In a change of policy, Barbados approved inspectors may no longer authorise DMLC Part II documents on our behalf and that it must be left solely to Class.

This Information Bulletin explains the position of Barbados Maritime Ship Registry (BMSR) in respect of establishing policies and procedures for mitigating maritime cyber risk.

This bulletin serves to remind all ship operators and crew of the ongoing requirement to help maintain a ship in good, safe and seaworthy condition.  COVID-19 has added considerably to the difficulties faced by all seafarers and ship operators, but is not an excuse for allowing standards to slip.  The guidance below has been issued previously but remains valid today.

This bulletin serves to notify the shipping community of recognition of documents issued in electronic format and scanned colour copies of originals.  Recognition of the scanned colour copies reduces undue delays while the vessel awaits delivery of the original documents.

Contact Data Sheet for Owners, Operators and Crewing Agents for all Barbados Registered Vessels

Please be advised that Barbados Maritime Ship Registry (BMSR) will no longer receive SSAS alerts directly from any vessels. Shipping companies are required to designate either an internal appointee (preferably the Company Security Officer (CSO) or Alternate Company Security Officer (ACSO) or an external, qualified third party to serve as the “Competent Authority” to receive all SSAS alerts and take appropriate action.

1. Aim
1.1 This Bulletin is intended to provide guidance on the use of electronic record keeping systems, including log books and record books, on board ships registered in Barbados. The Bulletin should be read in conjunction with International Maritime Organization (IMO) Resolutions A.813(19) & A.916(22) and IMO Circular MSC/Circ.982.

2. Introduction
2.1 Barbados legislation and other relevant international Conventions require that specific actions, events and operations be recorded in a log book or record book held on board the ship.
2.2 Barbados Maritime Ship Registry (BMSR) recognises and encourages the growing use of electronic record keeping systems on ships, including log books and record books.
2.3 Hence, the use of electronic record keeping systems for the recording of information required by national legislation and international Conventions is permitted, subject to compliance with this Bulletin and type approvals allowed by Class.
2.4 For the purposes of this Bulletin, electronic records are categorised as:

1. “Official” records required by Barbados legislation or international Conventions and Codes;
2. “Unofficial” records that are not required by national legislation or international Conventions and Codes but are commonly used.

2.5 The following official records may be maintained in an electronic record keeping system:

1. Barbados Official Logbook Part I;
2. Articles of Agreement or Seafarer’s Employment Agreements;
3. Records required by Regulation 17 of Chapter IV of SOLAS;
4. Records required by Regulation 28 of Chapter V of SOLAS;
5. Ballast Water Record Book;
6. Compass Error Book

2.6 Records required under Annexes I, II, V and VI of MARPOL may also be kept electronically, subject to section 5 of this Bulletin.
2.7 The following unofficial records may be maintained in an electronic recording system:

1. Bridge log book (also known as Deck Logbook);
2. Engine room log book;
3. Biofouling Record Book

3. General Requirements for Electronic Record Keeping Systems
3.1 This section outlines the requirements for electronic record keeping systems that are intended to replace paper records of actions, events and operations on board.
3.2 Electronic record keeping systems used to record official records must capture the information required to be recorded in paper log books and record books by the relevant legislation or international Convention.
3.3 The minimum requirements for electronic record keeping systems are as follows:
3.3.1 Electronic Record Keeping System Workstation:

1. The workstation should take in to account relevant ergonomic design criteria such as provided for in MSC/Circ.982.

3.3.2 Updating of Software:

1. Arrangements for software replacement, update or upgrade should be effectively implemented under a documented system.
2. The Company is responsible for ensuring that electronic record keeping systems are maintained to the latest standards required by BMSR or the relevant international Conventions.

3.3.3 Client/Server Installation:

1. Where the system can support a client/server installation, the server should be capable of recording data from clients using multiple workstations simultaneously.

3.3.4 Minimum Data Reporting & Exporting Requirements:

1. The system must be capable of reproducing records in hard copy (i.e. printed out);
2. The system must be capable of producing reports in PDF format;
3. Where data export is provided, the system should allow the data to be exported to another system in XML or other internationally standardised format;
4. Nothing within the system, or the contractual arrangements between the Company and equipment supplier, shall prohibit the provision of information to duly authorised officers of an Administration, inspectors, surveyors, auditors, investigators, etc. relating to the discharge of their duties.

3.4.5 Recording of Entries:

1. All users must have a unique username and password for accessing the system, or other form of login that is unique for each user;
2. The identity of the user making entries into the system must be clearly identified;
3. Where automated recording of navigational and machinery events is featured, the electronic bridge or engine room log book or data logger must be able to record relevant events, along with the necessary inputs, in real time.
4. All entries must have a stamp or input with date and time (UTC and local time on board);
5. The system must not allow the deletion of any entries. Any subsequent amendments or corrections to an entry must be clearly identifiable (e.g. by crossing through the original entry with a line) and show the identity of the user making the amendment or correction;
6. The system must be capable of electronically registering the signature or endorsement of the Master and other responsible Officers on all relevant entries;

3.4.6 Back Up and Recovery of Entries:

1. The power supply to the system should be fed from both the main and emergency source of power;
2. The system should be capable of making secure copies or backups of the entries to ensure that the information will not be lost if the system fails.  The system must be able to recover data from the copies or backups.
3. The system should be able to export all entries to a standard removable storage device, such as a USB memory stick;
4. Official records shall be retained by the system for at least the minimum period specified in the relevant legislation or international Conventions – a guide to retention periods is provided in the Annex.
5. Unofficial records shall be retained by the system for the period established by the Company.

4. Requirements for Specific Records
4.1 Official Log Book Parts I & II:
4.1.1 The Shipping Act does not specify that the Official Log Book has to be a hard (paper) copy, only that a log book is kept and that specific entries are recorded, as listed in the Shipping Act 1994, as amended.
4.1.2 Accordingly, information that is normally recorded in the Official Log Book Part I or Part II may be maintained in an electronic record keeping system, provided that all information required in the relevant section of the hard copy Official Log Book Parts I and/or II is recorded.
4.1.3 Any information in a section of the Official Log Book Parts I and/or II that is not recorded in an electronic record keeping system must be maintained in a hard copy Official Log Book.
4.1.4 In cases where some information is in a hard copy Official Log Book and some is in an electronic record keeping system, the hard copy Official Log Book shall contain a statement indicating where the information recorded electronically is stored.
4.1.5 All sections of the Official Log Book that are maintained electronically must be capable of being printed out in the same layout as the hard copy Official Log Book and exported in PDF format.
4.1.6 Printed pages must be signed by the Master as a true and complete copy of the corresponding entries in the electronic record keeping system.
4.2 MARPOL Annex I – Oil Record Book Parts I & II
4.2.1 Oil Record Book Parts I & II may be kept in electronic format, provided that:

1. Entries cannot be deleted;
2. Any changes to existing entries are clearly shown, along with the identity or electronic signature of the person that made the change;
3. The system is auditable;
4. The record, including any changes, is printed out weekly and the hard copy physically signed by the Master and Chief Engineer;
5. The  weekly  printed  pages  are  in  the  format  specified  in  the Convention for the Record Book; and
6. The weekly pages can be exported in PDF format.
7. Printed Pages are to be maintained onboard for the period noted in MARPOL and the annex of this bulletin.

4.3 MARPOL Annex II – Cargo Record Book for Ships Carrying Noxious Liquid Substances in Bulk
4.3.1 The Cargo Record Book for Ships Carrying Noxious Liquid Substances in Bulk may be kept in electronic format, provided they meet items i. to vi. in paragraph 4.2.1.
4.4 MARPOL Annex V – Garbage Record Book Parts I & II
4.4.1 Garbage Record Books Part I & II may be kept in electronic format, provided they meet items i. to vi. in paragraph 5.2.1.
4.5 MARPOL Annex VI Record Book
4.5.1 Records required under MARPOL Annex VI may be kept in electronic format, provided they meet items i. to vi. in paragraph 5.2.1.
4.5.2  MARPOL VI records may also be kept in the engine room log.
4.6 Crew Management System:
4.6.1 Where electronic management of crew articles is enabled, the system should be capable of recording information relevant to the crew list, including the following:

1. Full name of crew member;
2. Home address;
3. Age;
4. Place of Birth;
5. Nationality;
6. Passport Number;
7. Next of Kin;
8. Position on board;
9. Certificate of Competency details;
10. Place and date of embarkation;
11. Place and date of disembarkation.

5. BMSR Approval of Electronic Record Keeping Systems
5.1 When a Company selects an electronic record keeping system for use on a ship registered in Barbados, the Company shall apply to BMSR for approval and provide the following information:

1. Name and Official Number of all ships that will have the system installed;
2. A statement from the Company confirming the following:

• The installed system complies with the specific requirements set out in this bulletin;
• The crew has been appropriately trained in the management, use and operation of the system, in compliance with Regulation I/14.1.4 of the STCW Convention;
• The routines and processes for the conservation and maintenance of the entries in the system comply with relevant requirements and guidance and procedures for data entry, extraction and retention are incorporated in the Safety Management System;

3. A list of logbooks and record books that will have their entries captured in the electronic record keeping system;
4. System manufacturer’s declaration specifying that the system is installed according to approved existing requirements and that the installed system has been tested and is operating correctly.

5.2 On satisfactory review of the information provided, BMSR will issue a Letter of Approval for Electronic Record Keeping Systems for each ship using the system.
5.3 The Letter of Approval will list the official records permitted to be stored by the system and must be kept on board each ship using the system, for presentation to duly authorised officials when requested.
5.4 Each Letter of Approval for Electronic Record Keeping Systems will be valid for five (5) years from the date of issue and will be subject to the ship being managed by the Company noted on the approval letter.
5.5 The Company is to notify BMSR of any changes to the system or the procedures related to its use in the Safety Management System that affects the Letter of Approval.
5.6 The availability of the Letter of Approval will be verified at Flag annual inspections.

6. Provision of Data to New Managers or Owners
6.1 The international Conventions require certain records to be retained by the ship for specified periods, as indicated in the Annex.
6.2 Accordingly, Companies using electronic record keeping systems must provide the relevant records to the new Company, that cover the required minimum retention period.
6.3 The records may be provided as:

1. a PDF or XML file; or
2. printed out; or
3. in a data format that can be used by the new Company’s system.

6.4 In all cases, the ability to present the records to duly authorised officers upon request must be available on board the ship.

ANNEX – Retention Periods for Entries

The following table provides minimum retention periods for official records.

BMSR 03/08/2020

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

Internal audits on board are mandatory under Reg. 12.1 of the ISM Code.

Some clients have expressed an interest in Barbados approved inspectors carrying out preparatory inspections on board their ships in respect of ISM/ISPS/MLC. It is understood that this could be particularly useful in view of the current Covid-19 pandemic and the many travel restrictions worldwide which are leading to extensions and thus longer intervals between audits. Also, that certain other flag states are allowing their approved inspectors to carry out such preparatory inspections.

There is no objection from Barbados Maritime to their approved inspectors undertaking inspections in preparation for Annual Audits. It is envisaged that inspectors carrying out such audit work would be able to follow client’s in-house checklists/guidance and also provide recommendations, best practice advice and suggestions for improvement.

However, and as with Annual Flag State Inspections, we would not become involved in any charges for the service which would need to be agreed between the client and inspector.

28 July 2020

1. Purpose
1.1. This bulletin is issued by Barbados Maritime Ship Registry (BMSR) to provide information on COVID-19 (formerly called novel coronavirus) related issues.

2. Actions to be taken in case of suspected cases

2.1. Where COVID-19 is suspected, medical advice should be sought.
2.2. The advice of public health authorities in the country where the ship is located when cases are suspected should be sought and any instructions followed.
2.3. Owners/operators are requested to report any suspected or confirmed cases of COVID-19 to BMSR email: registry@barbadosmaritime.com

3. Inspections, surveys and audits
3.1. As a result of the outbreak and the serious challenges the COVID-19 pandemic poses to the shipping industry, BMSR is taking a pragmatic and practical approach regarding extensions, postponements, etc. as outlined below. These measures are temporary, and their duration will be based on the global evolution of the COVID-19 pandemic.

3.2. Barbados Initial, Annual and Pre-Registration Inspections
3.2.1. BMSR inspectors should not put themselves at risk and likewise not put ship’s crews at risk – this means they will follow the guidance of the health authorities in the country where they are located and may decline to attend ships.
3.2.2. Where an initial or annual inspection cannot be carried out before the end of the inspection window, the owner/operator shall advise BMSR providing full supporting information. Inspections should be carried out at the first port where an inspector is available.
3.2.3. The requirement for pre-registration inspections may be waived until 30 Sept. 2020 for ships on a case by case basis.
3.2.4. All ships proposed for registration, with the exception of new builds, remain subject to a pre-registration technical documentation review.

3.3. Surveys
3.3.1. Where a surveyor is not able to undertake scheduled surveys due to restrictions imposed by COVID-19, including cancellation of scheduled  dry docking and/or  bottom survey, and remote survey is not practicable, BMSR authorises its Recognised Organisations (RO) to consider  applications  for extension/postponement under force majeure or unforeseen exceptional circumstances and administratively issue short term statutory  certificates for up to 3 months  without prior approval of  BMSR (see also Bulletin No. 323). This is to be followed up by a physical survey at the earliest opportunity.
3.3.2. For statutory surveys delegated to Barbados ROs, the ROs shall consider the application, which should include full supporting information, before issuing short-term certification. The Master shall provide a statement to the RO confirming the structure or equipment to be surveyed remains fit for purpose and has not been subject to any damage.
3.3.3. Where the structure or equipment to be surveyed does not remain fit for purpose, or has suffered damage, or the RO does not support the application, the RO shall provide full details to BMSR. BMSR will then consider on a case-by-case basis and provide instructions to the RO.

3.4. ISM and ISPS Internal Audits
3.4.1. Timely completion of ISM internal audits is amongst the most frequently reported difficulties. BMSR therefore temporarily permits extensions to annual ISM internal audits for up to 3 months (as per para 12.1 of the ISM Code) in cases where it is not physically possible to attend and remote audit is not practicable. This is to be followed up by a physical audit at the earliest opportunity.
3.4.2. The Company Security Officer may postpone internal ISPS audits for up to three (3) months in cases where it is not physically possible to attend, and remote audit is not practicable. This is to be followed up by a physical audit at the earliest opportunity.

3.5. ISM External Audits
3.5.1. For interim ISM DOC audits where it is not physically possible  to attend  and remote audit is not practicable, BMSR may permit the issue of interim DOC upon receipt by the RO of a statement from the Company confirming that the safety management system is in place and meets the objectives of paragraph 1.2.3 of the ISM Code. This is to be followed up by a physical audit at the earliest opportunity.
3.5.2. For interim ISM SMC audits where it is not physically possible  to attend  and remote audit is not practicable, BMSR permits the issue of interim SMC, without prior approval of the BMSR, upon receipt by the RO of a statement from the Master confirming that the safety management system is in place and meets the objectives of paragraph 1.2.3 of the ISM Code. This is to be followed up by a physical audit at the earliest opportunity.
3.5.3. For initial ISM DOC and SMC audits where it is not physically possible  to attend  and remote audit is not practicable, BMSR permits the issue of a second  interim DOC/SMC for up to 6 months,  without prior approval of BMSR, upon receipt by the RO of a statement from the Company/Master confirming that the safety management system meets the objectives of paragraph 1.2.3 of the ISM Code. This is to be followed up by a physical audit at the earliest opportunity.
3.5.4. For SMC and DOC periodical audits, if these are not completed within the range date the certificate ceases to be valid as per ISM Code. In such circumstances, the RO may issue a new SMC or DOC valid for 3 months or until the audit can take place, whichever comes first, without prior approval of BMSR.
3.5.5. For SMC and DOC renewal audits, and noting the provisions of ISM Code 13.14, BMSR authorises its ROs to issue 3-month extensions, where requested by the Company, to existing SMC and DOC Certificates, without prior approval of BMSR.

3.6. ISPS External Audits
3.6.1. For interim ISSC audits where it is not physically possible to attend and remote audit is not practicable, BMSR permits the issue of an interim ISSC, without prior approval of BMSR, upon receipt by the RO of a statement from the Company Security Officer and Ship Security Officer confirming that:

1. A Ship Security Assessment has been completed.
2. A copy of the Ship Security Plan (SSP) is on board and there is evidence that the SSP has been submitted to the RO for approval.
3. The security measures identified in the Ship Security Plan are in place and the provisions of paragraph 19.4.2 of the ISPS Code have been met. This is to be followed up by a physical audit at the earliest opportunity.

3.6.2. For initial ISSC audits where it is not physically possible  to attend  and remote audit is not practicable, BMSR permits the issue of a second  interim ISSC for up to 6 months upon receipt by the RO of a statement from the Company Security Officer Ship Security Officer, as per 3.6.1. i to iii, without prior approval of BMSR This is to be followed up by a physical audit at the earliest opportunity.
3.6.3. For ISSC intermediate audits, if these are not completed within the range date the certificate ceases to be valid as per ISPS Code A19.3.8. In such circumstances, the RO may issue a new SMC or ISSC valid for 3 months or until the audit can take place, whichever comes first, without prior approval of BMSR.
3.6.4. For ISSC renewal audits, noting the provisions of ISPS Code A-19.3.5, BMSR authorises its ROs to issue 3-month extensions, where requested by the Company, to existing ISSC Certificates, without prior approval of BMSR.

3.7. Maritime Labour Inspections
3.7.1. For interim MLC inspections where it is not physically possible to attend and remote inspection is not practicable, BMSR permits the issue of an interim MLC for up to 6 months, without prior approval of BMSR, upon receipt by the: RO of a statement from the Company/Master confirming that

1. the applicable requirements of MLC 2006 have been met.
2. An approved Declaration of Maritime Labour Compliance Part I is on board or evidence provided that it has been requested from BMSR.
3. DMLC Part II is available in draft or evidence provided that it has been submitted to the RO.

This is to be followed up by a physical audit at the earliest opportunity.

3.7.2. For initial MLC inspections where it is not physically possible to attend and remote audit is not practicable, BMSR permits the issue of a second interim MLC for up to 6 months, without prior approval of BMSR, upon receipt by the RO of a statement from the Company/Master, as per 3.7.1 (i to iii).

This is to be followed up by a physical audit at the earliest opportunity.
3.7.3. MLC 2006 does not provide for the issue of extensions to existing MLC Certificates without inspection.  However, in this exceptional situation, BMSR authorises its ROs to administratively. issue a short-term Maritime Labour Certificate for 3 months, without prior approval of BMSR in cases where the renewal or intermediate inspection cannot be conducted due to COVID-19 restrictions.
3.7.4. The RO shall state that the certificate has been issued to allow the ship to continue on its intended voyage and complete the inspection at the first port where inspectors are available. When the renewal or intermediate inspection has been completed a full-term Maritime Labour Certificate may be issued with its expiry date not later than 5 years from the expiry date of the original full-term Maritime Labour Certificate.

3.8. Remote audits and surveys

3.8.1. BMSR will consider requests for remote audits and surveys where supported by the RO.

4. Seafarers and Manning
4.1. Reference is made to IMO Circular Letter No.4204 and ILO Statement from the “Special Tripartite Committee of the Maritime Labour Convention 2006 as amended”.

4.2. Seafarer Employment
4.2.1. In cases  where crew members may have to continue  their service beyond 12 months- or their contractual period onboard  as stated  in their original Seafarers’ Employment Agreement (SEA) because of travel restrictions imposed due to the outbreak  of the COVID-19 pandemic, BMSR will consider  such extensions to be force majeure and therefore not a breach  of the Maritime Labour Convention, 2006, (MLC) as amended.
4.2.2. A new SEA shall be arranged for the crewmembers in question, and it shall be stated that the seafarers are entitled to repatriation at no cost to the seafarer at one week’s notice.
4.2.3. The following text shall be inserted into the renewed contract:
The seafarer is permitted to terminate the contract giving 7 days’ notice when the force majeure situation caused by the COVID-19 pandemic permits him/her to travel to his/her destination safely and securely.

4.3. Expired Medical Certificates
4.3.1. If any seafarer’s Medical Certificate expires whilst he/she is on board, the seafarer can continue his/her service for up to 3 months or until a new certificate can be issued, whatever comes first.

4.4 Expired STCW Certificates and Certificates of Recognition (Endorsements)
4.4.1. If a Certificate of Competency (CoC) or a Certificate of Proficiency (CoP) that Barbados Maritime has endorsed expires and the issuing State has extended the period for which the certificate is valid, this document/endorsement shall automatically be extended by BMSR for the same period.
4.4.2. All STCW, MLC and Minimum Safe Manning Documents will be issued electronically by e-mail during COVID-19 restrictions and will not be printed. The documents will be printed on their respective templates and couriered to clients as soon as the measures to prevent the spread of coronavirus have been lifted.

4.5. Seaman’s Record Books
4.5.1. BMSR is currently restricted in the use of courier and mail services to send seaman’s record books to clients.
4.5.2. Where seafarers are not in possession of a Seaman’s Record Book, BMSR requests that the Master issues a Record of Service.
4.5.3. Notwithstanding the above, BMSR will still issue Seaman’s Record Books and clients are encouraged to apply for such.
4.5.4. BMSR will send the original Seaman’s Record Books by courier as usual when full access to courier services is available.

20/07/2020