Bulletin 022 – Barbados Change of Flag Surveys Rev 1.0

1.             References

a)              Barbados Merchant Shipping Act, 2024

b)              IACS PR 28 Procedure for Change of Flag

c)              Bulletin 008 – Permits Exemptions and Equivalences 

2.             Purpose

2.1           The purpose of this Bulletin is to define the surveys required when a vessel is transferring under the Barbados flag, and under what circumstances those surveys may be conducted remotely, in line with IMO Conventions and IACS PR 28.

3.             Scope of the Change of Flag (CoF) survey

3.1           The primary purpose of a Change of Flag (CoF) survey is to confirm full compliance with the requirements of the relevant international conventions under the Barbados flag. Upon satisfactory completion of the CoF survey, all statutory certificates shall be re-issued under the Barbados flag with validity dates harmonised, as far as practicable, with the vessel’s established survey cycles.

3.2           Upon completion of CoF survey (remote or physical), the Recognised Organisation (RO)  shall issue full statutory certificates
even if the vessel still holds a BMSR Provisional Certificate of Registry.

3.3           When the CoF survey is carried out within the prescribed annual/intermediate/renewal survey windows, the CoF survey shall be carried out to the extent of these surveys. Due consideration shall be given to the circumstances in order to avoid unreasonable burdens as could be, inter alia, a necessary dry-docking of the ship for renewal survey of the SOLAS Cargo Ship Safety Construction Certificate or similar.

3.4           In case where there is no change of RO and if the losing flag State Administration is Party to the relevant IMO Conventions, then surveys conducted by the RO within a three months’ time period prior to the date of Change of Flag may be credited towards CoF survey with the exception of SOLAS Safety Radio survey.

3.5           If the Change of Flag is to be undertaken outside the windows of the due dates for surveys of new certificates which are going to be issued on behalf of Barbados, then the scope of surveys shall be in line with Sec 3.2 of the IACS PR 28.

3.6           CoF surveys carried out at a date which is outside of appropriate time windows for the corresponding certificate issued on behalf of Barbados are to be understood as additional surveys which are carried out solely for the purpose of Change of Flag. These surveys do not replace the surveys required to be carried out within the appropriate time windows.

4.             RO obligations and reporting

4.1           When the vessel has been certified with Alternative Design and Arrangements or permanent exemptions, the RO shall provide BMSR with information or documentation for BMSR reissuance of relevant documents of approval and permanent exemptions.

4.2           The RO shall reapprove on behalf of Barbados all plans and drawings directly by another flag Administration or on behalf of a flag Administration not Party of the IMO Conventions.

4.3           The plans and drawings approved by the same Barbados RO that approved them on behalf of the losing flag Administration, which is Party of the IMO Conventions, do not need to be reapproved unless explicitly required by the IMO Conventions.

4.4           In cases where the existing Shipboard Oil Pollution Emergency Plan (SOPEP) or Cargo Securing Manual (CSM) cannot be reapproved at the time of CoF, the RO shall request a temporary permit from the BMSR, in accordance with Sec. 5 of BMSR Bulletin 008 – Permits Exemptions and Equivalences, to authorise the vessel to sail under the Barbados flag pending approval of the plans.

4.5           The RO shall always submit to the BMSR the following certificates, as applicable:

.1              Certificate of Class;

.2              International Tonnage Certificate;

.3              International Loadline Certificate;

.4              Safety Management Certificate;

.5              International Ship Security Certificate;

.6              Maritime Labour Certificate.

5.              Remote CoF Surveys   

5.1           The remote CoF surveys is a process of verifying that a vessel and its equipment are in compliance with the Statutory requirements where the verification is undertaken, or partially undertaken, without attendance on board by a surveyor.

5.2           The remote CoF survey is not to be considered as an alternative to a survey attended on board by a RO Surveyor, but as an additional and temporary measure to facilitate the registration of the vessel, when physical attendance is not feasible.

5.3           Remote statutory activities not requiring a survey, such as some administrative tasks, are not to be considered as remote surveys. An administrative task is a task where a survey decision is not being made, for example reissue of a certificate or record following a correction, or an update to the vessel’s records held by the RO or a document review.

5.4           The BMSR permits remote CoF surveys only for vessels:

.1              Of less than 20 years of age;

.2              With no PSC detentions or significant PSC findings in the last 36 months;

.3              With most recent statutory and class surveys completed within the past 12 months;

.4              With the Owners and Managers’ positive compliance record.

5.5           Remote CoF Surveys are Not Permitted for a vessel that transfers from a non-IACS member and/or from another RO.

5.6           For a Remote CoF Survey, the RO shall submit a request for a remote survey to BMSR, with justification and evidence. The request shall not be based on economic factors but mainly on the unavailability of the RO surveyor to attend the vessel in a remote location.

5.7           The RO shall also provide the list of known ports of call and propose the best suitable port for carrying out the CoF survey by physical attendance.

5.8           Upon assessment of the remote CoF survey the BMSR shall issue an official letter for authorisation of the CoF survey to be carried out remotely and administratively with relevant conditions.

5.9           The BMSR will only authorise the remote CoF survey if the RO will carry out a physical attendance survey with the same extent as per IACS PR 28 within 3 months from the issuance of the authorisation .

5.10       Upon completion of the remote CoF survey, the RO shall issue short-term statutory certificates with the validity of 3 months as per BMSR authorisation.