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1.             References

a)              Barbados Merchant Shipping Act, 2024

b)              Maritime Labour Convention, 2006 (MLC 2006)

c)              Bulletin 007 – Maritime Labour Convention 2006

d)              PPO01-F14: Ship Masters Medical Report Form

2.             Purpose

2.1           This Bulletin provides guidance and explanatory notes to assist Recognised Organisations (ROs), shipowners and operators in preparing the Declaration of Maritime Labour Compliance (DMLC) Part II, in accordance with MLC 2006 Standard A5.1.3 paragraph 10(b).

2.2           This Bulletin shall be read in conjunction with Bulletin 007, which details Barbados’ implementation of the MLC 2006, including DMLC Part I obligations and RO procedures.

3.             Application 

3.1           This Bulletin applies to all Barbados-flagged vessels required to carry a Maritime Labour Certificate and Declaration of Maritime Labour Compliance, as prescribed under MLC 2006 Title 5 and as prescribed under Sec. 7 of  Bulletin 007.

4.             DMLC Part II – General Requirements

4.1           The DMLC Part II shall be drawn up by the MLC shipowner and shall identify the measures adopted to ensure ongoing compliance with the national and international requirements between MLC inspections and the measures proposed to ensure continuous improvement.

4.2           The DMLC Part II shall be drafted in clear terms designed to help all persons concerned, such as flag State inspectors, authorised officers in port States and seafarers, to check that the requirements are being properly implemented.

4.3           Shipowners shall ensure that their DMLC Part II is completed in line with this guidance prior to submission to a Barbados RO for review and approval.

4.4           The DMLC Part II is a company-specific declaration outlining measures adopted to ensure compliance with each applicable MLC 2006 Regulations. It shall:

.1                        Address each item listed in DMLC Part I.

.2                        Be signed and stamped by the Company.

.3                        Include clear references to documented procedures, forms, or manuals used on board.

.4                        Be kept on board at all times and available to inspectors (RO approved copy).

4.5           Completed DMLC Part II shall be submitted to a Barbados RO for review. During the MLC initial or intermediate inspection, the RO will verify the measures onboard.

5.             DMLC Part II Records

5.1           Shipowners shall keep a copy of the completed and approved DMLC Part II at their management office and onboard each vessel.

5.2           An electronic copy of the DMLC Part II approved by the RO shall also be forwarded to registry@barbadosmaritime.com for BMSR records.

6.             Explanatory Notes and Recommended Content

6.1           The following guidance corresponds to each section of the Barbados DMLC Part I and addresses both the MLC 2022 amendments and the amendments regarding the need for basic training in the prevention of and response to violence, harassment, bullying, and sexual assault.

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.

1.             References

a)              Barbados Merchant Shipping Act, 2024

b)              ILO Convention C185 – Seafarers’ Identity Documents

2.             Introduction

2.1           Barbados officially deposited its instrument of ratification for ILO Convention C185 —the Seafarers’ Identity Documents Convention (Revised), 2003—on 3 March 2025.

2.2           Under the terms of C185, the convention enters into force for a Member State six months after that state lodges its ratification with the ILO Director‑General.

2.3           So, based on that timeline:

.1                        Ratification lodged: 3 March 2025

.2                        Entry into force for Barbados: 3 September 2025

3.             Purpose

3.1           This Bulletin gives guidance on the application of the ILO Convention C185 for seafarers working on Barbadian vessels.

4.             Application

4.1           In accordance with Article 2 of ILO Convention C185, a Seafarers’ Identity Document (SID) may only be issued by a Member State to its own nationals who are seafarers or, at that State’s discretion, to permanent residents.

4.2           Non-Barbadian nationals serving on Barbados-flagged vessels are not eligible for a Barbados-issued SID and must obtain one from their country of nationality or residence.

4.3           As the Barbados Maritime Ship Registry (BMSR) is not authorised to issue SIDs, after entry into force, Barbadian nationals who are seafarers shall submit all SID applications to the Barbados Maritime Administration (Government of Barbados), which is the designated competent authority for Visa and Immigration Considerations.

4.4           The SID, when issued by the competent authority, will be recognised under ILO Convention C185. However, it does not replace a passport and does not override national visa requirements of Port States.

4.5           Therefore, seafarers of any nationality serving on Barbados-flagged vessels may still require visas when calling at foreign ports, unless explicitly exempted by the immigration authorities of the State concerned.

4.6           Shipowners and operators must continue to ensure that all crew carry the appropriate passports, visas, and travel documentation in addition to discharge books or other records of service.

5.             Obligations of Shipowners and Operators

5.1           Verify immigration requirements for each crew member’s nationality well in advance of arrival and based on the country of arrival.

5.2           Do not assume that the Barbados or the seafarer country’s accession to C185 or the issuance of SIDs to their nationals removes the visa obligations of the other crew members.

5.3           Report any issues of SID recognition or immigration difficulties encountered at ports to the country that issued the SID and to the BMSR for awareness and record.

1. References

a) International Telecommunication Union Convention (ITU Convention);
b) ITU-T Recommendation D.90 (ITU D.90);
c) Form 144 – Application for Radio Accounting Authority Acting on Behalf of Barbados;
d) Maritime Service Activation Registration Form (SARF);
e) Maritime mobile Access and Retrieval System (MARS).

2. Purpose

2.1 This Bulletin explains:

.1 the radio message accounting procedures required by Barbados Maritime Ship Registry (BMSR) and the lists of the Radio Accounting Authorities (RAAs) approved by the BMSR.

.2 the procedures required by the Point of Service Activation (PSA) to activate, deactivate, and update information regarding Inmarsat Mobile Earth Stations (MESs) on Barbadian vessels;

.3 the procedures to obtain Maritime Mobile Service Identity (MMSI) numbers and Call Signs for Barbadian vessels.

3. Application

3.1 This Bulletin applies to all Barbadian vessels:

.1 Equipped with a Radio Ship Station;

.2 Installed, or will be, with an Inmarsat MESs.

4. RAA Requirements

4.1 The ITU Convention currently in force provides for RAAs to settle maritime radiocommunication accounts for ships licensed by the BMSR.

4.2 Due to the many problems occurring in international radio maritime accounting, no ship is entitled to be registered or to maintain registration under the Barbados flag unless the owner shall have entered into a valid contract with an authorized radio service company pursuant to the terms of which the latter assumes the accounting obligation and may assume responsibility for obtaining the vessel’s Radio Ship Station License (SSL).

4.3 It is mandatory that all international maritime radio traffic charges for radiocommunications from ship to shore, both terrestrial and satellite, shall be settled by the approved RAA pursuant to the contract with the owner of the vessel.

4.4 Application for RAA on behalf of the BMSR shall be submitted with Form 144, which is to be sent to registry@barbadosmaritime.com.

4.5 The ITU D.90 limits the number of RAAs based in other countries that the BMSR may recognize to 25. The RAAs approved by the BMSR are listed in section 4 below.

4.6 The RAA shall notify the BMSR of the vessels for which it has assumed full responsibility for the payment of the radiocommunication incurred through its maritime mobile station, ensuring, as required by the ITU Convention, that these payments are made in accordance with the ITU D.90 and will not accrue to the account of the Barbados Government. It is imperative that all radio traffic charges be sent to the RAA only and not to any third party.

5. List of RAAs

5.1 AAIC, means Accounting Authority Identification Code.

5.2 The Barbados RAAs Particulars can be retrieved on MARS by selecting Administration “BRB – Barbados” and pressing “submit query”.

5.3 Barbados does not approve any more RRAs.

6. PSA Requirements

6.1 Inmarsat is the internationally recognized body that sets the rules and oversees “service activation” or formal registration/re-registration of MES for all vessels. Deactivation and re-registration/activation of equipment must take place when a vessel changes Flag, changes owner or when changes occur with the equipment. In order to effect the change, the terminals must first be deactivated by the former PSA that activated the equipment.

6.2 A PSA is an entity authorized by Inmarsat to accept and process for Barbadian vessels applications for MES service activation, assign Inmarsat Mobile Numbers and transmit customer service activation information to the Inmarsat Customer Activation group.

6.3 In many cases, the PSA will also be the RAA or Inmarsat Service Provider (ISP) for the terminal, and works directly with the customer on service activation, in particular, and Inmarsat systems and services in general.

6.4 Any enquiries related to commissioning or decommissioning of Inmarsat terminals should be addressed to the PSA or Inmarsat.

6.5 To obtain the authorisation to activate the MES, the SARF, which is to be completed and signed by the owner of the MES who will ultimately be responsible for the payment of traffic charges incurred by the MES, is to be submitted either directly to the PSA or to the ISP. If applying for more than one MES, the customer must prepare separate SARFs for each MES to be activated. For further information on PSAs and ISPs please contact the Inmarsat Global Customer Support at the following address:

Inmarsat Global Customer Support
Inmarsat Global Limited
99 City Road
London EC1Y 1AX,
United Kingdom

Telephone +44 207 728 1020/1777
Email address: globalcustomersupport@inmarsat.com

6.6 It is imperative that this procedure be understood and followed by the PSA, shipowner, and ship operator so that registration/deregistration of systems may be quickly accomplished for Long Range Identification and Tracking (LRIT) compliance.

6.7 PSA shall inform the BMSR of all additions, deletions, and modifications to BMSR MESs as quickly as possible with a change of flag by email to registry@barbadosmaritime.com.

6.8 The PSAs authorised by Inmarsat can be obtained by contacting Inmarsat Global Customer Support above.

7. MMSI numbers and Call Signs

7.1 A MMSI is effectively an international maritime telephone number issued by the BMSR.

7.2 The BMSR continues to allocate MMSI numbers and Call Signs to Barbados vessels on behalf of the Barbados Ministry of Industry, Innovation, Science and Technology (MIST).

7.3 The Call Signs are allocated based on the guidelines of the ITU Convention – Radio Regulations Article 19.54 -19.56. The BMSR assigns Call Signs with two digits and 3 letters in the order: digit – letter- letter – letter – digit

7.4 Any enquiries related to MMSI numbers should be addressed to the BMSR registration department at registry@barbadosmaritime.com.

1.             References

a)              International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS)

b)              Fire Safety Systems (FSS) Code

c)              IMO Circular MSC.1/Circ.1432 Revised Guidelines on maintenance and inspection of fire protection systems and appliances

d)              IMO Circular MSC.1/Circ.1318/Rev.1 Revised Guidelines for the maintenance and inspections of fixed carbon dioxide fire-extinguishing systems

e)              IMO Assembly Resolution A.951(23) Improved Guidelines for Maintenance for Marine Portable Fire Extinguishers

f)               IMO Assembly Resolution A.1156(32) Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2021

g)              IMO Circular MSC/Circ.775 – Ships with Reduced Halon Quantities

h)              The International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code)

i)                IMO Circular MSC.1/Circ.1275 Unified interpretation of SOLAS chapter II-2 on the number and arrangement of portable fire extinguishers on board ships, as corrected by MSC.1/Circ.1275/Corr.1

j)                IMO Circular MSC/Circ.1002 Guidelines on alternative design and arrangements for fire safety, as corrected

k)              IMO Circular MSC.1/Circ.1395/Rev.4 Lists of solid bulk cargoes for which a fixed gas fire-extinguishing system may be exempted or for which a fixed gas fire-extinguishing system is ineffective

l)                IMO Circular MSC/Circ.670 Guidelines for the performance and testing criteria and surveys of high-expansion foam concentrates for fixed fire-extinguishing systems

m)            IMO Circular MSC/Circ.798 Guidelines for the performance and testing criteria and surveys of medium-expansion foam concentrates for fire-extinguishing systems

n)              IMO Circular MSC.1/Circ.1312 Revised guidelines for the performance and testing criteria, and surveys of foam concentrates for fixed fire-extinguishing systems, as corrected by MSC.1/Circ.1312/Corr.1

o)              IMO Circular MSC.1/Circ.1555 Unified interpretation of SOLAS chapter II-2

p)              IMO Circular MSC/Circ.1081 Unified interpretation of the Revised SOLAS chapter II-2

q)              IMO Circular MSC/Circ.849 Guidelines for the performance, location, use and care of emergency escape breathing devices (EEBDs)

r)               IMO Resolution MEPC.269(68) 2015 Guidelines for the Development of the Inventory of Hazardous Materials.

s)               International Code of Safety for High-Speed Craft (HSC Code)

2.             Purpose

2.1           This Bulletin provides instructions for inspection, maintenance, testing and survey requirements of fire protection systems, appliances, and equipment.

2.2           The maintenance and inspection provisions for fixed carbon dioxide (CO2) fire-extinguishing systems reflect the latest requirements of MSC.1/Circ.1318/Rev.1.

3.             Application

3.1           This Bulletin applies to all Barbadian vessels, except pleasure yachts.

 4.             Operational Readiness and Temporary Permits

4.1           All fire protection systems and appliances shall be in good order and available for immediate use while the vessel is in service.

4.2           If a fire protection system is under maintenance, testing, repair, or not working, then the ISM Mangers have to provide suitable arrangements to ensure fire protection capability is not diminished by providing alternative fixed or portable fire protection equipment or other measures. The ISM Managers shall request a Temporary Permit at ops@barbadosmaritime.com while the vessel is underway, or before it sails.

5.             Onboard Maintenance and Competent Persons

5.1           As per MSC.1/Circ.1432 and MSC.1/Circ.1318/Rev.1, certain maintenance procedures and inspections may be performed by competent crew members who have completed an advanced fire-fighting training course meeting the requirements of Section A-VI/3 of the STCW code, while others should be performed by persons specially trained in the maintenance of such systems. The onboard maintenance plan should indicate which parts of the recommended inspections and maintenance are to be completed by trained personnel.

5.2           For the purpose of section 5.1, a “competent person” is defined as someone who has achieved a level of technical skill (incorporating theoretical knowledge and practical experience) to be able to complete a task or activity safely and to the specified standard. The ISM Managers are responsible for assessing and selecting a suitable “competent person”. Appropriate procedures relating to this activity shall be established within the Company’s Safety Management System.

5.3           Onboard maintenance and inspections are to be carried out in accordance with the vessel’s maintenance plan, which should include the minimum elements listed in sections 4 to 10 of MSC.1/Circ.1432.

6.             Specific Requirements for Fire Detection Systems

6.1           As per MSC.1/Circ.1432 sample of fire detectors and manual call points should be tested monthly, so that all devices have been tested at least once every 5 years.

6.2           Testing of manual call-points should be conducted at the same time as the detector tests.

6.3           The monthly testing schedule is be prepared such that alternative detectors are physically tested at every monthly test. Remaining detectors shall still to be visually inspected and/or tested with internal electronic self-test function, where provided.

6.4           For very large systems (1,000+ detectors), at least one detector should be physically tested in each large compartment, or one detector tested within several smaller compartments in the same locality within the same fire zone (e.g., multiple sleeping rooms on the same side of the vessel located on the same deck and within the same fire zone). Whilst undertaking testing, all accessible detectors should be visually inspected for evidence of tampering, obstruction, etc.

6.5           At least one detector located along each cable line of the fire detection system and within each fire zone should be tested.

6.6           Where a fire detection system operating on an atmosphere sample extraction principal is installed the entire system should be physically tested every month. Where a vessel fitted with such fire detection system undertakes laden voyages of longer than 1 month, the sample extraction fire detection system covering cargo compartments should be tested before loading cargo.

7.             Specific Requirements for Fixed Gas Fire-Extinguishing Systems

7.1           Fixed gas fire-extinguishing systems have to be carefully and critically reviewed, routinely inspected, and maintained, verified, and tested to ensure that they will correctly operate during an emergency.

7.2           Monthly and annual inspections are to be carried out as per MSC.1/Circ.1432.

7.3           Flexible hoses have to be replaced at the intervals recommended by the manufacturer and in any case at intervals not exceeding 10 years.

7.4           Every two years (during the second or third periodical survey), fixed gas fire-extinguishing systems, except fixed carbon dioxide (CO2) extinguishing systems (see section 8 below), have to be checked by an authorised service facility acceptable to the vessel’s RO.

7.5           Every two years all high-pressure extinguishing agents, cylinders, and pilot cylinders have to be weighed or have their contents verified by other reliable means to confirm that the available charge in each is above 95% of the nominal charge. Cylinders containing less than 95% of the nominal charge have to be refilled.

7.6           Every year, blow dry compressed air or nitrogen through the discharge piping or otherwise confirm the pipe work and nozzles are clear of any obstructions. This may require the removal of nozzles, if applicable.

7.7           At least once every 10 years, a hydrostatic test and internal examination of 10% of the system’s extinguishing agent and pilot cylinders has to be conducted. If one or more cylinders fail, a total of 50% of the onboard cylinders have to be tested. If further cylinders fail, all cylinders have to be tested.

7.8           With cylinders for fixed-gas fire-fighting systems (except Halon) that have been date stamped before vessel delivery, the first 10-year hydrostatic test may be harmonized with drydocking at the second renewal survey under the HSSC. This is contingent on the initial date stamp (month/year) on the cylinder not exceeding 12 months before the vessel delivery date.

8.             Specific Requirements for Fixed CO2 Systems

8.1           Monthly and annual inspections are to be carried out as per MSC.1/Circ.1318/Rev.1.

8.2           At least once in every 5-year period, control valves of fixed CO2 systems are to be internally examined to ensure they can operate freely.

8.3           At least biennially (at intervals of 2 years ± 3 months) in passenger ships, or at each intermediate, periodical or renewal survey (as per HSSC) in cargo ships, the following maintenance is  be carried out (to assist in carrying out the recommended maintenance, examples of service charts are set out in the appendix of MSC.1/Circ.1318/Rev.1):

.1                        All high-pressure cylinders and pilot cylinders shall be weighed or have their contents verified by other reliable means to confirm that the available charge in each is above 90% of the nominal charge. Cylinders containing less than 90% of the nominal charge should be refilled. The liquid level of low-pressure storage tanks shall be checked to verify that the required amount of carbon dioxide to protect the largest hazard is available;

.2                        The hydrostatic test date of all storage containers shall be checked. High-pressure cylinders and pilot cylinders should be subjected to periodical tests at intervals not exceeding 10 years. At the 10-year inspection, at least 10% of the total number provided shall be subjected to an internal inspection and hydrostatic test. If one or more cylinders fail, a total of 50% of the onboard cylinders shall be tested. If further cylinders fail, all cylinders shall be tested. Before the 20-year anniversary and every 10-year anniversary thereafter, all cylinders shall be subjected to a hydrostatic test. Flexible hoses shall be replaced at the intervals recommended by the manufacturer and not exceeding every 10 years. When cylinders are removed for testing, the cylinders shall be replaced such that the quantity of fire-extinguishing medium continues to satisfy the requirements of 2.2.1 of chapter 5 of the (FSS) Code, subject to SOLAS regulation II-2/14.2; and

.3                        The discharge piping and nozzles shall be tested to verify that they are not blocked. The test should be performed by isolating the discharge piping from the system and blowing dry air or nitrogen from test cylinders or suitable means through the piping.

8.4           For the purpose of section 8.3.2 above, the BMSR interprets MSC.1/Circ.1318/Rev.1 as follows:

.1                        At the 10-year anniversary of the initial hydrotest, 10% of all CO2 cylinders are to be hydrotested. If one or more cylinders fail, a total of 50% of the onboard cylinders shall be tested. If further cylinders fail, all cylinders shall be tested;

.2                        Prior to the 20-year anniversary of the initial hydrotest, all CO2 cylinders are to be hydrotested, however cylinders tested satisfactorily at the 10-year anniversary need not be tested;

.3                        At every 10-year anniversary thereafter, all CO2 cylinders are to be hydrotested.

8.5           For vessels aged between 20 and 30 years as of May 2021, all CO2 cylinders have to be hydrotested at the first drydock.

8.6           The ISM Managers can request a Temporary Permit from the BMSR to allow all hydrotests to be completed at the same time. Applications for the permit is to be submitted to BMSR at ops@barbadosmaritime.com by the ISM Managers and include:

.1                        The reason for not completing the hydrotest at 20 years;

.2                        The proposed testing schedule, which should ensure that all cylinders are hydrotested at the earliest opportunity, taking into account the vessel’s operations;

.3                        Most recent service reports for the untested cylinders, including content check (by weighing or ultrasonic level detection);

.4                        A statement from the Master attesting to the condition of the untested CO2 cylinders.

8.7           The above provisions apply equally to vessels using a low-pressure high volume refrigerated vessel for liquified CO2 storage.

8.8           At least biennially (intervals of 2 years ± 3 months) in passenger ships or at each renewal survey in cargo ships, the following maintenance should be carried out by service technicians/ specialists:

.1                        Where possible, all activating heads should be removed from the cylinder valves and tested for correct functioning by applying full working pressure through the pilot lines. In cases where this is not possible, pilot lines should be disconnected from the cylinder valves and blanked off or connected together and tested with full working pressure from the release station and checked for leakage. In both cases this should be carried out from one or more release stations when installed. If manual pull cables operate the remote release controls, they should be checked to verify the cables and corner pulleys are in good condition and freely move and do not require an excessive amount of travel to activate the system;

.2                        All cable components should be cleaned and adjusted as necessary, and the cable connectors should be properly tightened. If the remote release controls are operated by pneumatic pressure, the tubing should be checked for leakage, and the proper charge of the remote releasing station pilot gas cylinders should be verified. All controls and warning devices should function normally, and the time delay, if fitted should prevent the discharge of gas for the required time period; and

.3                        After completion of the work, the system should be returned to service. All releasing controls should be verified in the proper position and connected to the correct control valves. All pressure switch interlocks should be reset and returned to service. All stop valves should be in the closed position.

9.             Specific Requirements for Halon Gas Systems

9.1           In accordance with Regulation of SOLAS II-2/10.4.1.3, fire extinguishing systems using Halon 1211, Halon 1301, Halon 2402, and perfluorocarbons are prohibited on all new buildings and on new installations on existing vessels.

9.2           In an existing installation and in the event of the discharge or loss of pressure of Halon gas cylinder(s), the BMSR might accept the replenishment of the discharged cylinder(s), if they remain in satisfactory condition.

9.3           The contents of the Halon cylinders should be weighed or have their contents verified by other reliable means at least every two years, plus or minus three months, as part of the survey for issuing the SOLAS Safety Equipment Certificate (SEC). This is to confirm that the available charge in each is above 95% of the nominal charge as far as reasonably practicable, as determined by the BMSR. Cylinders with less than 95% of the nominal charge should be refilled.

9.4           All Halon cylinders have to be hydrostatically tested:

.1                        After each 20 years of service;

.2                        Before recharging a discharged cylinder; or

.3                        When visual inspection reveals a potential defect.

9.5           Hydrostatic test dates have to be stamped on the cylinders. Hydrostatic testing have to be performed by an authorised servicing facility certified by a government agency or RO. The facility shall be acceptable to the attending RO surveyor. The same facility should recharge the cylinders after testing to demonstrate their serviceability.

9.6           Visual inspection and non-destructive testing (NDT) of Halon cylinders may be performed instead of hydrostatic testing by an authorised servicing facility which has been certified by a government agency or RO.

9.7           The safety of the vessel and its crew remains paramount and if Halon gas is not readily available, the ISM Managers have to ensure that the affected space has adequate temporary firefighting capability prior to departure from port.

9.8           The adequacy of any temporary arrangements and procedures is to be assessed by the RO prior to application for acceptance by the BMSR.

9.9           Application for acceptance of any temporary arrangements is to be made to the BMSR by the RO and, as per MSC/Circ.775, shall establish procedure to enable the vessel to safely depart the port, call at specified ports for discharge or loading of cargo, and arrive at the port for rectification of the deficiency. Where, such a procedure should specify the “port and date of departure”, the “port of rectification of the deficiency”, the “maximum duration of the voyage” and the “ports of call and operations approved en route”.

9.10       There is currently no internationally agreed date for the phasing out of Halon gas in existing installations, however there may be local or regional regulations that impose restrictions on the use and/or phase out of Halon. The BMSR recommends that ISM Managers of affected Barbadian vessels make themselves aware of any restrictions that may be applied by the country or region in which the vessel is trading.

9.11       ISM Managers operating vessels with existing Halon systems should note that the worldwide stock of Halon is diminishing, and it is strongly recommended that a plan is implemented for the replacement the Halon system on board.

9.12       It should be further noted that where Halon replenishment is not permitted by the country or region in which the vessel is operating, the vessel may be detained and/or prohibited from leaving port until a new fixed firefighting system is installed.

9.13       Details of any proposed replacement of a system containing Halon shall be forwarded to the BMSR for review by the RO.

9.14       As per MEPC.269(68), the Halons are Ozone Depleting Substances (ODS) and the Supplement to the International Air Pollution Prevention Certificate may identify the presence of onboard. The ODS Record Book shall be kept up to date and may form part of an existing logbook or electronic record book.

10.         Specific Requirements for Fixed Dry Chemical Powder Fire-Extinguishing Systems

10.1       Monthly and annual inspections are to be carried out as per MSC.1/Circ.1432.

10.2       Every 10 years fixed dry chemical powder fire-extinguishing systems have to be serviced and tested in accordance with the manufacturer’s and the RO’s requirements. Particular attention shall be paid to the powder condition for any signs of moisture ingress and that its properties remain as per the type approval.

10.3       In accordance with MSC.1/Circ.1432, two-yearly inspections have to be carried out on fixed, dry chemical powder systems by an authorised service facility acceptable to the vessel’s RO or the attending RO surveyor(s), who have to perform a general distribution piping and installation examination of the dry chemical powder fire-extinguishing system to confirm, to the extent possible, that the system has not been modified from its original installation.

10.4       This verification should also include the following minimum requirements:

.1                        The piping distribution system has to be blown through with nitrogen (N2) or dry air to ensure it is free of any obstruction. The nozzles, if any, have to be removed to ensure that they are free and not blocked during the blow-through operation;

.2                        Operational testing of local and remote controls and section valves;

.3                        The contents verification of propellant gas cylinders containing N2, including remote operating stations, shall be confirmed;

.4                        Flexible discharge hoses have to be inspected to confirm that they are maintained in good condition and have not perished, especially when located on open decks. In case of any doubt, the hoses have to be subjected to a full working pressure test;

.5                        The dry chemical powder containment tank and its associated safety valves have to be inspected for signs of corrosion or deterioration, which may affect the safety of the system. In case of any doubt, the tank has to be tested, and safety valve set points adjusted and confirmed by the authorised service facility.

11.         Specific Requirements for Alternative Fixed Gas Firefighting Media

11.1       Alternative firefighting systems referred in Chapter II-2 of SOLAS and the IGC Code for protection of machinery and accommodation spaces, pump rooms and cargo spaces may be fitted on board, subject to the approval, including any attached conditions, of a Barbados RO or a SOLAS contracting Government in accordance with the requirements for alternative fire-fighting systems and relevant guidance stated in IMO Circular MSC/Circ.1002. The BMSR shall receive prior notification of intention to fit an alternative system which has not been previously accepted by the BMSR.

11.2       The BMSR accepts the use of (non-asphyxiating) fire extinguishing agents in machinery spaces for which no specific provisions for fire-extinguishing appliances are prescribed under the provisions of Chapter II-2 of SOLAS, (such as “Novec^TM 1230” fluid, INERGEN, FM 200, etc.). Acceptance of such agents is subject to conditions, agreed on a case-by-case basis, appropriate to the space in question and provided that the space is not connected to an accommodation space.

12.         Specific Requirements for Alternatives to Ineffective Fixed Gas Firefighting Systems

12.1       Water supplies as defined in SOLAS Regulation II-2/19.3.1.2 are considered an alternative for the ineffective fixed gas fire-extinguishing system, when vessels are allowed to carry cargoes contained in MSC.1/Circ.1395/Rev.4, Table 2. Such an arrangement has to be verified for compliance by the vessel’s RO.

13.         Specific Requirements for Foam Concentrates: Fixed Fire-Extinguishing Systems and Portable Applications

13.1       The first periodical control for foam concentrates (except protein-based, alcohol-resistant ones) should be performed not more than three years after being supplied to the vessel, and after that, every year. These tests should be conducted by laboratories or authorised service suppliers acceptable to the RO.

13.2       Protein-based, alcohol-resistant foam concentrates should be subjected to a chemical stability test before delivery to the vessel and annually thereafter.

13.3       Guidance on performance and testing criteria and surveys of low, medium, and high-expansion concentrates for fixed fire-extinguishing systems are found in IMO Circulars MSC/Circ.670, MSC/Circ.798, and MSC.1/Circ.1312.

13.4       In accordance with MSC.1/Circ.1432 portable containers or portable tanks containing foam concentrate (excluding protein-based ones), less than 10 years old, that remain factory sealed, may normally be accepted without carrying out the periodical foam control tests referred to in MSC.1/Circ.1312.

13.5       Protein-based foam concentrate portable containers and portable tanks have to be thoroughly checked. If more than five years old, the foam concentrate has to be given the periodical foam control tests required or renewed, as referred to in MSC.1/Circ.1312.

14.         Specific Requirements for Portable Fire Extinguishers and Spare Charges

14.1       All portable fire extinguishers have to be periodically inspected in accordance with the manufacturer’s instructions.

14.2       Where recharged on board, all portable fire extinguishers should be provided with a visual discharge indicator. The manufacturer’s instructions for recharging should be available onboard.

14.3       All portable fire extinguishers shall be serviced at intervals not exceeding one year.

14.4       At least one extinguisher of each type, manufactured in the same year and kept on board a vessel, should be test discharged at five-year intervals as part of a fire drill.

14.5       All fire extinguishers, together with propellant cartridges, shall be hydrostatically tested in accordance with the recognized standard or the manufacturer’s instructions at intervals not exceeding 10 years.

14.6       A hydrostatic test may be also required by the RO Surveyor or BMSR Appointed Nautical Inspector (ANI) if visual examination indicates a potential defect in the cylinder.

14.7       Service and inspection should only be undertaken by, or under the supervision of, a person with demonstrable competence, based upon the inspection guide in A.951(23) (Table 9.1.3).

14.8       The hydrostatic test date shall be permanently and clearly marked on the bottles.

14.9       The servicing facility performing the hydrostatic tests has to be:

.1                        Certified by a government agency or an RO; and

.2                        Accepted by the vessel’s RO or the extinguisher manufacturer.

14.10    The same facility should recharge the cylinder after testing to demonstrate serviceability.

14.11    The number of portable fire extinguishers on board should be determined as follows:

.1                        Vessels built prior to 01 January 2009 – the number of portable fire extinguishers provided is to satisfy the requirements of the relevant Classification Society. In accommodation spaces, service spaces and control stations on vessels of 1,000 gross tonnage and upwards, no less than five (5) portable fire extinguishers are to be provided. ISM Managers are encouraged to apply the provisions of MSC.1/Circ.1275 where practicable.

.2                        Vessels built on or after 01 January 2009 – the number of portable fire extinguishers to be provided should be determined in accordance with MSC.1/Circ.1275. In accommodation spaces, service spaces and control stations on vessels of 1,000 gross tonnage and upwards, no less than five (5) portable fire extinguishers are to be provided.

14.12    The minimum number of spare charges carried on board for portable & semi-portable extinguishers shall be in accordance with SOLAS Chapter II-2, namely:

.1                        100% for the first ten (10) extinguishers; and

.2                        50% for the remaining extinguishers up to a maximum of sixty (60).

14.13    Additional extinguishers of the same type and capacity shall be carried in lieu of spare charges for any extinguishers which cannot be charged on board.

15.         Specific Requirements for Ten-Year Servicing: Water Mist, Water Spray, and Sprinkler Systems

15.1       The hydrostatic test and internal examination for gas and water pressure cylinders has to be conducted in accordance with EN 1968:2002+A1, Transportable Gas Cylinders – Periodic Inspection and Testing of Seamless Steel Gas Cylinders, or equivalent RO requirements. See also section 7.8 above of this Bulletin about harmonization with drydocking.

16.         Specific Requirements for Self-Contained Breathing Apparatus

16.1       Self-Contained Breathing Apparatus (SCBA) Cylinders should be inspected weekly to ensure that they are in the correct pressure range.

16.2       A responsible vessel’s officer shall inspect SCBAs at least once a month.

16.3       All SCBAs and their onboard means of recharging (if fitted) have to be inspected and tested at least annually by competent crew members unless manufacturers require annual servicing by an authorised agent.

16.4       The tests and examinations required by the HSSC shall be carried out in the presence of an RO surveyor.

16.5       Hydrostatic testing of SCBA cylinders has to be carried out once every five years. Where:

.1                        The hydrostatic test date shall be permanently marked on the bottles;

.2                        Intervals for hydrostatically testing cylinders of the ultra-lightweight type may vary and will depend upon the requirements of the cylinder manufacturer and the vessel’s RO.

.3                        Cylinder servicing has to be performed to the satisfaction of the RO surveyor.

16.6       In cases where SCBA cylinders have been date stamped before a vessel’s delivery, the first five-year hydrostatic test may be harmonised with drydocking at the First Special Survey under the HSSC. This is possible provided that the initial date stamp (month/year) on the cylinder is not more than six months before the vessel delivery date.

16.7       Two interchangeable spare charges suitable for SCBA use have to be provided for each required apparatus.

16.8       In accordance with SOLAS II-2/10, only one interchangeable spare charge is needed for each required apparatus on passenger ships carrying not more than 36 passengers and cargo ships. A suitably located means for fully recharging breathing air cylinders, free from contamination, is required for passenger ships constructed on or after 01 July 2010 carrying more than 36 passengers.

16.9       All vessels, unless provided with an onboard means of recharging breathing apparatus cylinders, are required to have a suitable number of spare cylinders to replace those used during training or drills. The BMSR does not prescribe any minimum number. The shipboard SMS should include provisions to ensure that sufficient spares are available onboard (see also  IMO Circular MSC.1/Circ.1555) corresponding to the number of breathing apparatuses being used during drills.

17.         Specific Requirements for Emergency Escape Breathing Devices

17.1       The BMSR considers the Guidelines contained in MSC/Circ.849 to be mandatory.

17.2       Only control spaces and workshops that are remotely located from the machinery space escape routes should be considered to comply with MSC/Circ.849, paragraph 4.6.

17.3       To comply with MSC/Circ.849, paragraph 4.6, a minimum of two EEBDs should be located on each level of the machinery space. If a machinery space contains an enclosed primary escape trunk with a door at each level, only one EEBD need be located on each level.

17.4       With reference to section 17.3 above, the term level should be interpreted as meaning a deck where watchstanding personnel reside, workshops and control stations are located, or the crew may be employed during routine maintenance. In essence, two EEBDs are required only on those deck “levels” where people are likely to be employed. Platform decks that serve to divide long ladders into segments and partial decks where personnel are not likely to be employed for any significant period of time are not considered as “levels” and do not require EEBDs. 

17.5       An EEBD shall not be used under any circumstances to enter an enclosed shipboard space in which the atmosphere is known or suspected to be oxygen-depleted or enriched, toxic, or flammable.

17.6       EEBDs have to be examined and maintained in accordance with the manufacturer’s instructions, including those for hydrostatic testing.

17.7       It should be noted that when an EEBD is fitted with a small capacity oxygen cartridge (two inches (50.8mm) or less in diameter), some manufacturers specify a fixed service life without scheduled hydrostatic pressure testing. In the absence of manufacturer’s instructions, hydrostatic testing has to be carried out at intervals not exceeding five years, unless specifically prohibited by the manufacturers.

17.8       In cases where EEBD cylinders have been date stamped before delivery of a vessel, the first hydrostatic test may be harmonized with drydocking at the First Special survey under the HSSC. This is provided that the initial date stamp (month/year) on the cylinder is not more than six months before the vessel delivery date.

17.9       Maintenance requirements, manufacturer’s trademark and serial number, shelf life with accompanying manufacture date, and name of the approving authority have to be printed on each EEBD as per MSC/Circ.849, paragraph 5.3.

17.10    Sufficient spare EEBDs should be on board to replace units that are used, reach their expiry date, or otherwise become unserviceable. MSC/Circ.1081 addresses the number of EEBDs, including spares, required under SOLAS II-2.

18.         Additional Survey Requirements

18.1       In surveying the safety equipment on a vessel, the RO has to verify that:

.1                        All firefighting equipment has been inspected and maintained in accordance with the manufacturer’s instructions and the foregoing requirements; and

.2                        The manufacturer’s maintenance instructions are on board; and

.3                        Records of inspections, maintenance and pressure tests are maintained as per section 18.3 below; and

.4                        Spare charges or extinguishers are provided in accordance with sections paragraphs 14.12 and 14.13 above.

18.2       The RO has to refer to the BMSR, with relevant recommendations, any cases where a Barbados vessel does not satisfy the foregoing requirements, prior to the issue or endorsement of a Cargo Ship Safety Equipment Certificate, Passenger Ship Safety Certificate or any other statutory certificate that relates to safety equipment.

18.3       The following records have to be maintained on board:

.1                        Weekly testing and inspections;

.2                        Monthly testing and inspections;

.3                        Quarterly testing and inspections;

.4                        Annual testing and inspections;

.5                        Two-year testing and inspections;

.6                        Five-year service;

.7                        Ten-year service.

19.         Prohibition of PFOS for fire-extinguishing media

19.1       The IMO has developed amendments to SOLAS II-2 Regulation 10 with the addition of paragraph 11 and the HSC Code(1994 and 2000) to prohibit using or storing fire-extinguishing media (including firefighting foams) containing perfluorooctane sulfonic acid (PFOS). The prohibition applies to fixed and portable systems and equipment and enters into force on 1 January 2026.

19.2       Vessels constructed (keel laid) on or after 1 January 2026 and subject to SOLAS/HSC Codes shall not use or store fire-extinguishing media (including firefighting foams) containing PFOS in concentrations above 10 mg/kg (0.001% by weight) upon the vessel’s delivery.

19.3       Vessels constructed (keel laid) before 1 January 2026 shall comply with the above requirement no later than the first survey date on or after 1 January 2026.

19.4       Disposal of the prohibited substances shall be done using appropriate shore-based reception facilities.

19.5       Any declaration issued by the fire-extinguishing media manufacturer should contain information about the extinguishing media, such as, but not limited to, type, production period, batch number and reference to Type Approval/MED Certificate. It shall also be kept onboard and made available to attending surveyors for review and verification that the fire-extinguishing media does not contain PFOS in concentrations above 10 mg/kg (0.001% by weight).

19.6       For extinguishing media installed before 1 January 2026, where the maker’s declaration or laboratory test reports are not available, sampling and testing of the extinguishing media onboard should be required to be conducted in accordance with a recognised standard to verify that the firefighting media does not contain PFOS in concentrations above 10 mg/kg (0.001% by weight).

19.7       By the first survey on or after 1 January 2026, shipowners, vessel managers and vessel operators shall ensure:

.1                        They have evidence that fire-extinguishing media is PFOS-free or have arranged for the safe disposal of any prohibited fire-extinguishing media;

.2                        Any replacement fire-extinguishing media or equipment has been suitably type-approved;

.3                        They update the vessel’s hazardous materials inventory after removing any PFOS-containing fire-extinguishing media, as applicable. 

19.8       For a Barbadian vessel, the “first survey” referenced in SOLAS regulations, unless indicated otherwise, is the first annual, periodical, renewal survey or any other survey (considering the extent of repairs and alterations being undertaken) due after 1 January 2026.

19.9       For a vessel under construction where the keel is laid before a regulation’s specified date, but the delivery is after that date, the initial survey is considered the “first survey”.

19.10    For the scope of this section, the BMSR considers as a recognised standard any testing methods that are based on internationally recognised or widely accepted analytical standards. Specifically, NPR-CEN/TS 15968, which outlines procedures for the determination of PFOS and related substances in various matrices using liquid chromatography–mass spectrometry (LC-MS), is deemed acceptable for the purpose of compliance verification.

19.11    Additionally, other equivalent standards such as those developed by ISO (e.g., ISO 25101) or EPA methods (e.g., EPA 537 or EPA 8327 for aqueous film-forming foams) may also be considered suitable, provided they ensure reliable detection and quantification of PFOS in accordance with the objectives of the IMO circulars.

1.             References

a)              Barbados Merchant Shipping Act, 2024

b)              The International Ship and Port Facility Security Code (ISPS Code)

c)              International Convention for the Safety of Life at Sea (SOLAS)

d)              Bulletin 035 – Piracy and Armed Robbery

e)              PPR01-F04 Security Communication Statement

f)               The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW)

g)              Bulletin 021 – BMSR Certificates of Endorsements

h)              IMO MSC/Circ.1154 Guide Training & Certification Security Officers

i)                Bulletin 008 – Permits Exemptions and Equivalences

2.             Purpose

2.1           This Bulletin provides consolidated guidance on maritime security in accordance with the ISPS Code. It establishes the standards and procedures set out by the Barbados Maritime Ship Registry (BMSR), covering requirements for vessels under the Barbados flag and encouraging harmonised application for maximum security and regulatory alignment.

2.2           Full compliance with ISPS Code Part A and SOLAS Chapter XI-2 is required.

2.3           ISPS Code Part B, which provides guidance on meeting Part A’s requirement is recommendatory, though it may be mandatory in some coastal states.

3.             Application

3.1           This Bulletin applies to:

.1                        Passenger ships, including high-speed passenger craft;

.2                        Cargo ships, including high-speed craft and commercial yachts of 500 gross tonnage (GT) and above;

.3                        Special Purpose Ships of 500 GT and above;

.4                        Self-propelled Mobile Offshore Drilling Units (MODUs) capable of international voyages.

3.2           The  ISPS Code and this Bulletin does not apply to:

.1                        Cargo ships and commercial yachts under 500 GT;

.2                        Offshore Support Vessels;

.3                        Pleasure/Private yachts;

.4                        Non-self-propelled barges and MODUs or location-bound offshore units (FPSOs/FSUs).

3.3           Vessels not subject to mandatory compliance with the  ISPS Code as per Sec. 3.2 above may do so voluntarily. Evidence of voluntary compliance is to be verified and certified by a Barbados Recognised Security Organisation (RSO).

4.             Communication of General Security Information

4.1           Routine security issues, enquiries, or reports of difficulties encountered during Port State Control inspections, may be directed to the BMSR Ops@barbadosmaritime.com , but not through the emergency telephone number.

4.2           The BMSR Emergency Response telephone number is only to be used in the case of a genuine maritime security emergency requiring intervention from the BMSR such as hijack, terrorist attack, piracy, any incident involving the use of firearms, any bomb threat, any use or threat of use of force.

5.             Company Security Officer (CSO) and Ship Security Officer (SSO)

5.1           The Company shall  appoint a Company Security Officer (CSO) for each of its vessels, who shall be an internal employee of the Company and shall assume all duties and responsibilities required by the ISPS Code, Part A, Sec. 11, for one or more of its vessels.

5.2           The Company shall notify the BMSR of the designated CSO for every Barbados vessel under its control. For all newly registered vessels, the CSO’s full contact details and the list of vessels shall be included on the form PPR01-F04 Security Communication Statement. The same applies if the Company changes or the identity of the vessel changes.

5.3           Changes to the CSO contact details only may be provided to the BMSR as an email notification to registry@barbadosmaritime.com.

5.4           The BMSR will provide acknowledgement letters confirming the appointment of the CSO by email.

5.5           Companies shall ensure that CSOs are trained as required by the ISPS Code, Part A, Sec. 13 and demonstrate the competencies in line with the requirements set in the Annex of MSC/Circ.1154 and IMO Model Course 3.20.

5.6            A Ship Security Officer (SSO) shall be designated on each vessel and shall carry out or perform all duties and responsibilities required by the ISPS Code, Part A, Sec. 12.

5.7           The SSO shall be either the Master or a senior officer, who shall have a certificate of proficiency in compliance with STCW Reg. VI/5, and a BMSR Certificate of Endorsement (COE) issued by the BMSR as per Sec. 4 of Bulletin 021.

6.             Ship Security Plan (SSP)

6.1           Each vessel shall carry on board a specific Ship Security Plan (SSP) approved by a Barbados RSO in compliance with the ISPS Code, Part A, Sec. 9. Subsequent amendments to the SSP that are related to the requirements of  ISPS CodeISPS Code, Part A, from Sec. 9.4.1 to 9.4.18, shall also be reviewed and approved.

6.2           The SSP must remain strictly confidential, and access should only be permitted to the Barbados RSO auditors.

6.3           The SSP shall outline equipment functions, response to equipment failure, and protection measures, and shall address:

.1                        Unlawful acts threatening the safety of the vessel and the security of its passengers and crew, based on a security risk assessment;

.2                        Countermeasures to protect against terrorism, piracy, stowaways, smuggling and armed robbery when operating in high-risk areas. See Bulletin 035 for more information;

.3                        The Master’s overriding authority to make decisions relating to vessel safety and security.

6.4           The implementation of the SSP, including amendments, must be verified by a Barbadian RSO during an onboard attendance.

6.5           There is no need to send a copy of the SSP to the BMSR, but BMSR reserve the right to ask for the SSP at any time if this is deemed necessary.

6.6           SSP are not generally subject to inspection by Port State Control officers. However, if there are clear grounds for believing that the vessel is in violation of the requirements of SOLAS Chapter XI-2 or of the ISPS Code, limited access to the specific sections of the SSP relating to the non-compliance is allowed, but only with the consent of the BMSR or the Master of the vessel.

6.7           The SSP and the records of activities addressed in the SSP shall be in the working language(s) of the vessel. If that working language is not English, then a translation into English shall be provided and maintained.

6.8           Records of activities provided for by the SSP, including Declarations of Security and the record of the vessel security Level, shall be maintained onboard for a period covering at least the previous ten (10) calls at port facilities.

6.9           During and after the period specified in Sec. 6.8 above, records shall be maintained ashore by the Company in accordance with its own procedures for record keeping. The Company shall note that if any activity is referred to in the vessel Official Logbook (OLB), that record shall be retained as an attachment to the OLB and consequentially the record is required to be maintained for a period of seven (7) years.

6.10       The SSP may be kept in electronic format. In such a case, it shall be protected by means to prevent it from being deleted, destroyed, or overwritten and from unauthorised access or disclosure.

6.11       The SSO shall review the SSA and the SSP in conjunction with an on-scene security survey at intervals not exceeding 12 months. The SSP shall be amended if inadequacies are identified during this annual review. Additional vessel security risks may also be identified during trainings, exercises, drills, or following a security incident.

7.             Vessel Security Levels

7.1           A vessel shall operate at the security level established by the BMSR, see Sec. 8 below, or port facility, which is typically based on the level set by the port State.

7.2           If a security level has not been set by the port State, there still may be a need for enhanced security measures due to reported threats in the area.

7.3           Security measures equivalent to a higher security level may be implemented if a vessel deems it necessary to operate at a higher security level than the port.

7.4           The security levels shall be set as per ISPS Code, Part A, Sec. 13.1:

.1                        Level 1 – Normal, which means the level for which minimum appropriate protective security measures shall be maintained at all times.

.2                        Level 2 – Heightened, means the level for which appropriate additional protective security measures shall be maintained for a period of time as a result of heightened risk of a security incident.

.3                        Level 3 – Exceptional, which means the level for which further specific protective security measures shall be maintained for a limited period of time when a security incident is probable or imminent, although it may not be possible to identify the specific target.

7.5           The SSO or CSO shall notify the BMSR on any changes to the onboard security level by sending an email notification to ops@barbadosmaritime.com without delay. The BMSR will acknowledge these communications and advise accordingly.

8.             Barbados Security Level

8.1           The current security level for Barbadian vessel is set to Level 1 – Normal.

8.2           The BMSR shall issue a Marine Circular “Barbados Security Level Update” to inform interested parties of any changes to the above security level.

9.             Communication of Major Security Threat

9.1           The BMSR requires notification of a major security threat or incident without delay. This includes any Ship Security Alert (SSA), once verified as authentic by the CSO.

9.2           The notification is to be made to the BMSR Emergency Response Officer (ERO) on the BMSR emergency ONLY telephone number +44 (0)7494116754 and with a following email to ops@barbadosmaritime.com with at least the information below:

.1                        Vessel Name and IMO number;

.2                        Geographical location of vessel;

.3                        Security threat description;

.4                        Number of people on board;

.5                        Cargo, if any;

.6                        Local authorities informed, if any;

.7                        Actions taken;

10.         Ship Security Alert System (SSAS)

10.1       The BMSR shall not be designated as the receiving authority for SSAS alerts.

10.2       The SSAS must be programmed to ensure that the security alert is sent to the Competent Authority, i.e. the Company or other recipient designated by the Company, and not to any other party, in accordance with SOLAS Chapter XI-2 Reg. 6.

10.3       The CSO shall remain a recipient of all SSAS transmissions along with Company designated Competent Authority.

10.4       Companies are required to designate either an internal appointee (preferably the 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.

10.5        BMSR requires that to be considered qualified, a Competent Authority shall:

.1                        Be available at all times (on a 24/7 basis) to receive and act upon SSAS alerts;

.2                        Be able to accurately identify and react to real, test, or false alerts;

.3                        Understand the SSAS requirements (Part A) and recommendations (Part B) of the ISPS Code and this Bulletin;

.4                        Maintain a current contact list of relevant authorities (BMSR, Maritime Rescue Coordination Centres (MRCCs), Coastal State Authorities, Information Sharing Centres) to be used in the event of an actual alert; and

.5                        Participate in drills or exercises involving tests of the SSAS.

.6                        The Competent Authority is to acknowledge and respond to all test messages directly, ensuring the proper functioning of SSAS equipment and verifying the accuracy of the transmitted data without the need for acknowledgement of receipt by the BMSR.

10.6       Third party Competent Authorities are not to contact the BMSR directly. All direct communication with BMSR must only be from the Company. Where a third party is appointed as Competent Authority, the third party is to inform the company and in turn company is responsible to notify the BMSR immediately for cases of real Major Security Threat as per Sec. 9 above.

10.7        SSAS alert messages shall include at the least the following information:

.1                        Vessel Name;

.2                        IMO Number;

.3                        Call Sign;

.4                        Maritime Mobile Service Identity (MMSI) Number;

.5                        Date and Time (UTC);

.6                        Global Navigation Satellite System (GNSS) position (latitude and longitude);

.7                        Course and Speed;

.8                        CSO 24/7 phone number; and

.9                        Alternate CSO 24/7 phone number.

11.         Procedures for Drills and Exercises

11.1       The BMSR accepts that a vessel safety drill, which has a security component within it, can be credited as a security drill. The interval between vessel security drills shall not exceed three (3) months.

11.2       In addition to the drill as mentioned in Sec. 11.1 above, in cases where more than 25 % of the vessel’s personnel have been changed with personnel that have not previously participated in any security drill on that vessel within the last three (3) months, a vessel security drill shall be conducted within one week of such a change.

11.3       The Company shall conduct an annual company security exercise, with no more than 18 months between the exercises, with one or more vessels within its fleet, which may include participation of the CSO, Port Facility Security Officers (PFSO), relevant authorities of contracting Governments as well as SSOs, if available. These exercises may be full scale or live; table top simulation or seminar or combined with other exercises held, such as search and rescue or emergency response.

12.         Barbados Vessels Entering Ports which are Not Compliant with the ISPS Code

12.1       The SSO or Master shall request that a Declaration of Security be completed by the Port Facility Security Officer (PFSO) or port facility management. If this request is refused then the vessel shall use the Declaration of Security to record the security measures and the Declaration of Security shall be completed and signed by the Master, or the SSO if the vessel has a designated SSO who is not the Master. The completed Declaration of Security shall be retained as per Sec. 6.8 above.

12.2       The vessel shall implement additional security measures to the extent that the CSO and/or SSO and/or Master deem necessary, and at the least:

.1                        Implement measures per the SSP equivalent to security level 2 or higher;

.2                        ensure all access points to the vessel are guarded;

.3                        attempt to execute a Declaration of Security; and

.4                        Log all implemented security measures for potential review by authorities at future port calls.

13.         Verification and Certification

13.1       Interim, initial, intermediate and renewal verifications that shall be conducted as required by the ISPS Code, Part A, Sec. 19.

13.2       The Barbados RSO that issues the International Ship Security Certificate (ISSC), with a validity of five (5) years shall be consulted if changes are made to security systems, equipment, or the approved SSP.

13.3       A vessel detained on maritime security grounds must undergo an additional verification before being allowed to sail.

13.4       An interim ISSC can be issued after an Interim Verification:

.1                        to new vessels on delivery;

.2                        when a Company takes responsibility for the operation of a vessel which is new to the Company; or

.3                       when a vessel changes flag.

13.5       Interim ISSCs are issued for a period not exceeding 6 months. The BMSR may, in special cases, extend the validity of an Interim ISSC for a further period which shall not exceed 6 months from the date of expiry. When an interim ISSC is extended, the full-term ISSC should be dated from the date of completion of the initial verification.

13.6       On satisfactory completion of the initial verification the Barbados RSO can issue a full-term ISSC.

13.7       During the initial verification, if it is found that the vessel does not merit the issuance of a full-term ISSC due to the number of non-conformities, a short term ISSC valid for 3 months is to be issued so that an additional verification can be carried out prior to the issuance of a full-term certificate. This is to be done in consultation with the BMSR.

13.8       The Barbados RSO or company shall send copies of any type of ISSC to the BMSR.

13.9       The intermediate verification shall be taking place between the second and third anniversary date of the issue of the ISSC and if not done within the window, the ISSC becomes invalid as per ISPS Code, Part A, Sec. 19.3.8. In such cases a renewal verification will be required, with the extent of audit at least that of an intermediate verification. A new ISSC may be issued on completion of the renewal survey, which shall have an expiry date not later than the expiry date of the original certificate. This is to be done in consultation with the BMSR as per Sec 13.15 below.

13.10    Renewal verification may be carried out within three months before the date of expiry of the ISSC and shall be completed before the date of expiry.

13.11    When the renewal verification is completed within three months before the expiry date of the existing  ISSC, the new  ISSC will be valid from the date of completion of the renewal verification to a date not exceeding five years from the date of expiry of the existing ISSC.

13.12    When the renewal verification is completed more than three months before the expiry date of the existing ISSC, the new  ISSC will be valid from the date of completion of the renewal verification to a date not exceeding five years from the date of completion of the renewal verification. This is to be done in consultation with the BMSR as per Sec 13.15 below.

13.13    If a renewal verification has been completed and a new ISSC cannot be issued or placed on board the vessel before the expiry date of the existing ISSC, the RSO may endorse the existing ISSC, and such an ISSC will be accepted as valid for a further period which shall not exceed five months from the expiry date. This is to be done in consultation with the BMSR as per Sec 13.15 below.

13.14    If a vessel at the time when an ISSC expires is not in a port in which it is to be verified, the BMSR may extend the period of validity of the ISSC upon receiving an application through RSO, but this extension will be granted only for the purpose of allowing the vessel to complete its voyage to the port in which it is to be verified, and  only in cases where it appears proper and reasonable to do so. No ISSC will be extended for a period longer than three months, and the vessel to which an extension is granted may not, on its arrival in the port in which it is to be verified, be entitled by virtue of such extension to leave that port without having a new ISSC. When the renewal verification is completed, the new certificate will be valid to a date not exceeding five years from the expiry date of the existing ISSC before the extension was granted.

13.15    When the intermediate or renewal verifications cannot be done within the due time frame and in the cases of the Sec. 13.9, 13.12 and 13.13 above the RSO shall contact the BMSR for issuance of a permit as per Sec. 5 of Bulletin 008.