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

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

1.             Purpose

1.1           This Circular serves to inform all Recognised Organisations (ROs), shipowners, managers, and other maritime stakeholders that Barbados has been a member of the Marine Accident Investigators’ International Forum (MAIIF) since 2022 and that the BMSR represents Barbados at MAIIF meetings and technical sessions.

2.             Background

2.1            The Marine Accident Investigators’ International Forum (MAIIF) was established in 1992 as a non-profit body of national marine safety investigation authorities. MAIIF’s purpose is to enhance maritime safety through cooperation, the exchange of investigative expertise, and the dissemination of lessons learned from marine casualties and incidents.

2.2           MAIIF is recognised internationally as a professional forum for marine casualty investigators and operates in support of the International Maritime Organisation (IMO) framework for the investigation of marine casualties and incidents. It promotes implementation of the Code of the International Standards and Recommended Practices for a Safety Investigation into a Marine Casualty or Marine Incident (Casualty Investigation Code), adopted by IMO Resolution MSC.255(84), and corresponding provisions under SOLAS 1974, Regulation I/21.

3.             Barbados Participation

3.1           Pursuant to the Barbados Merchant Shipping Act, 2024, and consistent with Section 1189, which provides for the investigation of marine casualties, Barbados has designated the Barbados Maritime Ship Registry (BMSR) to represent the State at the MAIIF.

3.2           Through this membership, Barbados joins other national marine safety investigation authorities working collaboratively to promote uniform interpretation of the IMO Casualty Investigation Code, mutual assistance in investigations, and improved exchange of technical information relating to marine safety and human-element performance.

3.3           This affiliation reinforces Barbados’s commitment to maintaining high standards of maritime safety and transparency consistent with its obligations as a flag State under Article 94 of the United Nations Convention on the Law of the Sea (UNCLOS).

4.             Implications for Barbados-Flagged Vessels

4.1           While MAIIF membership does not impose new operational requirements on Barbados-flagged vessels, it ensures that accident investigations conducted under Barbados jurisdiction adhere to internationally recognised best practices and benefit from access to global investigative expertise.

Shipowners, operators, and ROs are reminded that the reporting of casualties and incidents remains a statutory obligation under the Barbados Merchant Shipping Act, 2024, and related regulations. All reports of marine casualties, serious incidents, and occurrences involving Barbados-flagged ships shall continue to be submitted to BMSR in accordance with Bulletin 018.

5.             Enquiries

All enquiries and reports relating to marine casualty investigations or Barbados’s participation in MAIIF shall be directed to:

accidents@barbadosmaritime.com

Investigation Department

Barbados Maritime Ship Registry

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

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

 

1. Purpose

1.1 This Marine Circular is issued by the Barbados Maritime Ship Registry to provide guidelines to Appointed Nautical Inspectors (ANI) for conducting operational checks and safety drills during flag Inspections.

1.2 This is not intended to limit or restrict the professional judgment of the ANI or the scope of the inspection to be carried out.

1.3 This Marine Circular is based on the Paris MoU “Guidance on Procedures for operational controls”.

2. Scope

2.1 Safety drills, including fire drills, shall be carried out as realistically as possible, simulating an actual emergency to ensure that the crew is fully familiarised, prepared and capable of responding effectively.

2.2 The general assessment of any drill shall include:

.1 Training: Confirm that the crew have hands-on experience using lifesaving, firefighting or other relevant equipment and have sufficiently trained their roles in an emergency.

.2 Familiarisation: Ensure that all crew members know their specific duties, responsibilities, and the location of their assigned lifeboats or life rafts.

.3 Confidence: Confirm that the crew are confident in the effectiveness of the safety equipment and procedures, which will reduce panic during a real emergency.

.4 Teamwork: Evaluate the cooperation and communication among crew members during the drill.

3. Conduct of Drills

3.1 The ANI shall conduct at least two of the following drills during every flag Inspection, except the pre-registration inspection:

.1 Fire drill;

.2 Abandon ship drill;

.3 SOPEP/SMPEP drill;

.4 Man Overboard (MOB) drill

.5 Enclosed space entry and rescue drill;

.6 Emergency steering drill;

.7 Any other Drill as appropriate.

3.2 General Procedures for Drills:

.1 Upon arrival on board, the master and senior officers shall be informed about the intended drills to be carried out;

.2 Before the drill, the ANI shall check the records of the crew’s last participation in emergency drills on board. The documentary evidence of the crew members’ familiarisation with the relevant STCW training shall be checked;

.3 The locations and methods of the drills, such as fire, man-over-board (MOB), or enclosed space entry drills, shall be agreed with the master subject to his discretion. The master shall be instructed to notify the crew that a drill will be performed, but shall not reveal the specific type or location where the emergency is simulated, as this could affect the realism and accuracy of evaluating the crew’s response;

.4 If passengers are on board, they should be informed about the drill through public announcements;

.5 During the drill, the ANI shall question crew members at random, to evaluate their safety awareness on board the vessel.

3.3 Precautions:

.1 The ANI shall not request any drill or activity that, in the Master’s judgment, could endanger the vessel, crew, passengers, or cargo;

.2 When requesting a drill, the ANI should, as far as possible, avoid disrupting normal shipboard operations such as cargo or ballast handling, and the drills should not cause unnecessary delay to the vessel;

.3 Drills should be carried out at a safe and controlled pace. Everyone involved shall understand their duties and how to use the equipment safely. If unsafe practices are observed, or if a real emergency occurs, the ANI shall instruct the Master to stop the drill immediately;

.4 The ANI should create and control the scenario to achieve the most realistic results, as this keeps some level of uncertainty for the crew and reflects real-life conditions in a better way;

.5 It is recommended that ANIs wear high-visibility vests to distinguish themselves from crew members during the drill;

.6 Clear communication between the ANI and crew is essential. Drills may be divided into stages, such as:

i) Stage I: Incident – A fire report or alarm received on the bridge

ii) Stage II: Fire Drill

iii) Stage III: Abandon Ship Drill

3.4 Observing Drills:

.1 The ANI shall assess whether the drill is acceptable based on three key principles: command, control, and communication, while keeping notes as necessary;

.2 When observing a drill, the ANI(s) should confirm the following:

i) The crew are following the instructions given in the muster list;

ii) That there are enough crew members assigned to each duty or team to handle their responsibilities properly;

iii) Effective communication – between the teams, their leaders, and the Bridge (or command centre)

iv) Effective teamwork — observe and question their actions as necessary;

v) The ANI should note the time taken for the teams to assemble and their reaction time;

vi) That the equipment used in the drill works properly, including fire alarms, fire doors, personal firefighting gear, atmosphere testing instruments, etc.;

vii) The crew’s overall response time is quick enough, considering the size of the vessel, location of the fire, the number of available personnel and the equipment on hand.

.3 According to SOLAS standards:

i) Lifeboats and survival crafts shall always be in a state of readiness so that preparation for embarkation and launching can be completed in less than 5 minutes by two crew members (for vessels built after 1 July 1986);

ii) Lifeboats shall be fully boarded within 3 minutes on cargo vessels.

4. Standard Scenarios

4.1 The scenario should start by choosing a high-risk area appropriate for the drill, such as the engine room, galley, or electrical rooms. The drill scenarios shall be made as realistic as practicable.

4.2 Fire Drill:

i) The fire drill should be carried out in a suitable location, with realistic conditions such as simulated casualties, smoke, and potential hazards as far as practicable;

ii) The ANI should observe the crew’s performance in firefighting, communication, and safety procedures, including alarm activation, evacuation, ventilation control, use of equipment, and casualty handling.

4.3 Abandon Ship Drill:

i) Confirm that the escape routes are unobstructed and that muster stations are clearly marked;

ii) The ANI should ensure lifeboat drills demonstrate donning of lifejackets, testing of engine and steering, operation of davits and manoeuvring of at least one boat;

iii) The drill shall be carried out in a safe manner, and procedures involving unnecessary high risk shall be avoided;

iv) The number of crew members boarding the lifeboat shall be the minimum required at the master’s discretion;

v) Confirm that the team lowering the lifeboats is proficient and that the lifeboats are launched in safe conditions with the necessary permissions from the port authorities. Extra care shall be taken with free-fall lifeboats, and free-fall launching shall be avoided; a simulated launch may be carried out instead.

4.4 SOPEP/SMPEP drill:

i) The ANI shall confirm that the officers and crew members are familiar with their duties as per the Shipboard Oil Pollution Emergency Plan (SOPEP) and Shipboard Marine Pollution Emergency Plan (SMPEP);

ii) The use of the SOPEP/SMPEP equipment shall be demonstrated as far as practicable.

4.5 Man Overboard (MOB) drill:

i) This drill may only be performed if conditions permit and at the discretion of the master, as the full exercise is best carried out at sea while underway;

ii) The drill may still be simulated to the maximum extent possible, and communications, response times and the deployment of equipment, including the rescue boat davit and engine, shall be evaluated.

4.6 Enclosed space entry and rescue drill:

i) The drill evaluates the safe execution of enclosed space entry and rescue procedures, based on realistic scenarios agreed with the master;

ii) It verifies hazard identification, proper safety briefings, permit compliance, and the correct use of personal protective and communication equipment;

iii) The drill also verifies that the atmospheric testing equipment is properly calibrated and functional, and confirms that the rescue equipment is in good condition and ready for use.

4.7 Emergency steering drill:

i) The ANI shall check records that the emergency steering procedures are carried out at least once every three months;

ii) The ANI shall develop a realistic emergency scenario for the drill, in coordination with the master;

iii) During the exercise, the ANI shall verify that the crew are fully familiar with the emergency steering procedures, including direct control of steering from the steering compartment, proper communications and the use of alternative power sources. 4.8 Further details and guidance can be found in the Paris MoU “Guidance on Procedures for operational controls”.

5. Drill Assessment and Reporting

5.1 Upon completion of drills, the ANI shall review the entire exercise, including the debriefing conducted by the master and senior officers. Findings and any necessary corrective actions should be discussed. If operational deficiencies are significant, drills may be repeated until the ANI is satisfied.

5.2 The ANI shall take a video of all the drills carried out and be in the frame of at least one of the drills. All videos and inspection reports shall be forwarded to the Ops department.

5.3 If, in the professional judgment of the ANI, the drill performance is deemed highly unsatisfactory and the crew are unable to implement corrective measures, the ANI shall consult the BMSR Operations Department to determine appropriate actions. All observations and identified deficiencies shall be formally documented in the FSI report.

6. Validity

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

 

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

Operations Department

Barbados Maritime Ship Registry

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

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

1. Background

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

2. Purpose

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

3. GNSS Jamming and Spoofing

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

4. Enhancing Cybersecurity

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

5. Useful Links

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

6. Validity

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

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

 

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

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

1. Purpose

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

2. Application

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

3. Background

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

4. Recommendations

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

5. Validity

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

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

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

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1.             Purpose

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

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

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

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

2.             Application

2.1           This Marine Circular shall be read in conjunction with:

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

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

iii)        Resolution MEPC.381(80)

iv)        Resolution MEPC.382(80)

3.             Technical Requirements

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

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

i)           The ship is proceeding en-route;

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

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

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

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

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

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

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

4.             Recommendations

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

5.             Validity

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

 

 

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

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

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1.             Purpose

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

2.             Application

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

3.             Technical Requirements

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

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

3.3           Conditions for In Water Survey (IWS):

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

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

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

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

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

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

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

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

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

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

4.             Recommendations

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

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

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

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

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

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

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

5.             Validity

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

 

 

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

ops@barbadosmaritime.com

 

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

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1.             Purpose

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

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

2.             Application

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

3.             Background

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

i)            Pre-Registration Inspection

ii)          Initial Inspection

iii)         Annual Safety Inspection

iv)         Detention Follow-up Inspection

v)          Additional Safety Inspection

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

3.3           The Initial Inspections aim to assess:

i)            the physical condition of the vessel;

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

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

iv)         the competence of the crew;

v)          the marking of the vessel.

3.4           The Annual Safety Inspections aim to assess:

i)            the physical condition of the vessel;

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

iii)         the competence of the crew;

iv)         the maintenance of the vessel.

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

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

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

3.8           General Guidance for Conduct of Inspections:

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

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

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

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

       1.PPO01-F01 Flag State Inspection Checklist

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4.             Recommendations

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

5.             Validity

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

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

ops@barbadosmaritime.com

Operations Department

Barbados Maritime Ship Registry