-year period of validity of the Cargo Ship Safety Construction Certificate or the Cargo Ship Safety Certificate are required.

3.2           Inspections of the outside of the vessel’s bottom should normally be carried out with the vessel in dry dock. However, consideration may be given to alternate inspections being carried out with the vessel afloat (In water Survey IWS).

3.3           Conditions for In Water Survey (IWS):

i)           For vessels of less than 15 years of age, one bottom survey can be carried out afloat (IWS).

ii)          For vessels of 15 years of age and above, one bottom survey can be carried out afloat (IWS), upon concurrence from the classification society that there are no structural concerns.

3.4           Both bottom surveys shall be carried out with the ship in dry dock:

i)           For bulk carriers and oil tankers of less than 15 years of age but in an enhanced survey Program (ESP);

ii)          For bulk carriers and oil tankers of 15 years of age or above;          

iii)        For any type of vessel of 20 years of age.

3.5           In all cases, the interval between any two such inspections shall not exceed 36 months.

3.6           In ‘Exceptional circumstances’ such as: unavailability of dry-docking facilities; unavailability of repair facilities; unavailability of essential materials, equipment, or spare parts; or delays incurred by action taken to avoid severe weather conditions, the BMSR may allow extension for the bottom survey to be carried out later than 36 months from the previous one.

3.7           The request for any extension of the bottom survey due to the ‘Exceptional circumstances’ mentioned above shall come through the Recognised Organisation (RO), which is responsible for issuing the relevant certificates for the vessel.  The RO shall assess the case and provide the BMSR with their concurrence, reasons and justification, and any supporting documentation.  The BMSR will evaluate the request on a case-by-case basis and may issue a temporary permission with a validity of a maximum of 3 months.

3.8           All requests for temporary permissions for extensions of bottom surveys shall be sent to ops@barbadosmaritime.com

4.             Recommendations

4.1           The justification for the extension of bottom surveys must be on a non-commercial basis.  Similarly, the extension is not to be tied to a matter of convenience, except where an extension is proposed to further a harmonisation of surveys.  There must be exceptional circumstances for not arranging the docking before the due date, and the extension is only to be granted in cases where it is proper and reasonable to do so.  The principal consideration for granting an extension to a docking is the unavailability of suitable docking facilities, as per IACS PR1C and MSC-MEPC.5/Circ.1

4.2           For extensions to the dry docking due to unavailability of docks for up to three months, the following conditions are appropriate:

i)           Evidence that managers have attempted to fix drydocking (3 locations).

ii)          Evidence that a firm drydocking date and location have been made.

iii)        Statement from the Master that no damage to underwater parts has occurred since the last bottom survey.

iv)        Any Class requirements are met in full, and any conditions of class are reviewed.

4.3           In addition, where the extension brings the period since the previous bottom survey (either in drydock or in water survey) to over 36 months, an underwater examination is required.  A one-month grace period may be given where the in-water survey cannot be undertaken due to, e.g. poor visibility.

5.             Validity

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

 

 

For any inquiries or clarifications for this marine circular, please contact:

ops@barbadosmaritime.com

 

Notice to: All Appointed Nautical Inspectors (ANI) of the BMSR

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1.             Purpose

1.1           The purpose of this marine circular is to outline each type of inspection carried out by Barbados Maritime Ship Registry (BMSR) Appointed Nautical Inspectors (ANI) and the requirements for the conduct of the inspections, the Certificates of Inspection, and reports to be produced.

1.2           This procedure sets out the measures for Flag State Inspections as required under sections 1057 and 1058 of the Barbados Merchant Shipping Act, 2024 and Articles 94 and 217 of the United Nations Convention on the Law of the Sea (UNCLOS).

2.             Application

2.1           This Marine Circular shall be read in conjunction with the  Bulletin 004 – Flag State Inspections  and emphasis is given to topics not already covered by the above Bulletin, and also to provide additional guidance. 

3.             Background

3.1           The types of inspections normally conducted by the BMSR are:

i)            Pre-Registration Inspection

ii)          Initial Inspection

iii)         Annual Safety Inspection

iv)         Detention Follow-up Inspection

v)          Additional Safety Inspection

3.2           The Pre-Registration Inspection aims to assess the physical condition of the vessel, and the safety and pollution prevention standards of the vessel.  The Pre-Registration inspection is intended only to assess the physical condition of the vessel and not to assess compliance with Barbados requirements, and availability of Publications, documents, etc, on board.  The documentation and compliance with Barbados’ requirements will be verified in the following inspection, i.e. Initial inspection.  

3.3           The Initial Inspections aim to assess:

i)            the physical condition of the vessel;

ii)          the safety and pollution prevention standards of the vessel;

iii)         the compliance with Barbados requirements (Documents, Publications, Manning, Accident reporting, etc.);

iv)         the competence of the crew;

v)          the marking of the vessel.

3.4           The Annual Safety Inspections aim to assess:

i)            the physical condition of the vessel;

ii)          the compliance with Barbados requirements (Documents, Publications, Manning, Accident reporting, etc.);

iii)         the competence of the crew;

iv)         the maintenance of the vessel.

3.5           The Detention Follow-up Inspections are to be carried out as per a routine Annual Safety Inspection. Still, the ANI shall also assess the correct rectification of the PSC deficiencies raised at the PSC detention and the implementation of preventive measures.  

3.6           The Additional Safety Inspections are to be carried out as per a routine Annual Safety Inspection. Still, the ANI shall also assess any eventual additional items as instructed by the BMSR upon assignment to the inspection.   

3.7           The Initial inspection is required to be completed before the vessel is permanently registered with BMSR.  The ANI must verify, sign and stamp the Carving and Marking Note which will be made available on the vessel, and send to ops@barbadosmaritime.com along with the Inspection Reports. 

3.8           General Guidance for Conduct of Inspections:

a.Inspections are organised and arranged by the managers of the vessel or Regional Registrars directly with the ANI, as listed in the https://barbadosmaritime.org/list-of-appointed-nautical-inspectors/. All costs are agreed directly between the owners/managers and the ANI, and the payment is made directly to the ANI.

b.The ANI shall then approach the BMSR by email to ops@barbadosmaritime.com, along with the email confirmation of his/her appointment from the owners/managers, and it is not required to include any reference to costs. The BMSR shall then issue a unique authorisation code generated from our system and will give any specific instructions including the validity of the Certificate of Inspection (COI) in the authorisation message.

c.Once the authorisation is given, the ANI is expected to carry out the inspection in due time, and exemption is only permitted in cases of emergency due to personal illness, adverse weather conditions or change of vessel’s schedule. The ANI shall promptly inform the BMSR of any such instance.

d.The following documents must be submitted to the BMSR, as found in https://barbadosmaritime.org/inspections/inspection-templates/:

       1.PPO01-F01 Flag State Inspection Checklist

       2.PPO01-F02 Inspection Photos (the photos must be properly attached in the appropriate spaces provided in the form)

      3.Certificate of Inspection (original must be given to the master to be displayed onboard)

e.ANI shall ensure that the forms and the template used for the inspection are the latest revisions found on our website. Obsolete forms must be discarded and never be used, as this will be noted as a non-conformity in our Quality audits.

f.Reports shall be submitted to the BMSR as soon as possible, but not later than 7 days after the inspection. The ANI must inform the BMSR if he/she expects any further delay in submitting the reports.

g.A COI is issued to the vessel’s Master on completion of the inspection, to be displayed in a prominent place on board. The validity of the COI will always be mentioned in the authorisation message, or as “not applicable” if it is not required.  A COI is not issued for a pre-registration inspection. 

h.Where a Major Deficiency is identified and cannot be rectified before completion of the inspection, the inspector:

      i.Must immediately report the situation to the BMSR, via the emergency telephone number if necessary;

      ii.Must not issue a Certificate of Inspection (CoI), as per PPO01-F03, unless instructed to do so by the BMSR;

      iii.Where appropriate the BMSR may take the decision to Flag Detain the Vessel; and

      iv.Further guidance on Major deficiencies may be found in IMO Res. A.1185(33).

i.As proof of inspection, the ANI must send photographs of him/her in at least two different locations on the vessel, and additionally a short video with him/her in the frame conducting a drill on board. Any photograph that appears suspicious or edited will be taken seriously, and the ANI will be promptly removed from service. 

j.If a vessel is detained within 2 months of a Flag State Inspection, the performance of the concerned ANI who carried out the inspection will be evaluated. If there are clear grounds that the ANI had omitted recording any serious deficiency on purpose or by neglect, he/she may be suspended or dismissed from service as deemed appropriate. 

k.All correspondence regarding inspections and ANIs shall be sent to ops@barbadosmaritime.com.

3.9           Appointments of ANIs are normally for a term of three years, which will be renewed upon evaluation of the performance of the ANI.  Renewal notice will be given in due time to the ANI from the BMSR.  If the ANI does not wish to continue, he/she must inform the BMSR via email. 

3.10       Upon appointment, the ANI is issued an ID card and an official stamp, which are sent by post from the BMSR office. The ANI must use this stamp for any relevant official document issued on behalf of the BMSR, including the Certificate of Inspection.

3.11       All ANIs represent the BMSR and are expected to be professional in their conduct.  ANIs are advised not to engage in any dispute or conflict with the master, crew, managers or other representatives of the vessel.  If there is any dispute or if the ANI is not allowed to carry out the inspection in a professional manner, the ANI shall promptly inform the BMSR for further advice.  We want our ANIs to be treated with respect and we also expect the ANIs to treat others the same way.  Any case of bullying or harassment shall be promptly reported to the BMSR.

3.12       Access to the BMSR online system for ANIs for uploading inspections is a work in progress, and all ANIs will be duly informed when ready.

4.             Recommendations

4.1           While it is always ideal and pleasing to have “NIL deficiencies” during any inspection, ANIs are advised to treat such remarks with caution.  It is better to record deficiencies for the purpose of proper follow-up and rectification, to ensure the overall safety of the vessel, the safety of the crew on board, compliance with relevant regulations, and to avoid further problems in future Port State Control Inspections.  The BMSR aims to have safe vessels compliant with all relevant international conventions and codes, and proper feedback from our ANIs is crucial to maintain the highest standards. 

5.             Validity

5.1           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