Bulletins

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

1. References

• a) Barbados Merchant Shipping Act (CAP 296)
• b) Barbados Merchant Shipping Regulations
• c) Barbados Merchant Shipping Regulations
• d) Barbados Marine Notices

2. Purpose

• 2.1 This Bulletin describes the use of the Barbados Maritime Ship Registry (BMSR) Bulletin System for Barbadian ships.

3. Application

• 3.1 This Bulletin applies to all Barbadian ships above 150 GT that are engaged in international voyages.

4. Introduction

• 4.1 The Company and the master shall ensure that all persons joining a ship or unit are immediately given appropriate familiarization training with respect to the ship for emergency, safety and if applicable security in addition to their respective duties and functions.
• 4.2 The Company and the master of a ship shall ensure that watch standards and arrangements as outlined in STCW Convention Chapter VIII are always maintained.
• 4.3 The national mandatory requirements for all Barbadian ships are set by the Minister and/or Marine Administration through the Marine Shipping Act, Regulations and The Marine Notices.
• 4.4 The international mandatory requirements for all Barbadian ships are set by The IMO Instruments.
• 4.5 The BMSR bulletins are only to support the Merchant Shipping Act, Regulations, Marine Notices, and IMO Instruments and to provide an easy reference and of all the national and international requirements for Barbadian ship engaged in international voyages.
• 4.6 To improve clarity and make sure compliance with latest requirements, the BMSR has decided to reorganise the information currently provided in Bulletin, their numbering and layout.
• 4.7 Bulletins are provided with the letter “B” and three number identification, e.g., B001.
• 4.8 Bulletins specific for yacht are provided with the letter “Y” and three number identification, e.g., Y001.
• 4.9 Existing bulletins will continue to be valid until they are replaced by new version.
• 4.10 Each bulletin has an issue date which when it is published, and effective date from which the bulletin enters into effect. This is to allow the BMSR to provide information ang guidance on eventual upcoming new regulations.
• 4.11 It should be noted that specific bulletin may be reserved for future use (e.g., where referenced in legislation) so they may not be published in numerical order.
• 4.12 All bulletins are available on the BMSR website.
• 4.13 Bulletins when downloaded from the BMSR website are uncontrolled, therefore the BMSR website should be checked for the latest version of this or of any other bulletin.

5. Use and retention of Bulletins

• 5.1 Companies shall ensure that the contents of Bulletins, which are relevant to their operations, are incorporated into their safety management system procedures. Copies of relevant Bulletins, in their latest revision, shall be retained in Company offices and on board all Barbadian ships.
• 5.2 Recognised Organisations and BMSR Nautical Inspectors must ensure that the contents of relevant BMSR Bulletins are incorporated in their procedures relating to their Barbados delegation.

6. Distribution of BMSR Bulletins

• 6.1 Notification of the addition, or revision, of a document is sent by automatic emails.
• 6.2 To subscribe and receive latest Bulletins, it is essential to register on the BMSR website and provide First Name, Last Name and Email Address.
• 6.3 Subscription is free of charge.

Revision History

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

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1. References
a) Barbados Merchant Shipping Act (CAP 296)
b) Facilitation (FAL) Committee Circular - FAL.5/Circ.39/Rev.2/Corr.1 1 January 2017

2. Advantages of Barbados Registration
2.1 The Barbados Maritime Ship Registry (BMSR) offers competitive Initial Registration and Annual Fees, details of which can be found on the BMSR website. See Barbados Maritime Ship Registry Fees.
2.2 The BMSR is on the Paris MOU Whitelist and is qualified for USCG Qualship21 Program.
2.3 The BMSR has: 
.1      A friendly and dedicated team to guide through the registration process.
.2      A network of worldwide Regional Registrars to help and advise on the registration process and seafarer endorsement applications.
.3      An independent qualified and professional network of Authorised Nautical Inspectors (ANIs) to perform Flag inspections worldwide without delays to a vessel’s schedule.
2.4 The BMSR provides:
.1      24/7 Technical Support, to ensure compliance with Barbadian Laws and IMO standards is maintained at all times.
.2      Assistance from qualified and experienced professionals to help and advise on PSC inspections.
.3      24/7 vessel registration.
.4      Fast registration within a day when all documentation is received.
.5      Electronic ship certificates (Certificate of Registry (COR), Safe Manning Document (SMD) and etc.), as per Facilitation (FAL) Committee Circular - FAL.5/Circ.39/Rev.2/Corr.1 1 January 2017. This saves on courier fees and enables certificates to be delivered on board on time.

3. Purpose
3.1 This Bulletin is to help through the registration and any register alteration processes by explaining the procedures and documentation required for ships and yachts (here after both referred to as “vessel”) joining the BMSR and for any alteration to a vessel already in the Barbadian Registry.

4. Principal Registrar and Regional Registrars
4.1 The registration of a vessel to become a Barbadian vessel can be processed through the London Office or any appointed Regional Registrars located at strategic ports around the world. Their details are available on the BMSR website.

5. Eligibility
5.1 As per the Barbados Merchant Shipping Act (CAP 296) Sec. 9(1), any ship of 150 GT and above and any yacht engaged in international voyages may be approved for registration by the Principal Registrar.
5.2 Ships, and yachts when applicable, are to be classed by an IACS Member.
5.3 Any new vessel or any existing vessel up to 20 years of age is eligible to be registered with the BMSR.
5.4 Vessel eligibility is assessed by the Principal Registrar based on vessel’s history and PSC performance in the last 3 years.
5.5 Vessels of 21 years of age or older, up to 25 years of age, are considered for registration at the Principal Registrar’s discretion.
5.6 A vessel under repair or on Lay-up may be considered for provisional registration providing that the vessel undergoes a pre-registration inspection before it commences trading. The vessel has to undergo an initial inspection when in the water and in an operational condition.

6. Pre-Registration Enquires
6.1 Any inquiry regarding vessel registration is to be submitted to ops@barbadosmaritime.com.
6.2 Any inquiry for registration has to include as a minimum:
.1      Vessel Name and IMO number;
.2      Gross and Net Tonnage;
.3      Type and Age of the vessel;
.4      Vessel Manager Name and IMO number

7. Pre-Registration Inspection Requirements
7.1 New vessels and existing vessels up to 12 years of age are assessed and accepted for registration without a pre-registration inspection.
7.2 Vessels of 13 years of age or older, up to 20 years of age, might be subject to a preregistration inspection at the Principal Registrar’s discretion.
7.3 Vessels of 21 years of age or older, up to 25 years of age, are required to undergo a preregistration inspection.
7.4 A pre-purchase survey can be accepted in lieu of the pre-registration inspection on a case-by-case basis. The pre-purchase survey report shall be no older than 30 days from the application.

8. Alternative Entry Scheme
8.1 In cases where a seller does not allow additional pre-purchase survey and/or in case the vessel is at a port where a pre-registration inspection cannot be undertaken, an Alternate Entry Scheme may be utilised.
8.2 Under this Scheme a vessel may be provisionally registered, subject to satisfactory assessment by the Principal Registrar, for a maximum period of thirty (30) days. Within this period the vessel must complete all stipulated inspections and thereby be in a position to be permanently registered.

9. Provisional Registration
9.1 A vessel is first registered on provisional registration and can operate as soon as it is issued with a provisional Certificate of Registry (COR). The COR is valid for 6 months giving the owner/manager time to comply with all conditions for full registration.
9.2 As per the Barbados Merchant Shipping Act (CAP 296), the port of registry of all Barbados vessels is “Bridgetown”.
9.3 The required registration and annual fees are to be paid upon provisional registration of the vessel and are not refundable.
9.4 If the vessel’s registration is not completed before the COR expires, the vessel in question is liable to cease to be recognized as Barbadian.
9.5 When the COR expires and the ship is not permanently registered, the vessel cannot apply again for registration within one year of the issue date of the first provisional COR.
9.6 In special circumstances assessed by the Principal Registrar, Provisional Registration can be extended for up to a maximum of a further 6 months, for a total of 1 year of Provisional Registration.
9.7 The reissuance of a provisional COR after 6 months of provisional registration will be charged with an extra fee. Please See Barbados Maritime Ship Registry Fees.
9.8 This extra charge is designed to ensure that the shipowner has made proper preparation, including any mortgage arrangements, for full registration in good time.
9.9 On completion of the requirements for Provisional Registration, the BMSR issues the following:
.1      Provisional Certificate of Registration (COR);
.2      Safe Manning Document (SMD);
.3      Initial Continuous Synopsis Record (CSR) (subject to receipt of the final CSR from former flag);
.4      Ship Station Licence (SSL);
.5      Carving & Marking Note (CMN);
.6      Declaration of Maritime Labour Compliance Part I (DMLC Part I)
.7      Bunker Oil Pollution Damage (Bunker) Certificate, if required;
.8      Oil Pollution Damage (Tanker CLC ) Certificate, if required.
9.10 To issue a new CSR a complete CSR Amendment Form 2 is to be submitted to the BMSR.
9.11 On completion of registration the Transcript of Register is issued only upon request by the shipowner, ship managers and any third party on request.

10. LRIT Registration on Data Centre
10.1 When a vessel is provisionally registered the following data has to be entered onto the LRIT Data Centre. This is usually dealt with by the authorised service provider Fulcrum Maritime Systems Ltd. (www.fulcrum-maritime.com), that is also authorised as Application Service Provider (ASP) to perform the LRIT Conformance Test Report (CTR) in accordance with the current LRIT performance standards and functional requirements.

11. Permanent Registration
11.1 On completion of the requirements for Permanent Registration, the BMSR issues the following:
.1      Permanent Certificate of Registration (COR);
11.2 The permanent COR has 5 years validity and needs to be revalidated and reissued at or before the expiry date.
11.3 A vessel can be permanently registered upon receipt of:
.1      Certificate of Deletion from the losing Registry;
.2      Final (deletion) CSR from the losing Registry;
.3      Carving and Marking Note signed by ANI;
.4      Sighting of original Bill of Sale and/or Builder’s Certificate;
.5      Initial flag Inspection report.
11.4 Vessels that are permanently registered have to pay Annual fees, which are to be paid on the 1st of January of each subsequent year. Failure to do so may lead to deletion of the vessel from the register.
11.5 Vessels that have to move from one port to another to complete repairs or re-activation, and have not completed the Initial inspection, can do so with the prior knowledge of the BMSR and under conditions applied by their Classification Society through the issue of a Conveyance Certificate.

12. Registration – Application
12.1 Shipowners, agents or vessel managers seeking registration with the BMSR should initially submit Form 4 - Application for Registration or Change of Name of a Ship by email to registry@barbadosmaritime.com.
12.2 The list of forms and documents for Provisional and Permanent Registration of a ship are indicated on Checklist 02 Ship Registration.
12.3 The list of forms and documents for Provisional and Permanent Registration of a yacht are indicated on Checklist 01 Yacht Registration.
12.4 Upon receipt of Form 4 - Application for Registration or Change of Name of a Ship , the London Office will allocate and provide the following:
.1      Call Sign
.2      Official Number (O/N);
.3      Maritime Mobile Service Identity (MMSI) Number;
12.5 If the vessel joining the Registry is flagged with another Administration, the BMSR must receive from the owner a Transcript of Register for provisional registration confirming that no encumbrances remain against the vessel, for permanent registration.

13. Bareboat Charter Out
13.1 The Barbados Merchant Shipping Act (CAP 296) allows any vessel registered in Barbados to be dual registered under a bareboat charter out agreement to a Secondary Registry (flag), whilst also maintaining Barbadian registration, on the following conditions:
.1      The laws of the second flag allow it; 
.2      A bareboat charter Party is established between the shipowner and the charterer;
.3      Mortgagee’s Consent (if applicable) to transfer out to Secondary Registry;
.4      The Secondary Registry cannot make any changes to the vessel’s registered details without first informing the BMSR (Primary Registry);
.5      The Secondary Registry cannot enter nor delete Bills of Sale or Mortgages against the vessel under any circumstances.
13.2 During the period the vessel is bareboat chartered out of the Barbados Registry the only actions allowed to be recorded on the Barbados Registry are Mortgages, Transfers and Sale of the Vessel.
13.3 The BMSR Permanent COR must be removed from the vessel.
13.4 A vessel applying to register as Bareboat Charter Out can do so by submitting an email to registry@barbadosmaritime.com the documents as per Checklist 09 Bareboat (Demise Charter).
13.5 On completion of the requirements for Charter Out Registration, the BMSR issues the following:
.1      Barbados Letter of Authority (Stating No mortgage shall be recorded in Secondary Registry during period of the said Charter)
.2      Barbados Demise Charter Out - Certificate of Suspension

14. Bareboat Charter In
14.1 The Barbados Merchant Shipping Act (CAP 296) allows any vessel registered on Primary Registry (flag) to be dual registered under a bareboat charter in agreement to with the Barbados flag (Secondary Registry), whilst also maintaining registration with the Primary Registry, on the following conditions:
.1      The laws of the second flag allow it;
.2      A bareboat charter Party is established between the shipowner and the charterer;
.3      Mortgagee’s Consent (if applicable) to transfer out to the BMSR;
.4      The BMSR cannot make any changes to the vessel’s registered details without first informing the Primary Registry;
.5      The BMSR cannot enter or delete Bills of Sales or Mortgages against the vessel under any circumstances.
14.2 During the period the vessel is bareboat chartered into the Barbados Registry all ship certificates are issued by the BMSR, but the BMSR cannot record/Discharge/Transfer and process the sale of the vessel.
14.3 The Secondary Registry Permanent COR must be removed from the vessel.
14.4 A vessel applying to register as Bareboat Charter In can do so submitting by email to registry@barbadosmaritime.com the documents as per Checklist 09 Bareboat (Demise Charter).
14.5 On completion of the requirements for Charter In Registration, the BMSR issues the following:
.1       Letter to the Primary Registry confirming acceptance by the BMSR;
.2       Barbados Demise Charter In Certificate of Registry;
.3       Safe Manning Document (SMD);
.4       Continuous Synopsis Record (CSR) (initial) ) (subject to receipt of the final CSR from former flag);
.5       Ship Station Licence (SSL);
.6       Carving & Marking Note (CMN); 
.7       Declaration of Maritime Labour Compliance Part I (DMLC Part I)
.8       Bunker Oil Pollution Damage (Bunker) Certificate, if required;
.9       Oil Pollution Damage (Tanker CLC ) Certificate, if required.

15. Deletion
15.1 Deletion of a vessel from the Register may be initiated on notification of the vessel owner's intention to de-register.
15.2 For the deletion of the vessel: 
.1      All outstanding fees have been paid;
.2      documents issued as per paragraph 15.5 have been paid;
.3      Original discharged mortgage instrument stamped and signed by the mortgagee is to be provided (when applicable).
15.3 In the case of the vessel having a mortgage against it being removed from the Registry, the BMSR will provide advance written notification to the mortgagee(s) announcing the pending deletion.
15.4 When the mortgage is not discharged prior to the vessel leaving the Registry, the Register entry remains open showing details of the mortgage until such time as the mortgage is discharged.
15.5 When the vessel is deleted, the BMSR will issue:
.1      Deletion Certificate;
.2      Final (Deletion) CSR
.3      Transcript of Registry
15.6 On completion of the vessel’s deletion, the BMSR will inform Fulcrum accordingly.

16. Registry Alterations – Change of Ownership
16.1 To change ownership of the vessel while the vessel remains with the BMSR , the documentation of Checklist 05 Change of Owner, the discharge/transfer of any existing mortgages and the recording of any new mortgages is to be submitted by email to registry@barbadosmaritime.com.
16.2 Written Consent to the transfer of ownership is to be obtained from parties having a registered interest in the vessel, namely mortgagees and/or bareboat charter party principals.
16.3 On completion of this registry alteration, the BMSR issues the following, as applicable:
.1      Permanent Certificate of Registry (COR);
.2      Safe Manning Document (SMD);
.3      Continuous Synopsis Record (CSR);
.4      Ship Station Licence (SSL);
.5      Carving & Marking Note (CMN);
.6      Declaration of Maritime Labour Compliance Part I (DMLC Part I);
.7      Maritime Labour Certificate (MLC);
.8      Bunker Oil Pollution Damage (Bunker) Certificate, if required; 
.9      Oil Pollution Damage (Tanker CLC ) Certificate, if required.
16.4 To issue a new CSR a complete CSR Amendment Form 2 is to be submitted to the BMSR.
16.5 On completion of this register alteration, the BMSR will provide an updated LRIT contact list to Fulcrum.
16.6 An additional fee for “Change to Register Entry” is applied along with the fees for the reissuance of any of the documents issued as per paragraph 16.3. See Barbados Maritime Ship Registry Fees.

17. Registry Alterations – Change of Managers
17.1 To change the managers of the vessel while the vessel remains with the BMSR , the documentation of Checklist 11 Change of Manager is to be submitted by email to registry@barbadosmaritime.com.
17.2 On completion of this registry alteration, the BMSR issues the following, as applicable:
.1      Safe Manning Document (SMD);
.2      Continuous Synopsis Record (CSR);
.3      Ship Station Licence (SSL);
.4      Declaration of Maritime Labour Compliance Part I (DMLC Part I);
.5      Maritime Labour Certificate (MLC);
.6      Bunker Oil Pollution Damage (Bunker) Certificate, if required;
.7      Oil Pollution Damage (Tanker CLC ) Certificate, if required.
17.3 To issue a new CSR a complete CSR Amendment Form 2 is to be submitted to the BMSR.
17.4 On completion of this registry alteration, the BMSR will provide an updated LRIT contact list to Fulcrum.
17.5 An additional fee for “Change to Register Entry” is applied along with the fees for the re-issuance of any of the documents issued as per paragraph 17.2. See Barbados Maritime Ship Registry Fees.

18. Registry Alterations – Change of Vessel’s Name
18.1 For this register alteration the owner is to obtain written approval for the name change from any existing mortgagee.
18.2 To inform the BMSR of the intention to change a vessel’s name the mortgagee’s written consent together along with Form 4 - Application for Registration or Change of Name of a Ship is to be submitted by email to registry@barbadosmaritime.com.
18.3 The list of documents for this registry alteration indicated on Checklist 08 Change of Vessel’s Name .
18.4 On completion of this registry alteration, the BMSR issues the following, as applicable:
.1      Carving & Marking Note (CMN);
.2      Certificate of Registry (COR);
.3      Safe Manning Document (SMD);
.4      Continuous Synopsis Record (CSR);
.5      Ship Station Licence (SSL);
.6      Declaration of Maritime Labour Compliance Part I (DMLC Part I);
.7      Maritime Labour Certificate (MLC);
.8      Bunker Oil Pollution Damage (Bunker) Certificate, if required;
.9      Oil Pollution Damage (Tanker CLC ) Certificate, if required.
18.5 To issue a new CSR a complete CSR Amendment Form 2 is to be submitted to the BMSR.
18.6 On completion of this registry alteration, the BMSR will:
.1      Inform the Barbados Radio Licensing Authority for the updating of the MMSI;
.2      provide an updated LRIT contact list to Fulcrum;
.3      advise the vessel classification society and RO.
18.7 An additional fee for “Change of Vessel’s Name” is applied along with the fees for the reissuance of any of the documents issued as per paragraph 18.4. See Barbados Maritime Ship Registry Fees.

Revision History

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

1. References
a) Barbados Merchant Shipping Act (CAP 296)

2. Purpose
2.1 This Bulletin is to advise on the process for the registration and discharge of mortgages on vessel registered with the BMSR.

3. Mortgage - General
3.1 No mortgage instrument can be recorded on vessel that are in bareboat chartered (Demise In) with the BMSR and have dual registration with another register ( Primary Registry).
3.2 Except as far as is necessary to make a mortgaged vessel or mortgaged share available as a security for the mortgage debt, the mortgagee is not, by reason only of the mortgage, the owner of the vessel or share; nor does the owner cease to be the owner thereof by reason only of the mortgage.
3.3 A registered mortgagee has the absolute power to dispose of the vessel or share to which the registered mortgage relates and to give effectual receipts for the purchase money.
3.4 When there are more persons than one registered as mortgagees of the same vessel or same share, a mortgagee is not entitled, except by order of a court of competent jurisdiction, to sell that vessel or share without the concurrence of every prior mortgagee whose mortgage is earlier in time than his/her.
3.5 A registered mortgage of a vessel or share is not affected by any act of bankruptcy committed by the mortgagor after the date of the record of the mortgage in the register, notwithstanding that the mortgagor at the beginning of his bankruptcy had the vessel or share in his possession, order or disposition, or was reputed owner thereof; and the mortgagee is preferred to any right, claim or interest therein of the other creditors of the bankruptcy or any trustee or assignee on their behalf.
3.6 A mortgage may secure future advances and shall not be extinguished or lose its priority because all previously outstanding obligations secured thereby have been fully repaid or otherwise performed.
3.7 The obligations secured by a mortgage may be expressed in any unit or units of amount to which the parties may agree, including but not limited to currency of Barbados, currency or currencies of any foreign state or states or in equivalents of any other unit or units of account established by intergovernmental organisations.
3.8 A fee for “Mortgage Transaction” is applied for any registration, transfer, and discharge of Mortgages. See Barbados Maritime Ship Registry Fees.
3.9 Mortgages can be recorded on a Barbadian vessel as soon as the vessel has been issued with a provisional Certificate of Registry (COR). If for any reasons the vessel in not permanently registered, the mortgages remains open even when the vessel has left the register as per sections 3.10, 3.11 and 3.12 below.
3.10 As per Ch.29(1) of CAP 296, in the event of a registered vessel being actually or constructively lost, taken by the enemy, burnt or broken up, or ceasing to be a Barbadian vessel, the registration of the vessel shall be considered as closed except so far as relates to existing certificates of mortgage entered therein.
3.11 When the mortgage is not discharged prior to the vessel leaving the Register, the Register’s entry remains open showing details of the mortgage until such time as the mortgage is discharged.
3.12 In the case of the vessel having a mortgage against it being removed from the register, the BMSR will provide advance written notification to the mortgagee(s) announcing the pending deletion.
3.13 Any interested party can purchase a Transcript of Register of the Mortgage by email to registry@barbadosmaritime.com or on through the BMSR Portal. The Transcript of Register provides the Register details of the vessel’s mortgage, encumbrances, and liens, noting the time and date the revisions were recorded.

4. Mortgage Registration
4.1 For the recording of a mortgage against a vessel documentation listed in Checklist 06 “Mortgage Entering & Deleting” has to be submitted by email to registry@barbadosmaritime.com.
4.2 Mortgages are registered against the vessel concerned once the documentation has been reviewed and confirmed by the BMSR as complete and acceptable.
4.3 Mortgages are recorded in the order in time in which they are produced to the BMSR, and not according to the date of the mortgage. Each mortgage priority over any other mortgage is recorded by the noting of the date and time of each mortgage’s entry and the allocation of a letter denoting the order of the mortgage entry, ‘A’ confirming the first mortgage recorded.
4.4 Each mortgage is lettered sequentially along with:
.1      The number of shares assigned to the mortgage being entered;
.2      The nature and date of the transfer of interest;
.3      The name and address of the mortgagee acquiring title or power.
4.5 Where the vessel has been previously registered in a foreign country and mortgages were registered against that vessel, at the time of registration the BMSR is to receive the written consent of every mortgagee and those mortgages are shall be recorded in the order of precedence as was indicated in the previous register.
4.6 The original mortgage instrument is signed and filled in with the date and time of the recording into the Register. A copy of the mortgage instrument is retained by the BMSR, and the signed original is returned to each mortgagee or despatched elsewhere according to the instructions received from the sender.
4.7 On completion of the mortgage registration the BMSR will issue a Transcript of Register, which provides the revised Register details noting the time and date the revisions were recorded.

5. Transfer of Mortgage

• 5.1 For the transfer of a mortgage against a vessel a declaration of transmission is to be submitted along with the documents listed in Checklist 06 by email to registry@barbadosmaritime.com.
• 5.2 A registered mortgage or transfer of a vessel or share therein may be transferred to any person.
• 5.3 On the production of an instrument of transfer in the prescribed form, the BMSR will record it by entering in the register the name of the transferee or mortgagee of the vessel or share; and shall endorse on the instrument of transfer a note that it has been recorded by him/her on the date and time stated.
• 5.4 When the interest of a mortgagee in a vessel or share therein is transmitted on death or bankruptcy or by other lawful means not being a voluntary transfer, the transmission must be authenticated by a declaration of transmission by the person to whom the interest is transmitted.
• 5.5 On receipt of a declaration of transmission of a registered mortgage accompanied by the required evidence, the BMSR shall enter the name of the person entitled under the transmission in the register as mortgagee of the vessel or share in respect of which the transmission has occurred.
• 5.6 On completion of the transfer of mortgage the BMSR will issue a Transcript of Register. This provides a hard copy of the revised Register details noting the time and date the revisions were recorded.

6. Mortgage Discharge

• 6.1 For the discharge of a mortgage, documentation listed in Checklist 06 has to be submitted by email to registry@barbadosmaritime.com .
• 6.2 The discharge of a mortgage is initiated by the submission of the original mortgage instrument by the owner (mortgagor) or lending bank (mortgagee) bearing the endorsement of the mortgagee that the mortgage has been discharged.
• 6.3 The BMSR will record the discharge of the mortgage by making an entry assigned to the relevant mortgage, recording the date and time of the entry.
• 6.4 The BMSR will sign and stamp the mortgage instrument recording the date and time the mortgage was discharged.
• 6.5 The original mortgage instrument will be returned to the person designated by the sender.
• 6.6 On completion of the Mortgage discharge the BMSR will issue a Transcript of Register. This provides a hard copy of the revised Register details noting the time and date the revisions were recorded.

Revision History

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

1. References

• a) Barbados Merchant Shipping Act (CAP 296)
• b) United Nations Convention on the Law of the Sea (UNCLOS)
• c) International Safety Management (ISM) Code, adopted by IMO Resolution A.741(18)
• d) IACS Procedural Requirements PR17 Reporting on deficiencies possibly affecting the implementation of the ISM Code on board
• e) MLC Maritime Labour Convention, 2006

2. Purpose

• 2.1 This Bulletin sets out the measures for Flag State Inspections as required under sections 202 to 208 of Barbados Merchant Shipping Act (CAP 296) and Articles 94 and 217 of the United Nations Convention on the Law of the Sea (UNCLOS).

3. Application

• 3.1 This Bulletin applies to all Barbados registered vessels engaged in international voyages.
• 3.2 Pleasure (Private) yachts and unmanned barges are exempt from Flag State Inspections.

4. Flag State Inspections – General

• 4.1 The Flag State Inspections are to ensure that the arrangements, materials, and scantlings of the items below are in all respects satisfactory for the service for which the Barbadian vessel is intended.
• .1      The hull.
• .2      The boilers and other pressure vessels.
• .3      The main and auxiliary machinery.
• .4      The electrical installation.
• .5      All other equipment.
• 4.2 The Flag State Inspections also verify that:
• .1      The vessel complies with the standards of the applicable international conventions and codes.
• .2      The vessel is effectively managed by the company, and that the safety management system is effective and implemented properly as per the International Safety Management (ISM) Code, adopted by IMO Resolution A.741(18).
• .3      That Barbados national requirements, particularly those relating to the official logbook, crew articles, seafarer endorsements, and certificates, are being followed.
• .4      That the standard of work conducted by Recognised Organisations continues to meet the standards required by the BMSR.
• 4.3 The scope of the Flag State Inspections is not necessarily as the Annual, Periodic or Renewal Statutory Surveys conducted by Barbados Recognised Organisations (ROs).
• 4.4 Certain aspects of the inspection may be conducted by a sampling process. Therefore, the absence of deficiencies identified during the inspection does not mean deficiencies do not exist.
• 4.5 All Flag State Inspections can be conducted only by Barbados Appointed Nautical Inspectors (ANI), who must always contact the BMSR to request an authorisation code and specific instructions.
• 4.6 The BMSR has a large network of ANIs who cover all major ports, details of which can be found on the BMSR website under List of Appointed Nautical Inspectors.
• 4.7 ANIs are not restricted to a specific area or region so may inspect a vessel in any location.
• 4.8 The cost of an inspection is set independently by the ANI.
• 4.9 All costs relating to a Flag State Inspection are to be agreed between the shipowners/managers and the ANI and payment made directly to the ANI.
• 4.10 Failure to carry out a Flag State Inspection is considered by the BMSR as evidence of a failure of the safety management system of the vessel and company, hence as a Major Non-Conformity (MNC) under paragraphs 3 and 5 of the International Safety Management (ISM) Code, adopted by IMO Resolution A.741(18). An additional external DOC or SMS audit may be requested to address this.

5. Flag State Inspections – Documentation

• 5.1 On the completion of a Flag State Inspection, the ANI submits the inspection report, a list of deficiencies and/or observations to the BMSR and the Master.
• 5.2 On completion of both Initial Inspection and AFSI, the ANI also issues a Certificate of Inspection (CoI) with validity until the anniversary date of the vessel.
• 5.3 The CoI must be displayed onboard in a prominent location, typically in the accommodation or on the bridge.
• 5.4 Failure to display a valid CoI may result in a deficiency being raised during the next inspection.

6. Flag State Inspections – Type of Inspection

• 6.1 Pre-Registration Inspection
• .1      All vessels over 12 years of age are required to undergo a pre-registration inspection before they can be accepted for provisional registration. However, this requirement may be waived at the Principal Registrar’ discretion.
• .2      No vessel can be approved for provisional registration until the pre-registration inspection report has been reviewed by the BMSR and deficiencies addressed as per the BMSR request.
• .3      Shipowners and managers must consider the potential of delays to the registration process should the pre-registration inspection report not be received and reviewed by the BMSR and should ensure the inspection is carried out at least 7 days before they intend to register the vessel.
• .4      In exceptional circumstances, the BMSR may accept a recent (within 1 month) pre-purchase inspection report in lieu of a Pre-Registration Inspection.
• .5      In cases where a seller does not allow additional pre-purchase survey and/or in case the vessel is at a port where a Pre-Registration Inspection cannot be undertaken, the Alternate Entry Scheme may be utilised.
• .6      Under the Alternate Entry Scheme, a vessel may be provisionally registered, subject to satisfactory assessment by the Principal Registrar, for a maximum period of thirty (30) days. Within this period the vessel must undergo the Pre-Registration Inspection.
• 6.2 Initial Inspection
• .1      The Initial Inspection is to be conducted within the period of provisional registration (normally 6 months).
• .2      The vessel can only be permanently registered once the vessel has undergone a satisfactory Initial Inspection.
• .3      Failure to arrange the Initial Inspection within the period of Provisional Registration may result in the vessel being refused permanent registration.
• 6.3 Annual Flag Safety Inspection (AFSI)
• .1      All vessels registered with the BMSR have an anniversary date, which is the annual anniversary of the registration date indicated on the certificate of Registry(COR).
• .2      The AFSI is to be conducted within the period 3 months either side of the vessel’s anniversary date.
• 6.4 Follow-up Inspection
• .1      A Follow-up Inspection might be carried out where the vessel incurs in more than 3 deficiencies or is detained during Port State Control Inspection (PSCI).
• .2      The scope of a Follow-up Inspection is to verify that all deficiencies have been properly rectified, and measures put in place to prevent recurrence of the deficiencies.
• 6.5 Additional Inspection
• .1      A vessel may be requested to undergo an Additional Inspection based on, but not limited to:
•          i) Persistent failure to rectify deficiencies by the due dates or recurrence of deficiencies;
•          ii) PSCIs and AFSIs;
•          iii) Class and Statutory Surveys;
•          iv) International Safety Management Code (ISM) audit(s);
•          v) IACS Procedural Requirements PR17 Reporting on deficiencies possibly affecting the implementation of the ISM Code on board;
•          vi) Information on serious defects or substandard conditions received from the BMSR Inspectors, Recognised Organisation surveyors and auditors, other Administrations, etc.;
•          vii) Information received from the BMSR ANIs, PSCOs, ROs surveyors, crew members, etc., of serious breaches of the MLC Maritime Labour Convention, 2006.
• .2      The Additional Inspection is a one-off Flag State Inspection.

7. Special Inspection Program (SIP)

• 7.1 The SIP applies to those vessels where there is evidence of declining standards of operation and/or maintenance, or evidence of a significant lack of compliance with international Conventions and/or national requirements, or where a trend towards general noncompliance has been identified.
• 7.2 A vessel is placed automatically under the SIP when detained on more than one occasion in a 24-months period by a Port State Control Officer (PSCO).
• 7.3 A vessel may also be placed under the SIP based on one of the reasons listed in paragraph 6.5.1 above.
• 7.4 When a vessel is placed under the SIP, the shipowners/managers are to be notified by the BMSR with the reasons for the decision and with the time schedule of the SIP.
• 7.5 The first Special Inspection due date is one (1) month from the vessel being placed under the SIP.
• 7.6 The subsequent Special Inspection due dates are at three (3) month intervals thereafter.
• 7.7 When a vessel is under the SIP a new CoI is issued after each Special Inspection and valid for three (3) months.
• 7.8 The next Special Inspection is to be carried out within one (1) month before or after the due date.
• 7.9 After the first and any following Special Inspection if the BMSR is satisfied that the vessel has no deficiencies and proper corrective actions have been taken the vessel is removed from the SIP and will revert to the standard AFSI with the anniversary date as defined in paragraph 6.3.1 above.
• 7.10 If the BMSR is not satisfied with the rectification of the deficiencies and corrective actions the vessel is maintained under the SIP.
• 7.11 The SIP is intended to achieve satisfactory improvements within a twelve (12) month period from the date of inclusion (4 special inspections).
• 7.12 Where a vessel changes shipowners and/or managers while under the SIP, the vessel is meant to continue with the SIP. However, the vessel may be considered for removal from the SIP at the Principal Registrar’s discretion.
• 7.13 A vessel that has not addressed deficiencies and/or has not reached standards of operation and/or maintenance improvement after twelve (12) months is reviewed by the Principal Registrar and may incur on deletion from the register.
• 7.14 During a Special Inspection, new additional deficiencies may be raised, and it is particularly important that all deficiencies are proactively dealt with by the master and crew. Documentary evidence of this process is essential.

8. Deficiencies

• 8.1 The BMSR may add, remove, or amend deficiencies following a review of the Flag State Inspection reports and the list of deficiencies issued by the ANI.
• 8.2 All deficiencies must be closed out and evidence of rectification must be provided directly to the BMSR by email to ops@barbadosmaritime.com and by the due date given.
• 8.3 Acceptable evidence to close out a deficiency may include, but is not limited to:
• .1      Pictures.
• .2      Classification Society or RO survey report.
• .3      Certificate of maintenance.
• .4      Invoice or delivery notes.
• .5      Non-conformity reports or Corrective Action Plan (CAP).
• 8.4 Failure to rectify a deficiency within the due dates is considered by the BMSR as evidence of a failure of the safety management system of the vessel and company, hence as a Major Non-Conformity (MNC) under paragraphs 3 and 5 of the International Safety Management (ISM) Code, adopted by IMO Resolution A.741(18). An additional external DOC or SMS audit may be requested to address this.
• 8.5 Persistent failure to rectify deficiencies by the due dates or repeat occurrence of deficiencies may result in the vessel being:
• .1      Required to undergo an Additional Inspection as per paragraph 6.5 above;
• .2      Placed under the SIP as per paragraph 7 above
• .3      Suspended ( flag State detention);
• .4      Deleted from the Registry.

9. Observations

• 9.1 Observations give the ANI the opportunity to bring to the BMSR and shipowners/managers attention to items which are not considered deficiencies but that may be:
• .1      Worthy of further improvement (e.g., on board procedures, training, etc); or,
• .2      Worthy of praise (e.g., certain on-board working practices, maintenance levels, etc).
• 9.2 Observations are recorded in the inspection report and may be considered as suggestions for improvement by the Company.
• 9.3 Observations do not need to be formally closed out, but the Company may advise the BMSR of any follow up action taken.

10. Suspension of AFSIs

• 10.1 When a vessel is out of service, in layup or on bareboat charter out to a Secondary Registry the requirement for AFSIs during this period may be suspended if the BMSR is advised.
• 10.2 When the vessel re-enters service or returns to the BMSR from bareboat charter out and in case the due AFSI has not been completed on time and is overdue by more than 3 months a new Initial Inspection within one month of the vessel re-entering or returning is to be carried out.
• 10.3 In all cases the anniversary date does not change and is as defined in paragraph 6.3.1 above.

Revision History

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

1. References

• • a)      IMO Assembly Res. A.1155(32) Procedures for port state control, 2021;
  • b)      ILO Guidelines for port State control officers carrying out inspections under the Maritime Labour Convention, 2006;
  • c)      The International Safety Management Code (ISM Code).

2. Purpose

• • 2.1      This Bulletin provides instructions and sets out the manner in which compliance with Port State Control Inspections (PSCIs) should be managed to avoid detentions and undue delays to vessels.

3. Application

• • 3.1      This Bulletin is applicable to all Barbadian vessels on international voyages arriving at port states which operate Port State Control (PSC) regimes in compliance with international conventions, local regulations, and under the principles of the IMO Res. A.1155(32) and the ILO Guidelines for port State control officers carrying out inspections under the Maritime Labour Convention.

4. PSCI Reporting

• • 4.1      The ISM Managers are required to send copies of all PSCI reports (Form A and, if deficiencies are identified, Form B) to the BMSR at ops@barbadosmaritime.com as soon as possible after the PSCI.

• • 4.2      The BMSR will examine and record all the PSC reports and will determine any further action that may be necessary, such as an additional external ISM audit and/or Flag Inspection.

• • 4.3      Based on the PSCI deficiency’s action code, managers must provide evidence of closure of any PSC deficiencies to BMSR at ops@barbadosmaritime.com within the given time frame. For deficiencies with Action Code 17 (to be rectified before departure), evidence shall be provided within one week of the PSCI.

• • 4.4      The ISM Managers must also make sure that all PSCI reports for the previous 24 months, or since the date of registration if less than 24 months, are submitted to the BMSR. This is in addition to the requirement to keep PSCI reports on board the vessel for a period of minimum period of 36 months.
  • 4.5 Failure to provide PSCI reports may be considered as objective evidence of a failure in the safety management system and may lead to nonconformities being raised at external ISM audits.

5. Accidental Damage: Procedures to Avoid PSC Detention

• • 5.1     When there is a malfunction or defect that is the result of accidental damage suffered by the vessel, as per IMO Res. A.1155(32) chapter 2.3.7, the Port State Control Officer (PSCO) should not issue a detention order provided that:

• • .1      notification of the defect/malfunction has been made to the BMSR and to the RO responsible for issuing the relevant certificate;

• • .2      prior to entering a port, the Master or the ISM Manager has submitted to the port State authority details of the circumstances of the accident and the damage suffered and provide evidence of the notification to BMSR;

• • .3      appropriate remedial action, to the satisfaction of the port State authority, is taken; and

• • .4      the port State authority has ensured, having been notified of the completion of the remedial action, that deficiencies which were clearly hazardous to safety, health or environment have been rectified.

6. PSCI Preparation

• • 6.1     The ISM Managers are responsible for ensuring the vessel complies with the relevant requirements and that the ship and her crew are prepared for PSCIs.

• • 6.2     Any failures or breakdowns of equipment shall always be immediately communicated to BMSR, so a relevant dispensation (Permit) can be issued. Requests for a Permit are to be sent to ops@barbadosmaritime.com.

• • 6.3     Several ROs have produced checklists and guidance relating to preparation for PSCIs. The ISM Managers are advised to implement such checklists in the vessel’s SMS as an aid to ensuring that the vessel is routinely prepared for PSCIs.

• • 6.4     It is important that the Master and senior officers are familiar with the PSCI procedures and with Res. A.1155(32) and ILO Guidelines for port State control officers carrying out inspections under the Maritime Labour Convention, which are recommended to be carried on board for reference.

• • 6.5     The ISM Managers must also take into account the Regional PSC regime’s “Concentrated inspection campaigns” (CICs), which focus on specific areas where high levels of deficiencies have been encountered by PSCOs, or where new Convention requirements have recently entered into force. CICs generally take place annually over the three months September to November and are combined with a regular PSCI. Current CICs may be checked on the regional PSC regime websites.

7. Vessels on Priority I in Paris MoU

• • 7.1     ISM Managers are required to take additional precautions when the vessel is a priority I in the Paris MoU, as several detentions are due to easily rectified deficiencies, a lack of preparedness for a PSCI, and a lack of general knowledge of the vessel’s crew to successfully demonstrate normal shipboard equipment and procedures during a PSCI.

• • 7.2     In order to maintain the white flag status for Barbados registered ships and minimise operational risks for the overall benefit of shipowners/operators, vessels in priority I in the Paris MoU might be required to undergo an additional flag inspection at the first or second port prior to arrival in a Paris MoU port.

• • 7.3     In some cases, ISM Managers will also be required to undertake an additional flag inspection to be carried out at the same time of the PSCI, for the Appointed Nautical Inspector (ANI) to represent BMSR and give immediate assistance to the Master and the crew.

8. Conduct of PSCIs

• • 8.1     During a PSCI it is important to establish a professional working relationship with the PSCO and provide the necessary support during the PSCI.

• • 8.2     The Port State Control Officers (PSCOs) are to be met at embarkation and all the security controls (ID check and any other in accordance with the Ship Security Plan) must be carried out by the crew before escorting the PSCOs to the Master’s office.

• • 8.3     The Master shall have an opening meeting which shall cover the following areas:

• • .1       Identification of officer who will assist with the PSCI. All key staff should be present unless duty requires otherwise;

• • .2       Identification of the lead PSCO (if applicable);
  • .3       Explanation of the inspection procedure contemplated by the PSCO. If anything is unclear, the Master should ask for clarification;
  • .4       Details of any defect of equipment, including repairs and corrective action that are ongoing and the Permits (if applicable) that have been issued by the BMSR.
  • 8.4     PSCOs should never be left unescorted by a responsible officer, who should always be professional and knowledgeable of vessel’s equipment and should keep notes on any deficiencies noted by the PSCO.
  • 8.5     The responsible officer should strive to address any deficiency immediately or before the end of the PSCI.
  • 8.6     When defects cannot be dealt with immediately or when they could lead to a PSC detention, the RO or the BMSR should be contacted for proactive and appropriate corrective actions to be taken.

9. PSCI Closure and Follow-up

• • 9.1     On conclusion of the PSCI, the Master should hold a closing meeting to discuss any deficiencies, the justification for the deficiencies and/or the time-frame given for rectification of deficiencies.

• • 9.2     The Master must receive a report of the inspection from the PSCO, including details of any deficiencies. This report must be submitted to the BMSR as per section 4.

• • 9.3     Deficiencies identified at PSCIs can only be closed out directly with the PSC Authority involved and to the satisfaction of the PSCO.
  • 9.4     In some PSC Memorandum of Understanding (MoU) regimes, the rectification and closure of non-detainable deficiencies are recorded at the next PSC inspection within the same MoU.
  • 9.5     Deficiencies shall be closed with the time frame given by the action code. The ISM Managers are to be aware that any outstanding deficiency after the lapsed time will trigger a PSC Detention at the first port of the same MoU. Any deficiencies must also be closed with the BMSR as per 4.3 above.
  • 9.6     It should be noted that if a ship has open deficiencies the targeting factor may be increased with the possibility of further PSCIs.

10. PSC ISM Related Deficiencies

• 10.1   PSCOs do not perform ISM audits. However, any technical and/or operational deficiencies found during a PSCI can be individually or collectively considered by the PSCO as ISM-related to indicate that the deficiency/deficiencies show/s a failure, or lack of effectiveness, of the implementation of the ISM Code.
• 10.2   Where the PSCO has considered one or more technical and/or operational deficiencies as ISM-related, only one ISM deficiency is recorded in the PSCI report.
• 10.3   If an outstanding ISM-related deficiency from a previous PSCI exists and the current PSCI is more than three months later, the PSCO will verify, during the PSCI, the effectiveness of any corrective action taken by the company by examining the areas of the technical and/or operational deficiencies of the previous PSCI report which led to the issuance of the ISM deficiency.
• 10.4   If examination of the areas in relation to an ISM deficiency with the required corrective action within three (3) months is found not satisfactory, a new detainable ISM deficiency may be raised with the requirement for an additional external ISM Audit to be carried out before the vessel is released from detention.

11. Reporting of PSC detentions

• 11.1   The ISM Managers are required to inform the BMSR, the RO, Classification Society and the ISM issuing body if a vessel is detained.
• 11.2   BMSR shall also be informed of actions taken or planned to rectify all deficiencies as soon as practicable.
• 11.3   The ISM Managers shall undertake a Root Cause Analysis (RCA) within 30 days of the date of detention and take corrective actions to prevent a recurrence.
• 11.4   When the RCA is received, BMSR will determine what additional inspections are required of shipboard and or office Safety Management systems.
• 11.5   A vessel that is detained twice within a 12-month period will be deleted from the Register.
• 11.6   If the ISM Managers wish to dispute a detention, they should inform BMSR, whose technical officers will assess and assist with the appeal.

12. Code of Good Practice for PSCOs

• 12.1   The Code of Good Practice for port State control officers conducting inspections within the framework of the regional memoranda of understanding and agreement on port State control is available as Appendix 1 to Res. A.1155(32).
• 12.2   Any allegations of improper conduct by a PSCO should be reported to the BMSR, ISM Managers or the Master, with full details of the allegations and any supporting information, such as witness statements, for further action.

13. PSC Queries

• 13.1 Any queries regarding this Bulletin and PSCIs can be sent to BMSR at ops@barbadosmaritime.com.

Revision History

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

1. References

a) IMO Assembly a) IMO Assembly Res. A.1185(33) Procedures for port state control, 2023;
b) ILO Guidelines for port State control officers carrying out inspections under the Maritime Labour Convention, 2006;
c) BMSR Bulletin 004 – Flag State Inspections

2. Purpose

2.1 This Bulletin provides instructions and requirements for Port State Control (PSC) detentions.

3. Application

3.1 3.1 This Bulletin is applicable to all Barbadian vessels which are detained by a PSC Authority under the principles of the IMO Res. A.1185(33) and the ILO Guidelines for port State control officers carrying out inspections under the Maritime Labour Convention or under the national laws of a State (administrative or preventative detentions).
3.2 For the purposes of this Bulletin, flag State detentions have the same effect as PSC detentions.

4. Introduction

4.1 Companies operating Barbadian vessels benefit from Barbados ranked as white list in the Paris MoU and as a qualified flag of the United States Coast Guard Qualship21 program.
4.2 4.2 The BMSR is committed to retain this high ranking and to ensuring that all Barbadian vessels are always fully compliant with international Convention requirements and national regulations at all times.
4.3 The BMSR fully supports the objectives of the PSC process in eliminating sub-standard vessels, when applied in a fair and equitable manner.
4.4 PSC inspections are carried out according to:
.1 International Maritime Organization (IMO) Assembly Res. A.1185(33);
.2 ILO Guidelines for port State control officers carrying out inspections under the Maritime Labour Convention;
.3 Regional PSC regime instructions to PSC Officers (PSCOs).
4.5 A PSC detention is an action taken by a port State to prevent a substandard vessel proceeding to sea. In general, a vessel is regarded as substandard if the hull, machinery, equipment or operational safety and the protection of the environment is substantially below the standards required by the relevant international Conventions or if the crew complement is not in accordance with the Safe Manning Document, owing to, inter alia:
     .1 the absence of principal equipment or arrangements required by the Conventions;
     .2 non-compliance of equipment or arrangements with relevant specifications of the Conventions;
     .3 substantial deterioration of the vessel or its equipment;
     .4 insufficiency of operational proficiency, or unfamiliarity with essential operational procedures by the crew; and
     .5 insufficiency of manning or insufficiency of certification of seafarers.

4.6 If these evident factors as a whole or individually pose a danger to the vessel or persons on board or present an unreasonable threat of harm to the marine environment if it were allowed to proceed to sea, it should be regarded as a substandard vessel.
4.7 4.7 In taking a decision concerning the rectification of a deficiency or detention of a vessel, a PSCO takes into consideration the results of a more detailed inspection and the “Guidelines for the detention of ships” of Appendix 2 of Res. A.1185(33), which shall not be considered exhaustive but as examples of relevant detainable deficiencies.

5. PSC Detention – Notification

5.1 The Company is required to immediately notify the following parties of any detention of a Barbadian vessel :
     .1 the BMSR Operations Department ops@barbadosmaritime.com; and
     .2 the Classification Society that issued the Certificate of Class; and
     .3 the Recognised Organisation (RO) (i.e., Classification Society) that issued the statutory certificate(s); and
     .4 the RO that issued the ISM Code Document of Compliance (DOC) and Safety Management Certificate (SMC); and
     .5 for security/ISPS Code related detentions, the Recognised Security Organisation (RSO) that issued the International Ship Security Certificate (ISSC).
5.2 The Company is also required to arrange attendance of RO/Class surveyor(s) to assist in clearing the deficiencies.
5.3 The following documents are to be provided to the BMSR at the earliest opportunity, where available:
     .1 A copy of the PSC Report (Form A and B);
     .2 A copy of the Detention Notice;
     .3 Confirmation of notification to the parties listed in Section 5.1 above, as applicable;
     .4 Description of actions taken or planned to rectify all deficiencies at the earliest opportunity.
5.4 Good communications are essential to enable prompt resolution of matters related to a PSC detention. It is important that the BMSR receives the initial report promptly so that an assessment of the detention can be made. Subsequent action in Section 6 below may be modified according to the result of BMSR’s review of the initial report, particularly in cases where the detention may not be justified in the opinion of the BMSR.

6. PSC Detention – Follow Up

6.1 The Company is required to perform a Root Cause Analysis (RCA) within 30 days of the date of detention, unless otherwise agreed with the BMSR, and take the appropriate corrective and preventative actions to reduce the possibility of similar deficiencies arising in future.
6.2 The RCA report and details of corrective and preventative actions is to cover all deficiencies raised at the detention and should also include comments from the Master or Chief Engineer on the deficiencies, as applicable.
6.3 In addition to the requirements specified below, further Barbados “Detention Follow Up” inspection, additional ISM audits (DOC and/or SMC), ISPS audits and/or MLC inspections may be required.
6.4 The BMSR will determine the scope and extent of additional inspections, surveys or audits of shipboard and shore-based safety management systems of a Company, when a significant proportion of the Company’s fleet has been justifiably detained by PSC.
6.5 F6.5 For deficiencies related to non-payment or delayed payment of wages, the Company (or MLC shipowner for the purposes of MLC, if different) shall pay all wages due and provide documentary evidence to the BMSR confirming this before the vessel is released from detention. In order to prevent any recurrence of a similar situation, the Company (or MLC shipowner, as applicable), is also required to provide documentary evidence of timely payment of wages as they become due, for a period to be specified by the BMSR after release from detention. 

7. BMSR assessment following a detention

7.1 Following notification of the detention, the BMSR will review the reports and correspondence related to the vessel’s PSC and Barbados inspection performance in the 24 months prior to the detention. The follow up requirements depend on the number of detentions of the vessel in the previous 24 months, as outlined below.
7.2 For the First detention in a 12 months period, one or more of the following may be required by the BMSR prior to departure from the port of detention:
     .1 Additional “Detention Follow Up”; and/or
     .2 Additional external ISM audit; and/or
     .3 Additional MLC inspection; and/or
     .4 Additional ISPS audit.
7.3 Depending on the number and type of deficiencies the vessel might also be placed under the BMSR Special Inspection Program (SIP), as explained in Section 7 of Bulletin 004.
7.4 It should be noted that PSC authorities might also request an additional external ISM audit to be carryout before releasing the vessel from detention. The BMSR cannot waive this requirement.
7.5 If the detention occurs within the survey window for a related annual survey, the survey should be completed prior to the vessel sailing.
7.6 If the detention occurs within the survey window for a related renewal, periodical or intermediate survey, that survey should be conducted to the extent possible, except for Safety Equipment, Safety Radio and IOPP, which must be completed. Where a survey is incomplete, a schedule for completion of surveys at the next convenient port must be set by the RO and may not be delayed until the end of the window.
7.7 If the detention does not occur within any related survey window, the RO surveyor, after clearing the deficiencies, will carry out a general examination of the vessel and may decide, using his or her professional judgement, whether an additional survey is necessary. The extent of the additional survey will be at least to the extent of annual survey.
7.8 In some cases, where the PSC detention is a result of many serious deficiencies, the BMSR might also decide to reconsider the vessel’s registration and delete the vessel from the register. 
7.9 For the Second detention in a 12 months period the vessel will be specially examined to assess whether it remains acceptable for continued registration with the BMSR . This may lead to owners being asked to find an alternative register or deletion of the vessel from the Barbados register.
7.10 Should the BMSR decide to retain the vessel on the register, the vessel shall be subject to the actions as per above sections with the addition of an additional ISM DOC audit of the Company and to the extent of annual audit not later than 30 days from the date of the detention.

8. PSC Detentions - Disputes

8.1 When the Master or the Company feels that a detention is not justified, there are several ways to challenge a PSC detention.
8.2 The first step is to discuss the issue, in a professional manner, directly with the PSCO and contact the BMSR to seek advice on potentially avoiding the detention.
8.3 Since detention of a vessel is a serious matter involving many issues, it may be in the best interest of the PSCO to consider cooperating with the Company, the BMSR and/or the RO responsible for issuing the relevant certificates.
8.4 Without limiting the PSCO's discretion in any way, the involvement of the BMSR, Company and RO could result in a safer vessel, avoid subsequent arguments relating to the circumstances of the detention, and prove advantageous in the case of litigation involving "undue delay".
8.5 Furthermore, serious deficiencies could be dealt by the PSCO with “as agreed with flag or Recognised Organisation” (usually action codes 47 and 48) instead of “Detention” (action code 30).

9. National Appeal

9.1 The shipowner or operator generally has the right to appeal against a PSC detention decision to higher administrative Authority or to the Court of competent jurisdiction, according to the law in each country.
9.2 An appeal is generally made by the Company, the Owner or the Master direct to the PSC authority involved.
9.3 The links for appeal procedures are provided below:
     .1 Paris MoU Appeal Procedures;
     .2 Tokyo MoU Appeal Procedures
     .3 USA - Title 46, Code of Federal Regulations, Subpart 1.03
     .4 Mediterranean MoU Appeal Procedures
     .5 Indian Ocean MoU Appeal Procedures
     .6 Black Sea MoU Appeal Procedures
9.4 The BMSR s generally not involved in the formal appeal process but will provide, on request, a supporting statement for appeals where there are grounds to believe that the detention is not justified.
9.5 Where the PSC authority’s appeal procedure requires the appeal to be made by the flag State, the BMSR will usually appeal only where the detention is considered unjustified or inappropriate in the circumstances. In these cases, the Company will be required to provide its consent to the appeal before the appeal is lodged.
9.6 A positive outcome of a national appeal will lead to the PSC detention being deleted from the PSC regime database and, in some countries, may be used in any claim for financial compensation.
9.7 PSC authorities generally have their own national appeal procedure, which should be provided to the Master with the notice of detention.
9.8 There are time limits for the filing of an appeal and it should be noted that the time limits vary between MoUs and between PSC authorities within the same MoU.
9.9 It should be noted that if an appeal is made against a PSC detention to the Port State authority, this may exclude a subsequent review of the PSC detention by the MoU concerned.

10. Complaint

10.1 When a disagreement cannot be resolved within a reasonable time, or in cases where no appeal is made, Companies may present a complaint to the BMSR. The BMSR may then approach the PSC authority to ask it to reconsider its position.
10.2 The BMSR will proceed only in cases where the evidence supporting the complaint has sufficient merit. Companies are therefore expected to present a robust case to ensure that the complaint has the best chance of success.

11. PSC Detention Review under the MoU

11.1 In cases where an owner or operator declines to use the official national appeal procedure but still wishes to dispute a PSC detention, most of the PSC regimes still grant the opportunity for a detention review under the relevant MoU.
11.2 The BMSR is not directly involved in the review process but should be made aware of the Company’s intention to request a review. The BMSR will review the PSC report and will provide guidance and advice on how to prepare the request. The BMSR will also provide a supporting statement to explain why the detention is deemed not valid or justified.

11.3 The request for review may be made to the MoU secretariat and to the relevant MoU Review Panel (where established; not all MoUs have a detention review panel).
11.4 The review panel considers the facts of the case and delivers an opinion which may lead to the Port State reconsidering its decision, however it should be noted that the Port State is under no obligation to reconsider.
11.5 The opinion of the Review Panel is not binding on the Port State and cannot be used in any claim for financial compensation.

12. Code of Good Practice for PSCOs

12.1 The Code of Good Practice for Port State Control Officers is available as IMO Circular MSC-MEPC.4/Circ.2 and is also available as Appendix 1 to IMO Assembly Res. A.1185(33);

13. Queries

13.1 Any queries on this Bulletin may be submitted to ops@barbadosmaritime.com.

Revision History

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

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) Maritime Labour Convention, 2006 (MLC 2006).
c) ILO “Guidelines for flag State inspections under MLC 2006”.
d) ILO “Guidelines for port State control officers carrying out inspections under MLC 2006”.
e) Bulletin 013 -Barbados Approved Providers of Insurance.
f) Form 143 – DMLC Part I Application Form.
g) Form 140 – MLC 2006 – DMLC Part II.
h) Form 34 – International Safety Management (ISM) Code Declaration.
i) The International Safety Management Code (ISM Code).
j) FAL.5/Circ.39/Rev.2 and Corr. 1 Guidelines for the use of electronic Certificates.

2. Purpose

2.1 This Bulletin provides information on Barbados’ policy on the application of the MLC 2006, which governs maritime labour conditions and sets minimum standards for the working and living conditions of seafarers aboard ships, as applicable.

3. MLC Shipowner

3.1 “MLC Shipowner” means the owner of the ship or another organization or person, such as the Manager, agent or bareboat charterer, who has assumed the responsibility for the operation of the ship from the owner and who, on assuming such responsibility, has agreed to take over the duties and responsibilities imposed on shipowners in accordance with this Convention, regardless of whether any other organization or persons fulfil certain duties or responsibilities on behalf of the shipowner.”

4. Application

4.1 The MLC 2006MLC 2006 MLC 2006 applies to all seafarers and all vessels ordinarily engaged in commercial activities, whether publicly or privately owned, except as specified in Sec. 9 below.
4.2 Vessels constructed prior to 20 August 2013 are deemed to be existing vessels for the purposes of accommodation standards and accordingly Title 3 provisions of the MLC 2006 are not applicable to these vessels. Vessels constructed on or after 20 August 2013 shall comply with the accommodation standards specified in Title 3 MLC 2006.

5. Amendments of the MLC 2006 - Financial Security Documents

5.1 The Amendments to MLC 2006 entered into force on the 18th January 2017. From this date, vessels that are subject to MLC will be required to display certificates issued from an insurer confirming that insurance is in place for liabilities in respect of:
.1 Standard A2.5.1 – Repatriation; and
.2 Standard A4.2.1 - Shipowners' liability (Death & Injury Compensation).
5.2 Barbados vessels were required to comply with the new amendments as soon as the amendments entered into force, but not later than the first MLC renewal survey.
5.3 The insurance cover and the associated certificates shall be issued by a Barbados Approved Providers of Insurance as listed in Bulletin 013 and displayed on board.
5.4 The Financial Security Documents have a validity of 1 year, hence every year a copy shall also be provided to the BMSR as evidence of valid financial security.
5.5 The insurance certificates must be in a model format and must include the information specified in the MLC Amendments. It should be noted that on these certificates, the assured party will normally be the registered owner, but this will not necessarily be the same as the “MLC Shipowner” named on other MLC documentation.
5.6 Where the assured party named on the insurance certificates and the MLC Shipowner are different there should be evidence of this shall be provided to the BMSR submitting Form 34.
5.7 Valid documentary evidence of financial security is to be provided with the initial application and in the following circumstances:
.1 Change of the registered shipowner whose name is recorded in the P&I records and the issued evidence of financial security.
.2 Change to ISM Manager which invalidates the existing P&I issued evidence of financial security;
.3 Change of the vessel’s gross tonnage; and
.4 Changes to exemptions or equivalent arrangements.

6. 2022 Amendments of the MLC 2006

6.1 At its 110th session in June 2022, the ILO approved amendments to the Code of MLC 2006 which included modifications to recruitment, repatriation, recreational facilities, food and catering, medical care, and accident prevention. The amendments enter into force on 23 December 2024 and apply to all Barbadian vessels as per Sec. 4 above.
6.2 The 2022 amendments to MLC 2006 Regarding the amendments these do not necessitate any immediate changes to the Declaration of Maritime Labour Compliance (DMLC) Part I.
6.3 While the amendments to the Code of MLC 2006 shall be implemented no later than 23 December 2024, as a transitional measure, maritime labour certificates and the declarations of maritime labour compliance are required to comply with the requirements of the Convention as amended, no later than the date of the first renewal inspection following entry into force of the 2022 amendments on 23 December 2024.

7. MLC 2006 Certification

7.1 Considering Sec.Error! Reference source not found. , the MLC 2006 Certification is only required for vessels of:
.1 500 gross tonnage or over, engaged in international voyages;
.2 500 gross tonnage or over, flying the Barbados flag operating from a port, or between ports, outside Barbados waters.
7.2 The full Maritime Labour Certificate (MLC), the interim MLC and the Declaration of Maritime Labour Compliance (DMLC) Part I and II are to be as per the models given in the MLC 2006 Appendix A5-II.
7.3 The MLC is issued by a Barbados Recognised Organisation (RO) for a maximum period of five years, subject to an intermediate MLC inspection.
Interim MLC
7.4 An interim MLC is issued only once for a period of maximum of six months and in the cases below:
.1 For a new vessel;
.2 When the vessel is registered with the BMSR;
.3 When a new MLC shipowner assumes responsibility for the operation of the vessel.
7.5 The BMSR, in compliance with the MLC 2006, does not allow the issuance of a further interim MLC following the initial six months.
7.6 The initial MLC inspection for the issuance of the full MLC shall be carried out within the validity of the interim MLC. When the initial MLC inspection cannot be carried out for unforeseen reasons the BMSR might issue a permit for the issuance of a short-term MLC for a maximum of 3 months.
DMLC Part I
7.7 The DMLC Part I is the national declaration of MLC 2006 compliance and is to be attached to the MLC.
7.8 The MLC shipowner shall apply to the BMSR for the DMLC Part I by completing a Form 143 – DMLC Part I Application Form and sending it to registry@barbadosmaritime.com.
7.9 A new DMLC Part I will be required where there is a change of the vessel’s particulars as recorded on the DMLC Part I or any changes to the exemptions or equivalent arrangements.
7.10 A revised DMLC Part I is not required for a change of ISM Manager or owners.
7.11 The BMSR now issues electronic Declarations of Maritime Labour Compliance Part I (DMLC Part I). A valid DMLC Part I may still be maintained in original hard copy form aboard the vessel. It does not need to be re-issued in electronic form.
DMLC Part II
7.12 The DMLC Part II is developed by the shipowner to address the requirements set out in the DMLC Part I.
7.13 The DMLC Part II shall be signed by the MLC shipowner and by the attending RO surveyor at the initial MLC inspection for the issuance of the full MLC.
7.14 The copy signed by the MLC Shipowner and RO surveyor, together with the MLC, shall be sent to the BMSR.
7.15 A revised DMLC Part II is required where there is a change of MLC Shipowner or a change to the measures to ensure compliance with the provisions of the DMLC Part I.
7.16 The BMSR has its own template for DMLC Part II, Form 140.

8. Equivalency, exemption, or exception

8.1 Any applications for the acceptance of an equivalency, exemption, or exception from MLC 2006 requirements shall be submitted to the BMSR at the time of requesting the DMLC Part I by completing a Form 143 – DMLC Part I Application Form.
8.2 Applications for exemptions relating to structural requirements for vessels (i.e., provisions of Title 3 of MLC 2006) shall be submitted to the BMSR or through an RO.
8.3 The BMSR will assess the application and, where applicable, will issue a certificate of equivalence and/or exemption and will also include these in the DMLC Part I.
8.4 If, after to the issuance of the DMLC Part I, the MLC Shipowner requires consideration of an equivalency or exemption, a new application for DMLC Part I will be required and, if the application is granted, an amended DMLC Part I, DMLC Part II and inspection for an MLC will be required.
8.5 If, after to the issuance of the MLC, the MLC shipowner requires consideration of an exception, an application should be submitted and if the application is granted, an amended DMLC Part II and inspection for an MLC will be required.
8.6 Any equivalency, exemption or exception will require a re-assessment if there are any changes to the issuing conditions or change of shipowner/manager.
8.7 Where the application for an equivalency, exemption or exception is deemed to be related to a Barbados interpretation of MLC 2006 provisions (e.g., format of record keeping, determination of seafarer), the BMSR may issue a “Statement of Interpretation” to supplement the DMLC and MLC.

9. Vessel and seafarers that do not have to comply with the requirements of MLC 2006

9.1 The following type of vessels do not require to comply with MLC 2006:
.1 Vessels that are trading and/or operating exclusively between ports and facilities within Barbados’ waters;
.2 Offshore units whose primary service is in operations for the exploration, exploitation or production of resources on or beneath the seabed and are not ordinarily engaged in navigation or international voyages (e.g., MODUs, drill ships, jack-up platforms, accommodation platforms, Floating Production, Storage and Offloading units (FPSO), purpose built or permanently converted Floating Storage and Offloading/Floating Storage Units (FSO, FSU, FSRU, etc.);
.3 Objects under tow;
.4 Non-propelled barges;
.5 Charter (commercial) yachts of less than 24 meters in length;
.6 Private (non-commercial) yachts of any size.
9.2 A seafarer is a person engaged or employed onboard for the purpose of MLC 2006.
9.3 However, for the definition of seafarer other factors that are taken into consideration are:
.1 if the nature of work is not part of the routine business of the vessel;
.2 although trained and qualified in maritime skills, the persons concerned perform key specialist functions that are not part of the routine business of the vessel;
.3 the work the person performs is occasional and short term, with the principal place of employment being onshore; and
.4 all Seafarer Employment Agreements (SEA), or Collective Bargaining Agreements (CBA) forming part thereof, or Contracts of Employment, comply with MLC 2006.
9.4 Considering Sec. 9.3 above, the BMSR does NOT consider the following group of persons as seafarers:
.1 Port workers, including travelling stevedores;
.2 Pilots and port officials;
.3 Ship surveyors and auditors;
.4 Equipment repair/service technicians and riding crew whose principal place of employment is onshore;
.5 Guest entertainers who work occasionally and short term on board with their principal place of employment being onshore;
.6 Shipowner’s shore-based personnel;
.7 Chief storekeeper;
.8 Vessel HSE Officer; and
.9 Riding crew.
9.5 If the MLC Shipowner deems that there is any other category of persons who should not be considered seafarers for the purpose of MLC 2006, an application containing the following should be submitted to ops@barbadosmaritime.com.
.1 The category or capacity of the persons;
.2 The duration of the stay on board of the persons concerned;
.3 The frequency of periods of work spent on board;
.4 The location of the person’s principal place of work;
.5 The purpose of the person’s work on board;
.6 Who is responsible for the labour and social conditions for the persons;
.7 Whether an agreement is in place for the persons and if the shipowner has assessed it to ascertain if it is comparable with MLC 2006.
9.6 If the BMSR assesses a group of persons to not be a seafarer for compliance either fully or in part with the MLC 2006 requirements, BMSR will issue a “Statement of Interpretation” to supplement the DMLC and MLC.
9.7 The MLC Shipowner should note that even when a group of persons has been assessed not to be a seafarer or a vessel does not require compliance with the MLC 2006, the following minimum requirements remain applicable:
.1 The authority of the Master, (or Offshore Installation Manager where a Master is not on board) for the overall safety and security of the vessel and compliance with any relevant Barbados requirements;
.2 Minimum age: Persons shall be 16 years or older;
.3 Medical certificate: Persons who hold any STCW certificate shall have a valid medical certificate. For all other person serving onboard, the MLC Shipowner should verify that the affected person(s) is medically fit taking into consideration the shipboard environment;
.4 Training or instructions: Persons working on board shall be duly trained or instructed for their assigned shipboard duties especially those duties that are related to safety, security or environmental protection;
.5 Hours of rest: Persons assigned safety, security or environmental protection shipboard duties, shall comply with the STCW hours of rest requirements;
.6 Medical care: The person shall have access to on board medical care;
.7 Health and safety protection and accident prevention: The onboard occupational health and safety and accident prevention policies should be applicable;
.8 On board complaints: The person should have access to the on board complaints procedures;
.9 Employment period onboard: Persons should not be employed or engaged onboard for periods exceeding 12 months;
i) Repatriation: The MLC Shipowner should verify that there are measures to enable the repatriation of the persons employed or engaged onboard within 12 months of signing the SEA, CBA and/or Contracts of Employment;
ii) Wages: shall be paid for their work regularly and in full in accordance with their SEA, CBA and/or Contract of Employment.
9.8 All persons employed on board vessels shall receive safety familiarisation training and/or instruction prior to being assigned shipboard safety, security or environmental duties.

10. Regulation 2.1 - Seafarers' employment agreements

10.1 The duration of the seafarer’s contract of employment should not be confused with the protection of the rights to repatriation and annual leave.
10.2 There is no restriction on the length of a Seafarer’s Employment Agreement (SEA) under MLC 2006. Seafarers may enter into SEAs covering periods longer than 11 months.
10.3 MLC 2006 Standard A2.1, paragraph 4(g)(i) expressly allows SEAs for an indefinite period.
10.4 Should there be a restriction on the term of an SEA in an applicable collective bargaining agreement, such a restriction shall also be applicable to the SEA for service onboard a Barbadian vessel, provided the restriction is not in conflict with MLC 2006 regulations. However, without such a restriction, the seafarer’s ability to extend their contract beyond its expiration date or 12 months, if so desired, would not be limited, subject to mutual agreement between the seafarer and the shipowner.
10.5 Regardless of contract length, all SEAs must provide for annual leave and repatriation in accordance with MLC 2006 Standards A2.4 and A2.5, respectively.
10.6 A fixed expiry date for the length of the contract need not be indicated on a SEA (containing a start date) when a valid Collective Bargaining Agreement (CBA) with a set period (e.g., 6 months ± 1 month) of contract duration is attached. See Sec. 12 below.

11. Minimum age

11.1 No person below the minimum age of 16 years shall be employed, engaged or work on a Barbados registered vessel.
11.2 No person below the minimum age of 18 years shall be employed, engaged or work on a Barbados registered vessel in the following capacities:
.1 Master;
.2 Chief Mate;
.3 Chief Engineer;
.4 Officer In charge of a Navigational and an Engineering Watch;
.5 Electro-Technical Officer;
.6 GMDSS Radio Operator;
.7 Offshore Installation Manager;
.8 Ballast Control Operator;
.9 Barge or Maintenance Supervisor;
.10 Ship Cook.
11.3 No seafarer under the age of 18 shall work at night. For the purpose of these requirements, ‘night’ means a period of at least nine (9) hours starting no later than midnight vessel’s time and ending no earlier than 05:00 vessel’s time.
11.4 The requirement for night work may be waived where:
.1 the seafarer is engaged in a training programme that has been established by the MLC Shipowner. The training program and schedule of night time work should be documented in the Safety Management System; or
.2 the specific nature of the duty or training programme, as recognised by the BMSR, requires the performance of duties at night. The Company shall undertake a shipboard assessment which should determine that the work will not be detrimental to the health and wellbeing of the person under 18, taking into consideration the hazards outlined in the section below.
11.5 No person under the age of 18 shall be employed or engaged or work on board a vessel where the work is likely to jeopardise their health or safety. The Company shall ensure that the Shipboard Occupational Health and Safety Plan (SOHSP) specifically addresses seafarers under the age of 18, including any work or activity deemed hazardous and restrictions or training requirements for such work or activity.

12. Regulation 2.4 - Entitlement to leave

12.1 Annual leave with pay is to be calculated based on a minimum of 2.5 days per completed calendar month of employment.
12.2 MLC 2006 Standard A2.4.3 prohibits any agreement to forgo the minimum annual leave with pay, except in cases provided for by the Competent Authority. The Competent Authority in this case is the flag State.
12.3 The BMSR strictly prohibits a forfeiture of paid annual leave but does allow paid annual leave to be accumulated and taken as mutually agreed by the seafarer and shipowner as detailed in the SEA, provided the requirements for accumulating paid leave and the right of repatriation are continued and met.

13. Regulation 2.5 - Repatriation

13.1 MLC 2006 Standard A2.5.1.2(b) states that the maximum duration of service periods on board following which a seafarer is entitled to repatriation is to be less than 12 months.
13.2 The BMSR’s interpretation of Standard A2.5 is that repatriation is an absolute right and deems MLC 2006 “Guideline B2.5 – Repatriation” mandatory for ensuring the repatriation of a seafarer.

14. Collective Bargaining Agreements

14.1 As defined by MLC 2006 Article II 1.(g), a SEA includes both a contract of employment and articles of agreement.
14.2 In accordance with MLC 2006 Regulation 2.1 paragraph 3:
.1 To the extent not prohibited by the laws, regulations, and practices of the BMSR, seafarers’ employment agreements shall be understood to incorporate any applicable collective bargaining agreement. Clear information, including any labour contract, shall be made available to the crew on board every vessel as to the conditions of employment thereon.
14.3 The BMSR allows the provisions of a CBA to govern the specific conditions of employment, provided they are not in conflict with the MLC 2006 regulations.

15. MLC On-board Complaints Procedure

15.1 All seafarers shall be provided with a copy of the onboard complaint procedures applicable on the vessel. This shall include the following information:
.1 The seafarer’s right to representation;
.2 Safeguards against victimisation of the seafarer;
.3 Contact information of the BMSR or the competent labour authority in the seafarers' country of residence; and
.4 Name of a person or persons on board the vessel who can, on a confidential basis, provide seafarers with impartial advice on their complaint and otherwise assist them in following the complaint procedures available to them on board the vessel.
15.2 The MLC Shipowner and the Master are responsible to ensure that victimisation of a seafarer for filing a labour grievance under the MLC 2006 does not occur. Any claims of victimisation should be investigated by the master or shipowner and where instances of victimisation are found to occur, these must be dealt with under the Company's disciplinary procedures in the shortest possible time.
15.3 All complaints will be treated by BMSR in confidence and will be given serious consideration. It is however essential that the person making any complaint is identified to BMSR. BMSR will not reveal the source of its information when investigating but will not deal with any anonymous complaints.
15.4 If it is appropriate, a BMSR inspector will visit the vessel to investigate the complaint. The BMSR might also request an additional MLC inspection to be carried out by an RO surveyor to investigate the complaint and check compliance with the MLC 2006.
15.5 The complaint should be addressed to the head of the department of the seafarer lodging the complaint or to the seafarer’s supervising officer, who should attempt to resolve the matter within the prescribed time limits appropriate to the seriousness of the issues involved. The MLC Shipowner should have time limits outlined in the shipboard management system and this should take into consideration the time frame noted in Sec. 15.8 below.
15.6 If the head of department or supervising officer cannot resolve the complaint to the satisfaction of the seafarer, the seafarer may refer it to the master, who should handle the matter personally.
15.7 If a complaint cannot be resolved on board, the matter should be referred ashore to the MLC Shipowner, who should be given an appropriate time limit for resolving the matter, where appropriate, in consultation with the seafarer concerned or any person who the seafarer may appoint as their representative.
15.8 If, after twenty (20) days, conciliated settlement cannot be reached, either party shall have a further 20 days to refer the complaint to the competent labour authority, to decide upon a satisfactory solution to the matter.
15.9 If the seafarer lodges the complaint to an external authority rather than the BMSR, that authority shall be provided with the contact information of the BMSR and requested to communicate the complaint to the BMSR. Any investigation or action by an external authority should take into account the extent to which the on-board complaint procedure has been utilised, and its effectiveness in dealing with the complaint.
If the seafarer is in any doubt about presenting a complaint and considers that they will be victimised due to presenting a complaint, they shall have the right to contact the BMSR for guidance or they may submit the complaint directly to the BMSR at any time.

16. Electronic SEA and CBA, and digital signature

16.1 The BMSR has no objection for use of electronic documents (SEA and CBA) and digital signature, provided that both parties are content to accept an electronic them and with the principle that the seafarer must have time to read and take advice on the SEA before, and that both sides must have agreed it, boarding the vessel applies in all cases. As there are no specific guidelines from either IMO or ILO, the BMSR has outlined the below based on the same principles of The International Safety Management Code (ISM Code).
16.2 FAL.5/Circ.39/Rev.2 and Corr. 1.
16.3 Signatures on SEA :
.1 Every SEA must be signed by all contracting parties
.2 All contracting parties shall have a fully signed authentic copy for their perusal, which therefore is deemed to be original, and all parties must constantly be in possession thereof.
.3 The relationship between the parties involved must provide for the definite legal link between the Seafarer and the Shipowner(s), based upon evidence for any involved lawful authorisation (e.g., representation, acting as agents, subcontractors etc.
.4 The use of digital signatures and electronic documents is deemed to meet the authenticity requirements and therefore permitted, under the following conditions:
i) Security: There are appropriate security measures for digital signatures in place, which require the use of a certificate issued by a Qualified Trust Services Provider to establish the identity of the signer;
ii) Procedure: The procedure for use of digital signatures and electronic documents shall be outlined in the company management system(s) as per ISM Code Chapter 11;
iii) Authenticity: Each digital signature shall be unique to one individual and shall not be reused by, or reassigned to, anyone else.
iv) Traceability: Any alteration of electronic documents and any application of any digital signature shall be traceable in terms of its extent and origination;
v) Reference: Reference shall be made that the document has been digitally signed by (or for/on behalf of) the Shipowner(s) and or Seafarer(s) etc;
vi) Identification: Each electronic document shall have a unique tracking number (string of numbers, letters or symbols) ;
vii) Verification: Instructions for allowing third parties (PSCO/MLC inspectors ) to verify the information contained in the electronic documents and the authenticity of digital signatures and shall be available on board the vessel. This means a reliable, secure and continuously available process to confirm the authenticity and validity of an electronic documents using the unique tracking number and other data contained on or embedded in the electronic documents such as digital signature.

Revision History

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

1. References

• • a) International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS);
  • b) International Convention on Load Lines, 1966, as modified by the Protocol of 1988 (LLC);
  • c) International Convention for the Prevention of Pollution from Ships, as amended (MARPOL);
  • d) International Convention for the Control and Management of Ships' ballast water and Sediments (BWMC);
  • e) IMO Circular SLS.14/Circ.1151 “Issue of Exemption Certificates under the 1974 SOLAS Convention and Amendments thereto”

Purpose

• • • 2.1 This Bulletin explains the process for applying for:
  • •      .1 Temporary and Permanent Exemption from an IMO Convention or National requirement;
  • •      .2 Extension of statutory survey period or validity of a certificate issued under an international convention; or
  • •      3. Postponement of a survey, servicing period or any other applicable national or international requirement; or
  • •      4. Equivalent arrangement to an IMO convention requirement.
  • •      5. Where the vessel does not correspond with the particulars of the affected certificate owing to failure of equipment, damage, etc.;
  • •      6. Where detainable deficiencies are identified and cannot be permanently repaired or rectified immediately.

• 3. Application

• 3.1 This Bulletin applies to all Barbadian vessels.

4. Introduction

• • 4.1 As per SLS.14/Circ.115 the BMSR concurs that in various SOLAS regulations the words "exemptions", "relaxations”, “dispensations”, and "waivers" are used with apparently no intended difference in their meaning.
  • 4.2 A Permit is a temporary release from a statutory requirement for a limited time period where a vessel is, temporarily, unable to comply with statutory provisions and are generally limited to the minimum period of time necessary for the vessel to reach a port where rectification of the deficiency can be accomplished. This includes extension and/or postponement of statutory surveys, audits, verifications, and inspections.
  • 4.3 An Exemption is a permanent release from compliance with a statutory convention requirement, due to the existence of specific circumstances as sanctioned by the provisions of that Convention.
  • 4.4 An Equivalence is a permanent arrangement which provides the same general level of safety or intent of a Convention requirement without meeting all criteria for full compliance. Such arrangements can be accomplished, either independently or in combination with, alternative equipment, additional procedures/precautions, operational restrictions, etc.

5. Application for a Permit, Exemption and Equivalence

• • 5.1 Barbados Recognised Organisations (ROs) are not authorised to issue a Permit, Permanent Exemption or Equivalence without the agreement of the BMSR.
  • 5.2 Applications are to be submitted to the BMSR directly or via the RO that has issued the relevant Statutory certificate. The application should include, but not be limited to, the following:
    
    • •      .1 Reason and justification;
    • •      .2 Temporary measures in place;
    • •      .3 Corrective action plan to rectify the deficiency
    • •      .4 Supporting documentation.
    • • 5.3 When the application is submitted though the RO , the RO shall review the application and provide the BMSR with:
    • •      .1 Provisions contained in any applicable IMO convention, code, or IMO circulars;
    • •      .2 Provisions contained in Barbados national regulations.
    • •      .3 Recommendations and justifications

6. Application for a Permanent Exemption and Equivalence

6.1 Barbados Recognised Organisations (ROs) are not authorised to issue a permanent exemption or equivalence without the agreement of the BMSR.
6.2 Applications are to be submitted to the RO that has issued the relevant Statutory certificate.
6.3 Then the RO shall review the application and provide the BMSR with:
.1 The rule under the which the exemption can be granted;
.2 The rule from which the exemption is sought;
.3 Conditions/mitigating measures.

7. BMSR Documents of Approval

• 7.1 Approval of an application for Permit, Permanent Exemption or Equivalence is officially granted
  by the BMSR with the issuance of one of the below documents:
       .1 Single Voyage Permit;
       .2 Temporary Permission;
       .3 SOLAS Exemption Certificate;
       .4 Load Line Exemption Certificate;
       .5 Permanent Exemption;
       .6 Permanent Equivalence;
• 7.2 The Temporary Permission and Single Voyage Permit are both a permit as defined in section 4.2 above.
• 7.3 A Temporary Permission, unless otherwise stated in a convention or code, is generally issued for a maximum period of three (3) months, but may be re-issued if the defect is not rectified in time. In some circumstances (e.g., if repairs need to be carried out in a dry dock or spare parts are unavailable) a Temporary Permission is issued for longer periods.
• 7.4 A Single Voyage Permit is a permit with validity only for the single voyage.
• 7.5 A Permanent Exemption, SOLAS Exemption Certificate and International Load Line Exemption Certificate are all exemptions, as defined in section 4.3 above, and are linked to, and retained with, its associated statutory certificate.
• 7.6 A SOLAS Exemption Certificate is issued for an exemption from a provision of SOLAS, as listed in Annex of SLS.14/Circ.115, and based on the form provided in SOLAS.
• 7.7 A Load Line Exemption Certificate is issued for an exemption as per Article 6 of the LLC, and based on the form provided in the LLC.
• 7.8 A Permanent Exemption is issued for an exemption from provision of any other IMO convention, such as MARPOL, BWMC etc.
• 7.9 A Permanent Equivalence is issued for an equivalence to any IMO convention.
• 7.10 Exemptions and Equivalences are communicated to the IMO, through the IMO Global Integrated Shipping Information System (GISIS2).
• 7.11 As per SLS.14/Circ.115, when a Permit, an Exemption or an Equivalence is issued, port State authorities should interpret this as meaning that the vessel complies with the provisions of the Convention.
• 7.12 Port State authorities, whenever needed, can check validity of a BMSR Permit, Exemption or Equivalence on the BMSR portal Validate a Document3 or using the barcode on the electronic certificates issued by the BMSR.
• 7.13 For a BMSR Permit, Exemption or Equivalence without a barcode, Port State authorities can contact BMSR by email to ops@barbadosmaritime.com.

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

1. References

a) Hong Kong Convention, Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009.
b) EU SRR, Regulation (EU) No 1257/2013 of the European Parliament and of the Council on ship recycling.
c) EMSA Guidance on inspections of ships by the port States in accordance with Regulation (EU) 1257/2013 on ship recycling.

2. Purpose

2.1 This Bulletin provides instructions on the issue of Statements of Compliance (SoC) on Inventory of Hazardous Materials (IHM) under the Hong Kong Convention and the European Union (EU) EU SRR.

3. Application

3.1 This Bulletin applies to any ship requesting a SoC for IHM or EU SRR.

4. General – IHM

4.1 Both the EU SRR and the Hong Kong Convention require vessels to develop and maintain an IHM and undergo survey and certification to verify that the requirements are met.

4.2 A Barbadian vessel can be issued with a SoC by one of the Barbados Recognised Organisations (RO) after satisfactory initial survey including verification that the IHM Part I meets the relevant requirements.

4.3 The IHM shall be vessel specific and shall identify, as a minimum, the hazardous materials listed in Appendix I of the Hong Kong Convention or Annex I of the EU SRR, as appropriate.

4.4 The IHM shall be properly maintained and updated throughout the vessel’s operational life. It must reflect new installations that contain hazardous materials referred to in Appendix II of the Hong Kong Convention or Annex II of the EU SRR, as appropriate, and relevant changes in the vessel’s structure and equipment, taking into account the exemptions and transitional arrangements applicable to those materials under international law.

5. Hong Kong Convention

5.1 The Hong Kong Convention was adopted in 2009 and will enter into force on 26 June 2025.

5.2 Barbados is not a signatory to the Hong Kong Convention, but Barbados ROs are authorised to survey ships and issue voluntary SoC on behalf of Barbados when requested by the managers.

5.3 Vessels are to be surveyed in accordance with Regulation 10 of the Hong Kong Convention and a SoC may be issued following an initial or renewal survey. The renewal survey shall take place at intervals not exceeding five years.

5.4 The issuance and endorsement of the SoC shall be in accordance with Regulation 11 of the Hong Kong Convention and the SoC shall be based on the format of the International Certificate specified in Appendix 3 of the Hong Kong Convention.

5.5 An additional survey may be conducted at the request of the shipowner to ensure that any change, replacement, or significant repair made to the structure, equipment, systems, fittings, arrangements, and material continues to comply with the Convention requirements.

5.6 A final survey shall be conducted prior to the ship being taken out of service and before the recycling of the ship has started, except for existing vessels for which both an initial survey and a final survey are conducted at the same time.

6. EU SRR

6.1 Article 12 of the EU SRR requires vessels flying the flag of a non-EU Member State, when calling at a port or anchorage of an EU Member State, to have on board a SoC and IHM from 31 December 2020.

6.2 Barbados ROs are authorised to survey ships and issue voluntary SoC on behalf of Barbados when requested by the managers.

6.3 A vessel flying the flag of a third country may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of an EU Member State in the event that it fails to submit to the relevant authorities of that Member State a copy of the Statement of Compliance in accordance with paragraphs 6 and 7 of Article 12 of EU SRR, together with the IHM, as appropriate and on request from those authorities.

6.4 Failure to update the IHM shall not constitute a detainable deficiency, but any inconsistencies in the IHM will be reported to the BMSR by the Member State.

6.5 The EU SRR does not establish a period of validity for the SoC, unless so specified by the flag State. The BMSR requires the validity of SoC of EU SRR to have a five-year validity in line with the IHM of Hong Kong Convention. Therefore initial, renewal and additional surveys, as applicable, will need to be conducted for Barbadian vessels under the EU SRR.

6.6 The SoC shall be in the format specified in Annex 3 of the EMSA Guidance on inspections of ships by the port States.
 

Revision History

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

1. References
a) Barbados Merchant Shipping Act (CAP 296).
b) Maritime Labour Convention 2006 (MLC).
c) Bulletin 035 - Piracy and Armed Robbery.
d) Bulletin 018 - Marine Accident Reporting.
e) FAL.13(42) “Revised guidelines on the prevention of access by stowaways and the allocation of responsibilities to seek the successful resolution of stowaway cases”.

2. Purpose

2.1 This Bulletin provides information on BMSR’s reporting requirements for:
.1 Births and Deaths (Section 4);
.2 Occupational Diseases (Section 5);
.3 Breaches of security and Stowaways (Section 6).
2.2 This Bulletin does not cover reporting of Piracy and Armed Robbery accidents, which are addressed in Bulletin 035.
2.3 This Bulletin does not cover reporting of Marine Accidents, which is addressed in Bulletin 018.

3. Application

3.1 This Bulletin applies to all Barbadian vessels engaged in international voyages.

4. Births and Deaths

4.1 Section 166 of the CAP 296 requires the master of a Barbadian vessel to submit a record of any birth or death onboard the vessel. The Form 94 – Return of Births and Deaths shall be sent to registry@barbadosmaritime.com as soon as it is practicable to do so.
4.2 When recording a death, copies of the following documents shall be provided if and when they become available. All documents must be in English or accompanied by English translations:
i) Relevant extract from the Official Logbook;
ii) Deceased’s passport;
iii) Notice of death / death certificate (certified copy);
iv) Doctor’s report(s)
v) Autopsy / Coroner’s report
vi) Form 95 – Account of Property of Deceased Seaman (where applicable)
4.3 Unavailability of the required documents should not delay reporting.
4.4 Additional documentation may be requested by the BMSR depending on the circumstances of the case.

5. Occupational Diseases

5.1 As per MLC Regulation 4.3 any Occupational Diseases are to be reported with the Form 151 – Report of a Case of Occupational Disease, which is to be sent to ops@barbadosmaritime.com.

6. Breach of Security and Stowaways

6.1 Vessels that suffer, or prevent, a breach of security such as unauthorised access, cyberattack, bomb threat or discovery of suspicious items should report via email to ops@barbadosmaritime.com.
6.2 In the case of stowaway(s), Form 169 – Stowaway Incident Report shall be sent to ops@barbadosmaritime.com as soon as it is practicable to do so.
6.3 For dealing with cases of stowaways the shipowners and masters shall follow the basic principles of FAL.13(42).

Revision History:

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

1. References
a) Barbados Merchant Shipping Act (CAP 296).
b) Barbados S.I 2001 No. 44 - Shipping (Safe Manning, Watchkeeping and Hours of Work) Regulations, 2001.
c) SOLAS, International Convention for the Safety of Life at Sea.
d) IMO Assembly Resolution A.1047(27), Principles of minimum safe manning, adopted 30 November 2011.
e) Maritime Labour Convention 2006 (MLC).
f) The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, (STCW Convention).
g) The Seafarers’ Training, Certification and Watchkeeping Code (STCW Code).
h) The International Ship and Port Facility Security Code (ISPS Code).
i) Form 159 – Table of Shipboard working Arrangements.
j) Form 12 – Application for Safe Manning Document.
k) IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements and formats of records of seafarers’ hours of work or hours of rest.

2. Purpose

2.1 This Bulletin sets out the measures adopted by the Barbados Maritime Ship Registry (BMSR) to ensure Barbadian vessels comply with Barbados CAP 296 Section 211, Barbados S.I 2001 No. 44 , SOLAS Regulation V/14, IMO Assembly Resolution A.1047(27), MLC, STCW Convention Regulation VIII/2 and STCW Code Section A-VIII/2.

2.2 The requirements of this Bulletin are to ensure that Barbadian vessels are sufficiently, effectively, and efficiently manned to provide safety and security of the vessel, safe navigation and operations at sea, safe operations in port, prevention of human injury or loss of life, the avoidance of damage to the marine environment and to property, and to ensure the welfare and health of seafarers through the avoidance of fatigue.

3. Application

3.1 The safe manning requirements of Section 4 and the Barbados shipboard working arrangements requirements of Section 5, apply to all Barbadian vessels.

3.2 The requirements for a Safe Manning Document (SMD) of Section 5 apply to vessels engaged on international voyages and commercial yachts of 500 GT and greater.

3.3 The requirements for a Safe Manning Document (SMD) of Section 5 do not apply to :
.1 Ships of war and troopships.
.2 Cargo ships of less than 500 gross tonnage.
.3 Vessels not propelled by mechanical means.
.4 Wooden ships of primitive build.
.5 Pleasure yachts not engaged in trade.
.6 Fishing vessels.

4. Safe Manning Requirements

4.1 The Company and the Master shall ensure that all persons joining a vessel or unit are immediately given appropriate familiarization training with respect to the vessel for emergency, safety, security and environmental responsibilities in addition to their respective duties and functions.

4.2 The Company and the Master of a vessel shall ensure that watch standards and arrangements as outlined in STCW Convention Chapter VIII are always maintained.

4.3 The Company and the Master shall meet the relevant requirements of MLC 2006 and STCW Convention Chapter VIII with respect to periods of rest and prevention of alcohol abuse for any person assigned or performing designated safety, prevention of pollution and security duties.

4.4 Vessel’s Cook

.1 In all cases where the total manning consists of 10 persons or more, there shall be a dedicated certified cook.

.2 As per MLC A3.2.5, on vessels operating with a prescribed manning of less than 10 the company should have one person designated as the Cook. If the appointed person does not hold a vessel’s cook certificate, then the person is to be trained or instructed in areas including food and personal hygiene as well as handling and storage of food on board vessel.

4.5 Ship Security Officer (SSO)

.1 All persons, onboard vessels to which the International Code for the Security of Ships and Port Facilities (ISPS Code) applies, shall have received security training in accordance with STCW Convention Regulation VI/6. One appropriately trained person shall be designated as the Ship Security Officer (SSO) as required under the ISPS Code.

.2 The SSO may be the Master, or any other person designated by the Company. The designated officer shall meet the training requirements in accordance with the provisions of STCW Regulation VI/5 and shall be directly responsible to the Master (if the SSO is not the Master) and the Company Security Officer (CSO) in compliance with vessel’s SMS.

.3 The Company shall ensure that one of the capacities proposed to be included on the SMD is also able to carry out the duties of the SSO.

4.6 Persons Assigned Electronic and Electrical Duties

.1 A vessel powered by main propulsion machinery of 750 kW propulsion power or more may carry persons who are specifically assigned the specific duties, tasks and responsibilities relating to electrical and electronic tasks. If required to be carried, these persons should be certified as Electro-Technical Officers or Electro-Technical Ratings and satisfy the requirements of STCW Regulations III/6 or III/7 respectively.

.2 The SMD need only include these persons if they are additional to the Engineering Officers and they have been assigned shipboard duties to satisfy the requirements of the maintenance of a safe engineering watch, emergency as specified in the Muster List or operation and maintenance of the vessel’s electrical, electronic and control systems.

4.7 Person Designated for Safety

.1 All vessels shall have a person, who may be the Master, who has responsibility for implementation of and compliance with the vessel’s occupational safety and health policy and programme.

4.8 Manning During Hours of Darkness and Restricted Visibility
.1 Companies shall ensure that the vessels have sufficient trained navigational watch-keeping personnel to ensure that the navigation control room/bridge is manned by at least 2 watch keepers during hours of darkness and conditions of restricted visibility. One of these watch keepers shall be a Deck Officer. 

4.9 Manning Onboard Specific Ship

.1 Vessels with propulsion power of less than 750 kW

i) Vessels with propulsion power of less than 750 kW are not required to have an engineer certificated in accordance with STCW Convention. However, such vessels must have at least one person, other than the Master, who is trained and certified to operate the machinery onboard the vessel. If the training is not in accordance with STCW Convention then the person should have documentary evidence of his training and capability to perform the assigned tasks.

.2 Vessels with Unattended Machinery Space (UMS)

i) The UMS notation assigned by a Classification Society shall be considered when determining whether the machinery space can be unattended.
ii) If the manning of a vessel with propulsion power of more than 3000kW is based on UMS notation, then the vessel shall carry an additional watch-keeping engineer officer if the UMS systems are inoperative for more than seven days. The Company shall notify affected Classification Society and the BMSR of the related equipment failure affecting the UMS notation.

.3 Tankers

i) Companies operating tankers shall ensure that all officers, ratings, and persons involved in cargo operation hold a basic training in accordance with the provisions of STCW requirements relating to the type of tanker on which the person is serving.
ii) Officer shall have the Certificate of Proficiency STCW V/1-1 and V/1-2 endorsed by the BMSR.

.4 Vessels Fitted with ECDIS

i) The Company should ensure that if the vessel is fitted with ECDIS, the Master and navigating officers have appropriate generic and type specific ECDIS training.
ii) The Master shall ensure that all affected officers have documentary evidence ECDIS training prior to be assigned their onboard navigational duties.

4.10 Employment of Additional Seafarers by the Company.

.1 A Company may decide to employ more seafarers than stipulated in the SMD. These seafarers shall be trained to a level appropriate to their duties in addition to having the minimum basic training for emergency, safety, and survival. The statutory certificates will detail the maximum number of persons on board and there must be sufficient accommodation satisfying the MLC 2006 (as amended) standards for that number.

.2 There are a number of capacities that are not identified in STCW and accordingly the SMD may not refer to them. The Company should decide on their qualification or experience in accordance with the objectives of their Safety Management System but if the persons are employed and assigned shipboard safety, security, environmental protection, cargo operations or watch-keeping duties, the person must complete STCW basic training before joining the vessel and receive shipboard familiarization training before being assigned their shipboard tasks/duties.

4.11 Employment of Seafarers for vessel with no SMD requirements

.1 On a vessel that is not required to comply with the SMD requirements, either because not engaged on international voyages or exempted as per Sec. 3.3 above, the seafarers are not required to have STCW qualifications but they shall be trained to a level appropriate to their duties in addition to having the minimum basic training for emergency, safety, and survival.
.2 The Company should decide on their qualification or experience in accordance with the objectives of their Safety Management System but if the persons are employed and assigned shipboard safety, security, environmental protection, cargo operations or watch-keeping duties, the person must complete STCW basic training before joining the vessel and receive shipboard familiarization training before being assigned their shipboard tasks/duties.
.3 The statutory certificates will detail the maximum number of persons on board and there must be sufficient accommodation satisfying the MLC 2006 (as amended) standards for that number.

5. Watchkeeping

5.1 The company responsible for the operation of the vessel shall ensure that all watch standers on board its vessels adhere to the minimum limits of hours of rest in accordance with international regulations.

5.2 For vessels of 3000 GT and above and propulsion power of 3000 KW and above the Master and the chief engineer should not be part of the vessel watches and a three-watch system should be adopted for both the deck and engine watches.

5.3 For vessels of less than 3000 GT and with propulsion power of less than 3000 KW two-watch system may be adopted provided that the requirements for work and rest hours are met.

5.4 For deck watches that are normally limited in numbers, a routine for providing additional assistance without delay shall be established and standby personnel shall be identified and immediately contactable.

5.5 On vessels with periodically unattended machinery spaces (UMS) notation and of less than 2000 KW propulsion power and in case of limited number of cabins and bunks a watch with only the Chief engineer may be adopted during the daytime (0800-2000) provided that the requirements for work and rest hours are met and that additional assistance without delay is established.

5.6 When the engine watch is only with the Chief engineer, the Company shall anticipate the number of hours that the Chief engineer must devote to unscheduled work in case of emergency. As soon as practicable after the normal situation has been restored, the Chief engineer shall have an adequate period of rest.

6. Radio Watchkeeping

6.1 On Barbadian vessels with the GMDSS, all officers with radio duties shall hold a valid BMSR endorsed GMDSS radio operators Certificate of Competency (COC), as per STCW IV/2. Therefore, a Barbadian vessel shall have on board at least two officers to carry out radio duties in their own respective watch, when a 2-watch system is in place.

6.2 In case of a 3-watch system, to ensure a continuous radio watch while at sea, the third watch should either be supported by one of the two officers as per Sec.

6.1 above or manned with a third officer who also holds a BMSR endorsed GMDSS radio operators COC.

6.3 When the officers of Sec. 6.1 above provide support for the third watch their total hours of work and rest are to be maintained at all times.

6.4 The BMSR endorsed GMDSS radio operators COC is to be adequate for the Sea Areas (A1, A2,A3, A4) on which the vessel operates.

7. The Barbados Shipboard Working Arrangements

7.1 In compliance with the Barbados S.I 2001 No. 44 and with IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements, the company shall produce a shipboard working arrangements (SWA) of hours of work and rest for all seafarers on board which includes regular watchkeeping duties and non-watchkeeping duties at sea and in port.

7.2 The SWA shall be based on the BMSR format as per Form 159 – Table of Shipboard Working Arrangements, which is to be signed by the Master and be posted or maintained to be easily accessible and capable of being verified by Barbados Appointed Nautical Inspectors and Port State Control Officers.

7.3 A Copy of the Form 159 – Table of Shipboard Working Arrangements shall be submitted to BMSR in order to verify the vessel is safely manned.

7.4 Records of each seafarers’ daily hours of work or rest shall be maintained on board and with a model format as per Appendix 4 of the IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements.

8. Safe Manning Document - Requirements

8.1 The Company shall make an application for a SMD following an assessment that takes into consideration Sections 8.2, 8.3 and 8.4 of this Bulletin.

8.2 The minimum safe manning of a vessel should be established by taking into account all relevant factors, including the following:

.1 size and type of vessel;

.2 number, size and type of main propulsion units and auxiliaries;

.3 level of vessel automation;

.4 construction and equipment of the vessel;

.5 method of maintenance used;

.6 cargo to be carried;

.7 frequency of port calls, length, and nature of voyages to be undertaken;

.8 trading area(s), waters, and operations in which the vessel is involved;

.9 extent to which training activities are conducted on board;

.10 degree of shoreside support provided to the vessel by the company;

.11 applicable work hour limits and/or rest requirements; and

.12 the provisions of the approved Ship's Security Plan.

8.3 In determining the minimum safe manning of a vessel the following principles should be observed.

.1 The capability to:

i) Maintain safe navigational, port, engineering, and radio watches in accordance with regulation VIII/2 of the STCW Convention, as amended, and also maintain general surveillance of the vessel;
ii) moor and unmoor the vessel safely;
iii) manage the safety functions of the vessel when employed in a stationary or near stationary mode at sea;
iv) perform operations, as appropriate, for the prevention of damage to the marine environment;
v) maintain the safety arrangements and the cleanliness of all accessible spaces to minimize the risk of fire;
vi) provide for medical care on board vessel;
vii) ensure safe carriage of cargo during transit;
viii) inspect and maintain, as appropriate, the structural integrity of the vessel;
ix) operate in accordance with the approved Ship's Security Plan;

.2 The ability to:

i) operate all watertight closing arrangements and maintain them in effective condition, and also deploy a competent damage control party;
ii) operate all onboard firefighting and emergency equipment and life saving appliances, carry out such maintenance of this equipment as is required to be done at sea, and muster and disembark all persons on board;
iii) operate the main propulsion and auxiliary machinery including pollution prevention equipment and maintain them in a safe condition to enable the vessel to overcome the foreseeable perils of the voyage.

8.4 The following onboard functions, when applicable, should also be taken into account:

.1 ongoing training requirements for all personnel, including the operation and use of fire fighting and emergency equipment, life-saving appliances, and watertight closing arrangements;

.2 specialized training requirements for particular types of vessels and in instances where crew members are engaged in shipboard tasks that cross departmental boundaries;

.3 provision of proper food and drinking water;

.4 need to undertake emergency duties and responsibilities; and

.5 need to provide training opportunities for entrant seafarers to allow them to gain the training and experience needed.

9. Safe Manning Document - Temporary Exemption

9.1 In cases of Force Majeure, where the manning level falls below that of the SMD e.g., due to crew illness, unexpected repatriation on compassionate grounds etc., the vessel may as a temporary measure, sail with one person less than that stipulated in the SMD and in exemption of SOLAS V/14 provisions. This does not apply to the capacities of Master and chief engineer.

9.2 In all such cases the Master, in consultation with the chief engineer where the shortage relates to an engineer officer, should ensure that there is a continuity of watches by duly qualified persons without affecting the statutory minimum periods of rest.

9.3 The shortage must be filled at the earliest opportunity and in any case not later than fourteen (14) days or at the next port if the intended voyage is more than fourteen (14) days.

9.4 In circumstances of exceptional necessity, as per MLC Standard A3.2.6, where a Company is unable to achieve the minimum manning due to the lack of a duly certificated Cook, a temporary exemption from the provision of MLC Regulation 3.2.3 may be granted and permitting a non-fully qualified cook to serve in a specified vessel for a specified limited period, until the next convenient port of call or for a period not exceeding 1 month, provided that the person to whom the dispensation is issued is trained or instructed in areas including food and personal hygiene as well as handling and storage of food on board vessel.

9.5 The BMSR must be notified and provided with the following information, which must also be duly recorded in the Official Logbook:

i) Name and IMO Number of the vessel
ii) Capacity and rank of the officer
iii) Reason for exemption
iv) No. of crew onboard, excluding the affected officer
v) The Port of departure and arrival with the shortage
vi) Date of departure and ETD

10. Safe Manning Document – Application

10.1 The Company shall submit of a proposal for minimum safe manning defining the nature of the operation of the vessel, taking into account the requirements of Section 8 of this Bulletin.

10.2 The minimum SMD can be issued with a designation of “Unlimited” or “Limited” trading areas, for those vessels which have operations to a limited geographical area.

10.3 “Limited” trading areas are when:

.1 The voyages do not exceed 24 hours between ports of calls; or

.2 Voyages are within 200 nm from the nearest shore; or

.3 Enclosed areas.

10.4 Enclosed areas, may include, but are not limited to:

.1 Mediterranean Sea, Red Sea, Caspian Sea, Black Sea, Azov Sea, North Sea, Gulf of Aden, Baltic Sea, Persian Gulf;

.2 Caribbean Sea (restricted areas 1, II, and/or III, as defined in CCSS Code);

10.5 A vessel which operates part of the time within a limited areas and part of the time on more extensive voyages may elect to have two (2) SMDs.

10.6 To apply for an SMD the Form 12 – Application for Safe Manning Document shall be used.

10.7 The fields of the SMD application Form are to be completed with accurate information. If an item does not apply to the vessel, “N/A” is to be placed in the space. The application is to be completed and signed by a person appointed by the Company.

10.8 A guideline of the minimum manning levels required by the BMSR for unlimited and limited trading areas is provided in Appendix A of this Bulletin.

10.9 If there are special considerations that may affect manning levels, they should be included on the form at the bottom of the second box where it says “Comments/Special Considerations or vessel configurations that may affect manning.” This could include operations such as coastal or domestic trade, number of cabins and/or bunks on the vessel, the vessel’s intended port schedule, etc.

10.10 In assessing minimum deck manning, the BMSR shall consider the vessel’s dimensions, layout of crew accommodation, and internal communications systems, all of which affect crew capabilities and response reactions, the vessel’s propulsion power, the engine room layout and proximity to boiler rooms, etc.

10.11 In this respect the BMSR may increase the scale of manning from that proposed by the Company. The BMSR will not normally reduce the manning level from that proposed by the Company unless it considers certain references in the SMD application proposed by the Company are unnecessary or inconsistent with standard practices.

11. Safe Manning Document – Validity

11.1 In compliance with the requirements of Annex 5 of the IMO Assembly Resolution A.1047(27) an SMD issued to a vessel shall have a validity of 5 years from the date of issue.

11.2 A new SMD is also required to be issued when:

i) there is a change of vessel’s name; or
ii) there is a change of trading area; or
iii) change of ISM Managers; or
iv) any other changes/alterations to the vessel, its crew, construction, machinery, equipment, operation, maintenance, or management that affects the manning level required to continue safe operations.

12. Port State Control

12.1 The STCW Convention, Regulation I/4, enables port State authorities to verify conditions on any vessel, particularly as to the qualifications and ability of personnel on board. Port State authorities may pay particular attention to the following:

.1 that all seafarers on board who are required to be certificated hold an appropriate Barbados certificate or provide documentary proof that an application for an endorsement has been submitted to the BMSR; and/or

.2 the numbers and certificates of the seafarers serving on board conform to the applicable safe manning requirements of the BMSR.

12.2 In accordance with section A-I/4 of the STCW Code, port State authorities may assess the ability of the seafarers of the vessel to maintain watchkeeping standards as required by the STCW Convention, if there are clear grounds for believing that such standards are not being maintained because of any of the following having occurred:

.1 the vessel has been involved in a collision, grounding, or stranding;

.2 there has been a discharge of substances from the vessel when underway, at anchor or at berth, which is illegal under any international convention;

.3 the vessel has been manoeuvred in an erratic or unsafe manner whereby routing measures adopted by the IMO or safe navigation practices and procedures have not been followed; or

.4 the vessel is otherwise being operated in such a manner as to pose a danger to persons, property, or the environment.

12.3 Regulation 2.7 of the MLC requires vessels to have a sufficient number of seafarers employed on board to ensure that they are operated safely, efficiently, and with due regard to security under all conditions, taking into account concerns about seafarer fatigue and the particular nature and conditions of the voyage. Port State Control (PSC) officers are entitled to verify that this is the case when there are grounds for carrying out a more detailed inspection.

Appendix A

The tables given below are provided for guidance/reference and are samples only, to assist Owners/Managers when making a proposal for minimum safe manning levels.

Deck Department

(1) See Sec. 10.3 
(2) BMSR may request one ONW be added, following review of vessel’s operational area and type of ship.
(3) BMSR will accept alternative manning for ranks II/4 and II/5 as far as the total number is as per table.

Engine Department

(4) See Sec. 10.3
(5) For UMS notation ONLY, BMSR might accept an OICEW in lieu of the Second Engineer III/2.
(6) Manning may be reduced by one at this rank if vessel classed with UMS.
(7) BMSR may request one additional one at this rank.
(8) Tankers of 1000 GT or more shall add one additional Engineering Watch Rating.
(9) BMSR will accept alternative manning for ranks III/4 and III/5 as far as the total number is as per table.
(10) Manning may be reduced by one see Sec. 5.5.
(11) See Sec. 4.9.1.
(12) BMSR might accept an OICEW in lieu of the Chief Engineer III/3.

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

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.

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 reflects 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 must 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 must 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 must 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 must 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 ship 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 ship 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 must 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 must 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 must 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 must be subjected to an internal inspection and hydrostatic test. If one or more cylinders fail, a total of 50% of the onboard cylinders must be tested. If further cylinders fail, all cylinders must be tested. Before the 20-year anniversary and every 10-year anniversary thereafter, all cylinders must be subjected to a hydrostatic test. Flexible hoses must be replaced at the intervals recommended by the manufacturer and not exceeding every 10 years. When cylinders are removed for testing, the cylinders must 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 must 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 must be tested. If further cylinders fail, all cylinders must 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 ships 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 must 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 ship 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 ships make themselves aware of any restrictions that may be applied by the country or region in which the ship is trading.
• 9.11 ISM Managers operating ships 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 ship is operating, the ship 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 must 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 must 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 must 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 have 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, must 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 associate 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 must 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 “NovecTM 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 ships 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 ship, 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.
• 14.4 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 must 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 ship, should be test discharged at five-year intervals as part of a fire drill.
• 14.5 All fire extinguishers, together with propellant cartridges, must 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 must be permanently and clearly marked on the bottles.
• 14.9 The servicing facility performing the hydrostatic tests have 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 ships 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 ship’s officer must 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 must 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 must 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 ship’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 must 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.

Revision History

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

1. References

• • a) Barbados Merchant Shipping Act (CAP 296)

• • b) Convention on Limitation of Liability for Maritime Claims 1976

• • c) Maritime Labour Convention, 2006, as amended (MLC 2006)

• • d) the International Convention on Civil Liability for Oil Pollution Damage, 1992, as amended (1992 Civil Liability Convention);

• • e) the International Convention on Civil Liability for Bunker Oil Pollution Damage, 2001 (2001 Bunkers Convention);

• • f) the Nairobi International Convention on the Removal of Wrecks, 2007 (2007 Nairobi WRC);

• • g) the Athens Convention 2002 concerning the transport of passengers and their luggage by sea, (PAL 2002);

• • h) IMO Circular Letter No. 3464. July 2, 2014

2. Purpose

• • 2.1 The purpose of this Bulletin is to inform of the List of Approved Providers of Insurance for Barbadian vessels and for the following purpose:

• • .1 All ships - P&I Certificate of Entry for general liability;

• • .2 Any ship greater than 1000 Gross Tonnage - Article 7 of 2001 Bunkers Convention;

• • .3 Any ship carrying more than 2000 tons of oil in bulk as cargo- Article 7 of the 1992 Civil Liability Convention;

• • .4 All seafarers on any ship - Repatriation (Reg. 2.5) and Shipowner’s Liability (Reg. 4.2) of the MLC 2006;

• • .5 Any ship in international voyage - Article 4bis of the PAL 2002;

• • .6 Any ship of 300 Gross Tonnage and above - Article 12 of the2007 Nairobi WRC.

• • .7 This bulletin supersedes Bulletin number 338.

3. Removal of Wrecks Certificate (2007 Nairobi WRC)

• • 3.1 The 2007 Nairobi WRC entered into force on 30 Oct 2024.

  • 3.2 Barbadian vessels with Valid Wreck Certificates issued by another member state will be still considered accepted until their expiration date.

  • 3.3 All new Wreck Certificates shall be issued by the BMSR only.

4. BMSR Approval of Insurance Providers

• • 4.1 As per IMO Circular Letter No. 3464, the BMSR accepts all certificates of insurance or blue cards issued by members of the International Group of P&I Associations.

• • 4.2 Insurers wishing to provide insurance services to Barbadian ships must be approved before their certificates will be accepted by the Registry.

• • 4.3 The BMSR will charge for the approval of an insurer with the rate for ‘Assessment and approval of any manual or plan’ as per the BMSR fees, plus the fees for the issuance of the Letter of Approval.

• • 4.4 At a minimum, the following documents should be submitted by email to ops@barbadosmaritime.com for review:

• • .1 A completed PPO03-F01 Providers of Insurance Application Form;

• • .2 Evidence of registration with the appropriate national regulatory authority;

• • .3 3 years of audited accounts;

• • .4 Documentation on reinsurance coverage, if applicable;

• • .5 A guarantee that the insurer can cover the liability under the relevant conventions;

• • .6 A statement that liability incurred under the relevant convention due to an act of terrorism is covered;

• • .7 Sample certificates of insurance or blue cards;

• • .8 Evidence of approval by any other flag states (if applicable);

• • .9 Evidence that the insurer or its reinsurers have been rated by an independent and internationally recognised rating agency.

5. BMSR List of Approved Providers of Insurance

• • 5.1 ACE Insurance

• • 5.2 AIG Europe S. A

• • 5.3 ALANDIA
•  
  • 5.4 Alfastrakhovanie PLC

• • 5.5 American International Group UK Limited

• • 5.6 American Steamship Owners Mutual Protection & Indemnity Association, INC.

• • 5.7 Amlin Europe N.V.

• • 5.8 Amlin Insurance SE

• • 5.9 Amlin Marine N.V.

• • 5.10 ASPEN INSURANCE UK LIMITED

• • 5.11 Assuranceforeningen Gard – Gjensidig

• • 5.12 Assuranceforeningen Gard – Gjensidig – Japan Branch

• • 5.13 Assuranceforeningen Skuld (Gjensidig) Singapore Branch

• • 5.14 Assuranceforeningen Skuld (Gjensidig) UK Branch

• • 5.15 Aurora P&I (Formerly Carina P&I)

• • 5.16 Balance Insurance JSC

• • 5.17 Brit Syndicate 2987

• • 5.18 British Marine

• • 5.19 Catlin Indemnity Company

• • 5.20 China Shipowners Mutual Assurance Association

• • 5.21 EF MARINE PTE LTD. (Singapore) & EF MARINE B.V., Rotterdam.

• • 5.22 Forsakringsaktiebolaget Alandia

• • 5.23 GARD AS

• • 5.24 Gard P. & I. (Bermuda) Ltd

• • 5.25 Gard P. & I. (Bermuda) Ltd., Singapore Branch

• • 5.26 GENERALI OSIGURANJE D.D.

• • 5.27 Great American Insurance Company

• • 5.28 Hanseatic P&I

• • 5.29 Hydor

• • 5.30 Ingosstrakh Insurance Company

• • 5.31 Lingard Limited

• • 5.32 Liverpool and London Steamship Protection and Indemnity Association Limited

• • 5.33 Lloyd’s

• • 5.34 LODESTAR MARINE (issues insurance on behalf Aspen)

• • 5.35 Maritime Mutual Insurance Association (NZ) Limited

• • 5.36 MARKEL International Insurance Company Limited

• • 5.37 Meiji Yasuda General Insurance Company, Limited

• • 5.38 Mitsui Sumitomo Insurance Company, Limited

• • 5.39 MS Amlin Insurance SE

• • 5.40 NAVIGATORS INSURANCE COMPANY

• • 5.41 NIPPONKOA Insurance Company, Limited

• • 5.42 Nissay Dowa General Insurance Company, Limited

• • 5.43 NoordNederlandscheP&IClub

• • 5.44 NorthStandard EU DAC  

• • 5.45 North of England Protecting and Indemnity Associated Limited

• • 5.46 NORWEGIAN HULL CLUB

• • 5.47 PICC Property and Casualty Company Limited Dalian Branch

• • 5.48 QBE EUROPE SA/NV trading as BRITISH MARINE

• • 5.49 QBE Insurance (Singapore) Pte Ltd trading as QBE Asia P&I / British Marine

• • 5.50 QBE UK LIMITED trading as BRITISH MARINE

• • 5.51 RaetsMarine Insurance B.V.

• • 5.52 Raets Marine Insurance B.V. (Formerly InterCostal Shipowners P&I B.V.) 

• • 5.53 Rosgosstrakh Insurance Company

• • 5.54 Royal & Sun Alliance Insurance plc

• • 5.55 SAISON Automobile & Fire Insurance Company, Limited

• • 5.56 Safeguard Guarantee Company Ltd.

• • 5.57 SECOM General Insurance Company, Limited

• • 5.58 Sun Re Limited

• • 5.59 SKULD

• • 5.60 SKULD (Far East) Ltd.
•  
  • 5.61 SOGLASIE Insurance Company Limited

• • 5.62 Sompo Japan Insurance Inc.

• • 5.63 Steamship Mutual Underwriting Association (Europe) Limited

• • 5.64 Steamship Mutual Underwriting Association Limited

• • 5.65 Sveriges Angfartygs Assurans Forening (The Swedish Club)

• • 5.66 SWISS RE INTERNATIONAL SE

• • 5.67 Syndicate 2001

• • 5.68 The Britannia Steam Ship Insurance Association Limited

• • 5.69 The DAIDO Fire and Marine Insurance Company, Limited

• • 5.70 The Japan Ship Owners’ Mutual Protection & Indemnity Association

• • 5.71 Thomas Miller Specialty

• • 5.72 Tokyo Marine & Nichido Fire Insurance Company, Limited

• • 5.73 The Fuji Fire & Marine Insurance Company, Limited

• • 5.74 The Korea Shipowner’s Mutual Protection & Indemnity Association

• • 5.75 The London Steam-Ship Owners’ Mutual Insurance Association Ltd.

• • 5.76 The Nisshin Fire & Marine Insurance Company, Limited

• • 5.77 The North of England Protecting and Indemnity Association Limited

• • 5.78 The Pacific Maritime Club

• • 5.79 The Power Front Ship Owner Mutual Insurance Association (PFMA)

• • 5.80 The Shipowners’ Mutual Protection and Indemnity Association (LUXEMBOURG)

• • 5.81 The Society of Lloyds

• • 5.82 The Standard Club Asia Ltd

• • 5.83 The Standard Club Europe Ltd

• • 5.84 The Standard Club Ireland DAC

• • 5.85 The Standard Club UK Ltd

• • 5.86 The Standard Steamship Owners Protection and Indemnity Association (Europe) Limited

• • 5.87 The Standard Steamship Owners Protection and Indemnity Association (Bermuda) Limited

• • 5.88 The Steamship Mutual Underwriting Association (Bermuda) Limited

• • 5.89 The Steamship Mutual Underwriting Association Limited

• • 5.90 The Sumi-Sei General Insurance Company, Limited

• • 5.91 Türk P ve I Sigorta A.Ş. (Trading as Türk P&I)

• • 5.92 United Kingdom Mutual Steam Ship Assurance Association (Bermuda) Limited

• • 5.93 United Kingdom Mutual Steam Ship Assurance Association (Europe) Limited

• • 5.94 The West of England Ship Owners Mutual Insurance Association (Luxembourg)

• • 5.95 The West of England Ship Owners Mutual Insurance Association (Luxembourg) S. A.
•  
  • 5.96 VSK Insurance Company, Russia

• • 5.97 Water Quality Insurance Syndicat

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

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) Barbados Shipping (Oil Pollution) Act (CAP296A.
c) International Convention for the Prevention of Pollution from Ships (MARPOL).
d) NOX Technical Code 2008 (NTC 2008).
e) MEPC.1/Circ.892 Guidelines for exemption of unmanned non-self-propelled (UNSP) barges from the survey and certification requirements under the MARPOL Convention.
f) Resolution MEPC.340(77) 2021 Guidelines for Exhaust Gas Cleaning System.
g) MEPC.1/Circ.795/Rev.2, Unified Interpretations to MARPOL Annex VI.
h) Resolution MEPC.364(79) 2022 Guidelines on the Method of Calculation of the Attained EEDI for New Ships.
i) Resolution MEPC.333(76) 2021 Guidelines on the Method of Calculation of the Attained (EEXI).
j) Resolution MEPC.324(75) Procedures for sampling and verification of the sulphur content of fuel oil and the Energy Efficiency Design Index (EEDI).
k) Resolution MEPC.320(74) 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.
l) MEPC.1/Circ.881 Guidance for port State control on contingency measures for addressing non-compliant fuel oil;
m) MEPC.1/Circ.864/Rev.1 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships.
n) MEPC.1/Circ.889 2020 Guidelines for on board sampling of fuel oil intended to be used or carried for use on board a ship.
o) MEPC.1/Circ.884/Rev.1 Guidance for best practice for Member State/coastal State.
p) Resolution MEPC.346(78) 2022 Guidelines for the development of a ship energy efficiency management plan (SEEMP).
q) Bulletin 008 – Permits Exemptions and Equivalences.
r) Resolution MEPC.348(78) 2022 Guidelines for Administration verification of ship fuel oil consumption data and operational carbon intensity.
s) MEPC.1-Circ.876 Sample Format for The Confirmation Of Compliance, Early Submission Of The SEEMP Part II etc.
t) Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport, and amending Directive 2009/16/EC.
u) SI 2018/1388 The Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions) (Amendment) (EU Exit) Regulations 2018.
v) MIN 669 (M+F) Amendments 1 - Reporting Emissions Data into the UK MRV Regime.
w) Resolution MEPC.335(76) 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve.
x) Resolution MEPC.375(80) Amendments to the 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve (res. MEPC.335(76)). 

2. Purpose

2.1 This Bulletin outlines the requirements of MARPOL Annex VI, and specifically Chapter 3 requirements for control of emissions and Chapter 4 requirements to reduce the carbon intensity for Barbadian vessels.

2.2 MARPOL Annex VI sets limits on vessel sulphur oxide (SOX) and nitrogen oxide (NOX) emissions. It regulates the deliberate emissions of ozone-depleting substances (ODS), the emissions of volatile organic compounds (VOCs) from tankers, and the incineration of certain products on board vessels. It also establishes fuel oil quality standards.

3. Application

3.1 The MARPOL Annex VI Chapter 3 requirements apply to all Barbadian vessels, regardless of tonnage, except where expressly provided otherwise.

3.2 The MARPOL Annex VI Chapter 4 requirements apply to Barbadian vessels of 400 gross tonnage (GT) and above, except where expressly provided otherwise as detailed in the relevant sections below.

3.3 The MARPOL Annex VI Chapter 4 requirements do not apply to vessels not propelled by mechanical means, platforms including Floating Production, Storage and Offloading Facilities (FPSOs) and Floating Storage Units (FSUs), and drilling rigs regardless of their propulsion and vessels operating in Barbados national waters.

4. Definitions

4.1 For the purposes of the MARPOL Annex VI Chapter 4, the definition of “New ship”, Major conversion MARPOL Annex VI Reg. 2, as per MEPC.1/Circ.795/Rev.2 defines the following terms:

.1 “New ship” means a vessel:

          i) for which the building contract is placed on or after 01 January 2013; or
          ii) in the absence of a building contract, the keel of which is laid, or which is at  a similar stage of construction on or after 01 July 2013; or
          iii) the delivery of which is on or after 01 July 2015.

.2 “Major Conversion” means a conversion of a vessel:

          i) which substantially alters the dimensions, carrying capacity, or engine power of the vessel; or
          ii) which changes the type of the vessel; or
          iii) the intent of which in the opinion of the Administration is substantially to prolong the life of the vessel; or
          iv) which otherwise so alters the vessel that, if it were a new ship, it would become subject to relevant provisions of the present Convention not applicable to                   it as an existing vessel; or
          v) which substantially alters the energy efficiency of the vessel and includes any modifications that could cause the vessel to exceed the applicable required Energy Efficiency Design Index (EEDI) as set out in MARPOL Annex VI Reg.21.

.3 A vessel delivered on or after 01 September 2019 means a vessel:
          i) for which the building contract is placed on or after 01 September 2015; or
          ii) in the absence of a building contract, the keel of which is laid, or which is at a similar stage of construction on or after 01 March 2016; or
          iii) the delivery of which is on or after 01 September 2019.

4.2 For the purposes of MARPOL Annex VI Chapter 4, the categories defined in MARPOL Annex VI Reg.: 2.2.5 Bulk carrier; 2.2.7 Combination carrier; 2.2.9 Container ship; 2.2.11 Cruise passenger ship; 2.2.14 Gas carrier; 2.2.15 General cargo ship; 2.2.16 LNG carrier; 2.2.20 Passenger ship; 2.2.22 Refrigerated cargo carrier; 2.2.26 Ro-Ro cargo ship; 2.2.27 Ro-Ro cargo ship (vehicle carrier); 2.2.28 Ro-Ro passenger ship; 2.2.29 Tanker.

5. Exceptions and Exemptions (MARPOL VI Reg.3)

5.1 MARPOL Annex VI regulations do not apply to emissions necessary for securing the safety of the vessel, saving life at sea, or those resulting from accidents and damage suffered to the vessel or its equipment:

.1 provided that all reasonable precautions have been taken after the occurrence of the damage or discovery of the emission for the purpose of preventing or minimizing the emission; and

.2 except if the Owner or the Master acted either with intent to cause damage, or recklessly and with knowledge that damage would probably result.

5.2 The requirements of MARPOL Annex VI Reg. 18 on fuel oil availability and quality shall not apply to the use of hydrocarbons that are produced and subsequently used on site as fuel and this exemption shall be annotated on the International Air Pollution Prevention Certificate (IAPPC).

5.3 The BMSR may exempt unmanned non-self-propelled (UNSP) barges from the survey and certification requirements of MARPOL Annex VI by means of an International Air Pollution Prevention Exemption Certificate for Unmanned Non-self-propelled (UNSP) Barges for a period not exceeding five years as per MEPC.1/Circ.892.

6. Equivalents (MARPOL VI Reg. 4)

6.1 Requests for equivalencies or alternative arrangements must be submitted to the BMSR at Ops@barbadosmarime.com. As per Bulletin 008, they must include a recommendation from the Recognised Organisation (RO) confirming that the alternative arrangement is at least as effective in terms of emissions reductions as required MARPOL Annex VI.

6.2 Upon satisfactory review of the application, the BMSR will notify the International Maritime Organization (IMO) of the acceptance of the equivalent/alternative compliance by making an entry in the IMO Global Integrated Shipping Information System (GISIS).

7. Surveys and Certification (MARPOL VI Reg. 5 to 9)

7.1 Barbadian vessels of 400 GT and above, engaged on international voyages, and every fixed and floating drilling rig or other platform shall be surveyed and certificated for compliance with the requirements of MARPOL Annex VI Reg. 5.1 and be issued with an IAPPC.

7.2 As per MARPOL Annex VI Reg. 13.1.1, each marine diesel engine with a power output over 130 kilowatt (kW) that is installed (or undergoes major conversion) on a vessel, irrespective of tonnage, must be surveyed and certified in accordance with the NTC 2008.

7.3 Barbadian vessels of 400 gross tonnage and above, to which MARPOL Annex VI Chapter 4 applies, shall undergo surveys in accordance with MARPOL Annex VI Reg. 5.1 and be issued with an International Energy Efficiency Certificate (IEEC).

7.4 Barbadian vessels which are not required to keep a Ship Energy Efficiency Management Plan (SEEMP) do not require an IEEC.

7.5 The ship type on the IEEC shall refer to the ship type in accordance with definitions specified in MARPOL Annex VI Reg. 2.2. which are indicated in Sec. 4.2 above.

7.6 If the vessel does not fall into the ship types defined in Sec. 4.2 above, in the IEEC the ship type shall be entered as “Ship other than ship types defined in in MARPOL Annex VI Reg. 2.2" and “the type of ship is exempt in accordance with MARPOL Annex VI Reg. 22.1/23.1/24.1/25.1” as applicable, shall be ticked in the IEEC relevant section.

7.7 If needed, the BMSR can issue a waiver letter as confirmation by this flag Administration of the ship type and to address Sec. 7.6 above.

7.8 The BMSR considers that the ship type stated on the IEEC should usually replicate the ship type designated at the stage of design and construction on which the Certificate of Class and Statutory Certificates of the vessel are based and with the ship type of the Barbados Certificate of Registry (COR).

7.9 In situations where, owing to operational necessity, an existing vessel may be required to change the ship type on the IEEC, the BMSR will consider such requests, where supported by the RO that issues the IAPPC of the vessel, provided that the ship type on the Certificate of Class, Statutory Certificates and COR of the vessel are amended accordingly.

7.10 The Owners of a vessel certificated to the ISM Code should be aware that where a change of ship type is requested, the vessel’s Safety Management Certificate (SMC) and the Company Document of Compliance (DOC), including associated safety management documents and procedures, may require to be amended.

8. MARPOL VI – RO’s Degree of Authorisation

8.1 The BMSR has authorised all Barbados ROs to:

.1 Issue or endorse an IAPPC;

.2 Issue or endorse an Engine International Air Pollution Prevention (EIAPP) certificate;

.3 Verify VOC management plans (Sec. 12.2 below);

.4 Carry-out Type Approval of shipboard incinerators (Sec. 13 below);

.5 Approve SOX Emissions Compliance Plans and issue a SOx Emission Compliance Certificate to vessels which use an Exhaust Gas Cleaning Systems (EGCSs) as an approved equivalent;

.6 Verify attained EEDI values calculated for each vessel (Sec. 14 below);

.7 Verify attained EEXI values calculated for each vessel (Sec. 16 below);

.8 Issue an IEEC after completion of the relevant surveys referred to in Sec. 7 above. The IEEC is to remain valid for the life of the vessel, except for the cases specified under MARPOL Annex VI Reg. 9.11 (vessel withdrawn from service, major conversion, or upon transfer of the vessel to the flag of another State).

.9 Verify the Ship Energy Efficiency Management Plan (SEEMP) Part II (Ship Fuel Oil Consumption Data Collection Plan) and issue Confirmation of Compliance (Sec.17.6 below );

.10 Verify Ship Fuel Oil Consumption Data Collection from each vessel operator, per vessel and issue an Annual Statement of Compliance (SoC) (Sec. 18 below);

.11 Submit data to the IMO Ship Fuel Oil Consumption Database.

9. Ozone-Depleting Substances (MARPOL VI Reg. 12)

9.1 Deliberate emissions of ozone-depleting substances (ODS) are prohibited and all vessels with installations containing ODS must comply with MARPOL Annex VI Reg. 12, except for permanently sealed equipment where there are no refrigerant charging connections or potentially removable components that contain ODS.

9.2 The ODS Record Book is required for the vessel of 400 GT and above, and drill rigs and platforms regardless of tonnage, which have rechargeable systems containing ozone-depleting substances. The BMRS ODS Record Book can be ordered on Shipboard Document Online Form.

10. Nitrogen Oxide (NOX) Emissions (MARPOL VI Reg. 13)

10.1 It is prohibited to operate a marine diesel engine with a power output of more than 130 kW, and which is installed, or undergoes a major conversion on or after 01 January 2000, unless it complies with the applicable NOX emission limits and requirements specified in MARPOL Annex VI Reg. 13, which applies to any vessels (including yachts and fishing vessels) irrespective of tonnage.

10.2 Marine diesel engines installed on a vessel must comply, based on the date of vessel construction, with the NOx Tier III emission standards when the vessel is operating in an Emission Control Area (ECA) as specified in MARPOL Annex VI Reg. 13.5.1.2.

10.3 Emergency diesel engines and engines installed in lifeboats, devices, or equipment intended to be used solely for emergencies are exempted from the MARPOL Annex VI Reg. 13 requirements.

10.4 Emissions from fixed or floating platforms and drilling rig engines that are solely dedicated to the exploration, exploitation and associated offshore processing of seabed mineral resources are exempted from the regulations regarding NOx controls. However, any emissions from engines that jointly supply power to exploration and processing machinery and also the platform domestic load are NOT exempted.

10.5 Each engine on board a Barbados vessel subject to MARPOL Annex VI is required to have an associated Engine Technical File. The Technical file shall remain on board the vessel for as long as the engine remains on board and shall be available for inspection by duly authorised officers.

10.6 The Technical File shall include an on-board NOx verification procedure, the parent engine’s emission test report and the Engine International Air Pollution Prevention Certificate (EIAPPC).

10.7 Boilers and gas turbines are not covered under the NOx controls regulations.

11. Sulphur Oxides (SOX) and particulate matter (MARPOL VI Reg. 14)

11.1 The carriage of fuel oil for use on board the vessel with a sulphur content exceeding 0.50% m/m is prohibited under MARPOL Annex VI Reg. 14.1. This prohibition does not apply to non-compliant fuel oil carried for use onboard a vessel with an approved EGCS installed as an alternative means of compliance and to fuel oil carried on board as a cargo.

11.2 The global sulphur limit is a mandatory requirement and is applicable to all vessels on all voyages, covering all fuel carried on board for consumption – this includes fuel oil used in emergency systems (emergency generator, lifeboats, rescue boat, etc.), and concerns about the safety of the vessel and machinery do not exempt the vessel from the requirement to bunker and/or consume compliant fuel oil.

11.3 In ports where the discharge of wash water from open loop EGCS (scrubbers) is not permitted, vessels fitted with open loop/hybrid EGCS may be expected to consume compliant fuel oil or to switch to closed loop mode. Documents related to changeover procedure and records should be kept on board.

11.4 IMO Resolution MEPC.340(77) requires the EGCS Technical Manual (ETM) and Onboard Monitoring Manual (OMM) to be approved by the RO on behalf of Barbados.

11.5 While a vessel is operating within an Sulphur Emission Control Area (SECA) as defined under MARPOL Annex VI Reg. 14.3, the sulphur content of fuel oil used on board that vessel shall not exceed 0.10% m/m as per MARPOL Annex VI Reg. 14.4.

11.6 Vessels using separate fuel oils when operating within a SECA must carry a written fuel oil changeover procedure, developed specifically for the vessel. A record of the changeover operation shall be recorded in the MARPOL Annex VI Record Book.

11.7 The BMSR MARPOL Annex VI Record Book can be ordered on Shipboard Document Online Form.

12. Volatile Organic Compounds (MARPOL VI Reg. 15)

12.1 Tankers subject to vapour emissions control must be fitted with a vapour collection system approved by an RO on behalf of Barbados, within three years after a port/terminal has notified the IMO of its regulation of tanker VOC emissions. See GISIS module for ports or terminals where VOCs are controlled.

12.2 The VOC management plan, required for all tankers carrying crude oil, must be approved by an RO on behalf of Barbados.

12.3 Gas carriers must comply with the requirements of this section only if their loading and containment systems allow safe retention of non-methane VOCs on board, or their safe return ashore.

13. Shipboard Incineration (MARPOL VI Reg. 16)

13.1 All vessels, irrespective of tonnage, must comply with the regulations on shipboard incineration under MARPOL Annex VI Reg. 16. Special rules on incineration under domestic law may apply in some ports and may exist in some special areas. Operation of shipboard incinerators may require permission from individual coastal or port authorities concerned.

13.2 Incinerators installed in accordance with the requirements of MARPOL Annex VI Reg. 16 shall be provided with a manufacturer’s operating manual and personnel responsible for the operation of an incinerator shall be trained to implement the guidance provided in the manufacturer’s operating manual.

13.3 An incinerator on a vessel constructed on or after 01 January 2000, or installed on or after 01 January 2000 must be approved by an RO on behalf of Barbados, taking into account the standard specification for shipboard incinerators as per MARPOL Annex VI Reg. 16.3 and 16.6.1.

14. Fuel Oil Quality - BDN and FONAR (MARPOL VI Reg. 18)

14.1 For every vessel of 400 GT and above, details of fuel delivered for combustion purposes must be documented by means of a Bunker Delivery Note (BDN) in the format specified under Appendix V of MARPOL Annex VI.

14.2 BDNs shall be kept on board for at least 3 years after the delivery of the fuel oil and shall be accompanied by a representative sample (“MARPOL delivered sample”) which is to be sealed and signed by the Master or officer in charge of the bunker operations and retained under the vessel’s control until the fuel oil is substantially consumed, but in any case, not less than 12 months from the time of delivery. Representative samples of fuel already consumed may be retained in an appropriate shore side facility under control of the Company.

14.3 Coastal and port State authorities of a Party to MARPOL Annex VI, as appropriate, may utilise the sampling point(s) which is(are) fitted or designated for the purpose of taking representative sample(s) of the fuel oil being used on board as outlined in IMO Circulars MEPC.1/Circ.864/Rev.1, MEPC.1/Circ.889 and Resolution MEPC.324(75). The competent authority shall take fuel oil samples as expeditiously as possible without causing the vessel undue delays, and the sample must be sealed by the representative of the competent authority in the presence of the vessel's representative and the vessel shall retain a duplicate sample.

14.4 For every vessel of 400 GT and above on scheduled services with frequent and regular port calls which would render compliance with the requirements of this section impracticable, an alternative documentation and sampling storage plan may be approved by the BMSR, after consideration of the circumstances involved and consultation with the affected States concerned.

14.5 Where, despite all reasonable efforts, compliant fuel oil is not received at the scheduled port of call, and no feasible alternative exists, the vessel will be required to prepare and submit a Fuel Oil Non-Availability Report (FONAR) as per Sec. 5 of Resolution MEPC.320(74), which shall be submitted to both the BMSR and the Coastal State authorities of the port(s) of destination.

14.6 When a vessel has presented evidence of the non-availability of compliant fuel oil, the BMSR will subsequently notify the IMO through “MARPOL Annex VI” GISIS module. The following information shall be provided to the BMSR:

.1 a record of actions taken to attempt to achieve compliance;

.2 copies of Bunker Delivery Note(s);

.3 post-bunkering laboratory analysis of drip samples taken to determine the percent concentration of sulphur found within the stemmed fuel oil; and

.4 evidence that the vessel attempted to purchase compliant fuel oil in accordance with its voyage plan and, if it was not made available where planned, that attempts were made to locate alternative sources for such fuel oil and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase.

14.7 Providing the information above does not indemnify the vessel from Port State Control (PSC) action in the event compliant fuel oil could not be obtained. The relevant authorities of a Party to MARPOL Annex VI will consider all relevant circumstances in addition to the evidence provided when determining the appropriate action to take based on the guidance for Port State Control on how to address the provision of non-compliant fuel oil , as per IMO Circular MEPC.1/Circ.881.

14.8 Follow-up actions may be considered when arranging the supply of compliant fuel oil following bunkering of non-compliant fuel oil under a FONAR:

.1 De-bunker any remaining non-compliant fuel oil at the first port where compliant fuel is available; and

.2 Specific preparations to ensure bunker tanks and fuel transfer, treatment and preparation systems are sufficiently cleaned and are suitable for compliant fuel oil without the risk of contamination by residues of non-compliant fuel oil. Such actions may include tank cleaning, system pipelines and equipment flushing or mechanical cleaning.

15. Attained EEDI and Required EEDI (MARPOL VI Reg. 22 and 24)

15.1 Energy Efficiency Design Index (EEDI) represents the equivalent amount of carbon dioxide that a vessel as a whole emits, in relation to the amount of cargo carried per mile sailed.

15.2 The attained EEDI is defined under MARPOL Annex VI Reg. 2.2.3 as the EEDI value achieved by an individual vessel in accordance with MARPOL Annex VI Reg. 22. The attained EEDI should be lower than the required EEDI prescribed in MARPOL Annex VI Reg. 24, which is the maximum value of attained EEDI allowed for the specific vessel type and size.

15.3 The attained EEDI and required EEDI are applicable for a “new ship” as defined in Sec. 4.1.1 above or an existing one which has undergone a major conversion so extensive that it is regarded as newly constructed, which falls into one or more of the categories defined in Sec. 4.2 above.

15.4 The attained EEDI shall be calculated taking into account Resolution MEPC.364(79) and verified by a Barbados RO. The attained EEDI shall be specific to each vessel and shall indicate the estimated performance of the vessel in terms of energy efficiency and be accompanied by the EEDI Technical File that contains the information necessary for the calculation of the attained EEDI and shows the process of calculation. When a vessel may be identified as falling under more than one category listed above, the more stringent criteria in calculations shall apply.

15.5 Starting from 01 April 2022 for all vessels to which requirements of MARPOL Annex VI Reg. 22and 24 apply, the attained EEDI and required EEDI shall be reported to the IMO as follows:

.1 For vessels constructed on or after 1 April 2022 within 7 months from the date if the IEEC Initial Survey; or

.2 for vessels constructed prior to 1 April 2022 by 1 November 2022.

16. Attained EEXI and Required EEXI (MARPOL VI Reg. 23 and 25)

16.1 Energy Efficiency Existing Ship Index (EEXI) is a measure of a vessel’s energy efficiency, expressed in grams of carbon dioxide per amount of cargo carried per mile sailed.

16.2 The attained EEXI shall be calculated as per MARPOL Annex VI Reg. 23. taking into account Resolution MEPC.333(76) and verified by a Barbados RO. The Required EEXI is the maximum value of attained EEXI allowed for the specific vessel type and size and is calculated as per MARPOL Annex VI Reg. 25.

16.3 The attained EEXI and required EEXI are applicable for each existing vessel and each vessel which has undergone a conversion, which fall into one or more of the categories defined in Sec. 4.2 above.

16.4 Where a vessel may be identified as falling under more than one category listed above, the more stringent criteria in calculations shall apply. The process of calculation and the necessary information to produce the EEXI calculation shall be addressed in the vessel specific EEXI Technical File.

16.5 Notwithstanding Sec. 16.2, for each vessel to which MARPOL Annex VI Reg.22 applies, the attained EEDI may be taken as the attained EEXI if the value of the attained EEDI is equal to or less than that of the required EEXI as required by MARPOL Annex VI Reg. 25. In this case, the attained EEXI shall be verified based on the EEDI Technical File and the provisions contained within the EEDI Technical File may be used in place of an EEXI Technical File.

16.6 The EEXI Technical File shall be reviewed and accepted by the Verifier. The Verifier may issue a statement affirming the completion of an EEXI Technical File review; however, such a statement does not form part of the survey requirements of MARPOL Annex VI Reg. 22.

17. Shaft / Engine Power Limitation Systems and use of Reserve of Power
17.1 As per Resolution MEPC.335(76) the following definitions are to be used:

.1 Shaft power means the mechanical power transmitted by the propeller shaft to the propeller hub. It is the product of the shaft torque and the shaft rotational speed. In case of multiple propeller shafts, the shaft power means the sum of the power transmitted to all propeller shafts.

.2 Engine power means the mechanical power transmitted from the engine to the propeller shaft. In case of multiple engines, the engine power means the sum of the power transmitted from the engines to the propeller shafts.

.3 Overridable Shaft Power Limitation (SHaPoLi) system means a verified and approved system for the limitation of the maximum shaft power by technical means that can only be overridden by the vessel's Master or the officer in charge of navigational watch (OICNW) for the purpose of securing the safety of a vessel or saving life at sea.

.4 Overridable Engine Power Limitation (EPL) system means a verified and approved system for the limitation of the maximum engine power by technical means that can only be overridden by the vessel’s Master or OICNW for the purpose of securing the safety of a ship or saving life at sea.

.5 Power reserve means shaft/engine power above the limited power which cannot be used in normal operation unless in the case when SHaPoLi/EPL is unlimited for the purpose of securing the vessel safety.

17.2 Any SHaPoLi and EPL system installation on board of Barbadian vessels shall be approved and verified by a Barbadian RO for compliance with Resolution MEPC.335(76).

17.3 The SHaPoLi/EPL system shall be accompanied by the Onboard Management Manual (OMM) for SHaPoLi/EPL, which shall be verified by a Barbadian RO after a survey verifying the vessel's attained EEXI and shall be permanently on board the vessel for inspection.

17.4 The use of a power reserve is only allowed for the purpose of securing the safety of a vessel or saving life at sea, consistent with MARPOL Annex VI Reg. 3.1 such as: operating in adverse weather and ice-infested waters, participation in search and rescue operations, avoidance of pirates and engine maintenance.

17.5 As per Resolution MEPC.335(76) the use of power reserve (override) shall be allowed only for the following cases:
.1 operating in adverse weather;
.2 operating in ice-infested waters;
.3 participation in search and rescue operations;
.4 avoidance of pirates;
.5 engine maintenance;
.6 description of other reasons consistent with MARPOL Annex VI Reg. 3.1.
17.6 The use of power reserve for engine maintenance as Sec. 17.5.5 above, depends on the engine type and auxiliary systems. Hence, if the maintenance, as per manufacturer's specifications, cannot be done with normal power, the use of a power reserve can be considered for engine maintenance for any applicable regular and irregular maintenance by the RO when approving the OMM.

17.7 The RO, in this case, approves the use of a power reserve for regular maintenance only after assessment of the manufacturer's specifications as per above. In this case, the authority for this should be clearly set out in the OMM and/or the SMS manual, as appropriate.

17.8 Any use of a power reserve should be recorded in the record page of the OMM for SHaPoLi/EPL, signed by the Master and should be kept on board and in the format as per appendix of Resolution MEPC.375(80).

17.9 Where an EPL/ SHaPoLi override is activated but the power reserve is not subsequently used, this event should be recorded in the bridge and engine-room logbooks. The engine-room logbook should record power used during the period when the override was activated. The EPL/SHaPoLi should be reset as soon as possible, and details of the reset should also be recorded in the bridge and engine-room logbooks.

17.10 In case of having used a power reserve, the vessel shall without delay (within 24 hours) notify the RO responsible for issuing the relevant certificate and the competent authority of the relevant port of destination with the information recorded as per Sec. 17.8 above. The notification need not be done to the BMSR.

17.11 On an annual basis by 30 June every year, the RO responsible for issuing the relevant certificate shall report to the IMO Secretariat uses of a power reserve over a 12 month period from 1 January to 31 December for the preceding calendar year with the information recorded in accordance with Sec. 17.8 above.

17.12 Once the risks have been mitigated, the vessel shall be operated below the certified level of engine power under the SHaPoLi/EPL.

17.13 The SHaPoLi/EPL system should be reactivated or replaced by the crew immediately after the risks have been prevented and the ship can be safely operated with the limited shaft/engine power. The reactivation or replacement of the SHaPoLi/EPL system should be confirmed (e.g. validation of mechanical sealing) with supporting evidence (e.g. engine power log, photo taken at the occasion of resetting the mechanical sealing) by the RO at the earliest opportunity.

17.14 The type of evidence and the timing of submission shall be stated in the OMM and SMS manual. The submission is to be at the earliest opportunity, hence as soon as the use of power reserve and within 24 hours.

17.15 Supporting evidence includes engine power log, photo taken at the occasion of resetting the mechanical sealing and these can be verified remotely by the RO. The BMSR does not request an additional survey for reactivation of the SHaPoLi/EPL after engine maintenance.

17.16 The RO shall carry out an additional survey in case of replacement of the SHaPoLi/EPL systems and any alteration in the systems.

18. Ship Energy Efficiency Management Plan (SEEMP) (MARPOL VI Reg. 26)

18.1 Every vessel of 400 GT and above shall keep on board a ship specific Ship Energy Efficiency Management Plan (SEEMP). This may form part of the ship's Safety Management System (SMS). The SEEMP shall be developed and reviewed, taking into account Resolution MEPC.346(78).

18.2 The SEEMP shall be provided on board before issuance of the IEEC.

18.3 There are three parts to a SEEMP:
.1 SEEMP Part I. The purpose of this part is to provide an approach to monitor vessel and fleet efficiency performance over time and describe ways to improve the vessel's energy efficiency performance and carbon intensity. Part I of the SEEMP applies to any vessel of 400 GT and above;
.2 SEEMP Part II. The purpose of this part is to provide a description of the methodologies that should be used to collect the Ship Fuel Oil Consumption Data required pursuant to MARPOL Annex VI Reg. 27 and the processes that the vessel should use to report the data to the Barbados RO. Part II of the SEEMP applies to any vessel of 5,000 GT and above.
.3 SEEMP Part III. The purpose of this part is to provide:
i) A description of the methodology that should be used to calculate the vessel's attained annual operational Carbon Intensity Indicator (CII) required by MARPOL Annex VI Reg. 28 (Sec. 19 below);
ii) The processes that should be used to report this value to the Barbados RO;
iii) The required annual operational CII for the next three years;
iv) An implementation plan documenting how the required annual operational CII should be achieved during the next three years;
v) A procedure for self-evaluation and improvement; and
vi) For vessels rated as D for three consecutive years or rated as E, a plan of corrective actions to achieve the required annual operational CII.

18.4 Part III of the SEEMP applies to any vessel of 5,000 GT and above which falls into one or more of the categories defined 4.2 above.

18.5 The SEEMP Part I does not require verification or approval by the Administration/RO. This may form part of the vessel’s SMS.

18.6 The SEEMP Part II should be verified by the nominated Reporting Organisation/Verifier, prior to commencement of Ship Fuel Oil Consumption Data reporting. On successful verification of the amended SEEMP, the Reporting Organisation/Verifier is to issue a Confirmation of Compliance as per MEPC.1-Circ.876 to the vessel, in accordance with MARPOL Annex VI Reg.5.4.5.

18.7 Where there is a change of nominated Reporting Organisation/Verifier, the new Reporting Organisation/Verifier shall obtain the SEEMP Part II verified by the previous Recognised Organisation/Verifier and the related Confirmation of Compliance and take those to their files as a basis for later verifications.

18.8 The SEEMP Parts I & II & III and Confirmation of Compliance shall be kept on board.

18.9 The SEEMP Part III amendments shall be verified and confirmed acceptable to the Reporting Organisation/Verifier.

19. Collection and Reporting of Ship Fuel Oil Consumption Data (MARPOL VI Reg. 27)

19.1 The Company shall ensure that fuel consumption data and the attained annual operational CII index for the previous year for vessels to which MARPOL Annex VI Reg. 27 and 28 apply is submitted to the Reporting Organisation/Verifier by not later than 31 March. The Statement of Compliance required by MARPOL Annex VI Reg. 6.4 is to be issued by the Reporting Organisation/Verifier by 31 May each year.

19.2 Verified fuel consumption and attained annual operational CII index data is to be uploaded to the IMO Global Integrated Shipping Information System (GISIS) by the Reporting Organisation/Verifier within 1 month after issuing the Statement of Compliance but not later than 30 June each year.

19.3 When preparing the annual fuel consumption reports for their fleet, the Company should be aware that submission is also required for a part of a year if a vessel has left or been accepted to their management, joined, or left the Barbados flag, or has been recycled before 31 December. The reporting of the fuel consumption data is required on the day of completion of the transfer from one flag to another or of the change from one Company to another, or as close thereto as practical.

19.4 Notwithstanding 18.3, where a vessel changes flag to the Barbados at any time after 01 January the attained annual operational CII index shall be reported to the Reporting Organisation/Verifier for the entire 12 months period by 31 March the next year. As of the date of issue of this Notice, the IMO is yet to develop the detailed guidance on the end of year reporting where only partial fuel consumption information is available.

19.5 Recognising that on occasions timely submission or review of aggregated and verified data cannot be completed, the BMSR exercises a pragmatic approach in allowing the Reporting Organisation/Verifier additional time to complete the submission and issue a Statement of Compliance.

19.6 A request for a permit, as per Bulletin 008, for a conditionally issued short term IEEC should be submitted via the RO or Company for every vessel where any of the limit date(s) in Sec. 18.1 cannot be met.

19.7 In accordance with Appendix IX of MARPOL Annex VI, the following information is to be included in the annual cumulative fuel consumption data report:

.1 Identity of the vessel: IMO number, ship type, gross tonnage, net tonnage, deadweight, rated power of each main and/or auxiliary reciprocating internal combustion engine over 130 kW, Attained EEDI (where applicable), Ice Class;
.2 Every type of fuel oil consumed on board for any purpose (engines, boilers, incinerator, inert gas generators, heaters etc.), in metric tonnes. This requirement also applies to ships consuming boil-off gas (BOG) for the purpose of propulsion or shipboard operational needs ;
.3 distance travelled over ground;
.4 hours underway;
.5 information on the method used to collect fuel consumption data as required by MARPOL Annex VI Reg. 22A.

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[1] The quantity of consumed BOG should be reported in metric tonnes in reference to the original quantity of liquified gas

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19.8 Reporting of direct CO2 emission measurements is not mandatory. This method may however be utilised concurrently where the necessary equipment is installed on board to supplement the fuel consumption data report.

19.9 When the Reporting Organisation/Verifier has received fuel consumption data from a ship and verified that it has been collected and reported correctly per Resolution MEPC.348(78), a Statement of Compliance shall be issued to the vessel confirming the submission of the data required for the period. The format of the Statement of Compliance can be found in Appendix X of MARPOL Annex VI.

19.10 Each Statement of Compliance will remain valid for the duration of the calendar year when it was issued and for the first five months of the next calendar year.

19.11 Expired Statements of Compliance are not required to be retained beyond their expiration date, once a new statement has been issued and delivered on board.

19.12 In situations where a vessel is not in a position to obtain a new Statement of Compliance following the end of a calendar year due to lay-up, conversion of period of inactivity, the last issued Statement of Compliance shall be retained on board for inspection.

20. Operational Carbon Intensity (MARPOL VI Reg. 28)

20.1 Starting from 01 January 2024, each vessel of 5,000 GT and above which falls into one or more of the categories specified in Sec. 4.2 above shall calculate the attained annual operational Carbon Intensity Indicator (CII) over a 12-month period from 1 January to 31 December for the preceding calendar year, using the data collected in accordance with MARPOL Annex VI Reg. 27.

20.2 The attained annual operational CII for the preceding year shall be reported by the Reporting Organisation/Verifier by 01 April each year.

20.3 Notwithstanding the above, in the event of a change of flag of a ship completed after 1 January 2023, the vessel shall, after the end of the calendar year in which the transfer takes place, calculate and report the attained annual operational CII for the full 12- month period from 1 January to 31 December in the calendar year during which the transfer took place, for verification by the RO.

20.4 The attained annual operational CII shall be verified by the Reporting Organisation/Verifier against the required annual operational CII to determine an operational carbon intensity rating of A, B, C, D or E, indicating the ship’s preceding year performance level, as outlined in MARPOL Annex VI Reg. 28.6.

20.5 A ship rated as D for three consecutive years, or when rated as E, shall develop a plan of corrective actions to achieve the required annual operational CII.

20.6 The SEEMP shall be reviewed to include the above plan of corrective actions accordingly. The revised SEEMP shall be submitted to the Reporting Organisation/Verifier for verification, not later than 1 month after reporting the attained annual operational CII. Implementation of corrective actions shall commence immediately following the verification by the Reporting Organisation/Verifier.

21. EU/UK MRV Reporting

21.1 The EU requires the monitoring, reporting and verification (MRV) of carbon dioxide emissions from maritime transport as applicable, for vessels above 5,000 GT on EU related voyages and to be in compliance with Regulation (EU) 2015/757.

21.2 As a result of the United Kingdom leaving the EU, the EU MRV no longer applies to the UK. However, the UK has adopted with SI 2018/1388 UK MRV regulations, based on the EU MRV, which are applicable for vessels above 5,000 GT trading in or out of any UK ports and reporting shall be done as per UK Marine Information Notice MIN 669 (M+F).

21.3 The EU and UK MRV are in addition to the provisions of MARPOL Annex VI.

21.4 It is anticipated that the EU/UK MRV and MARPOL Annex VI fuel consumption data submission requirements will eventually be aligned to reduce administrative burden, as some vessels will need to report the same data twice. However, so far there are no firm indications of the timescale for alignment of the EU/UK MRV and MARPOL Annex VI requirements.

21.5 Fuel consumption data for voyages between ports in the UK, whilst at berth in any UK ports, between ports in the UK and non-EEA ports and vice-versa shall be included in UK MRV reporting.

21.6 To avoid duplication, fuel consumption data covering voyages between the UK and EEA ports and vice versa shall not be reportable under the UK MRV regulations and shall continue to be submitted as part of EU MRV data.

21.7 Where a Barbados RO acts as a Reporting Organisation/Verifier (DCS) and has been accredited as an MRV verifier, the BMSR has no objection to fuel consumption data and MRV reporting being combined, provided that the combined reports provide all of the information required by MARPOL Annex VI Reg. 22A.

21.8 A Document of Compliance covering the EU/UK MRV fuel consumption data submission shall be provided on board every applicable vessel.

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

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) SOLAS, International Convention for the Safety of Life at Sea.
c) Resolution MSC.402(96) Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear.
d) Resolution MSC.404(96) Amendments to SOLAS Ch's II-2 and III.
e) Bulletin 041 – Barbadian Authorisation of Service Provider.
f) Resolution A.761(18) Recommendation on Conditions for the Approval of Servicing Stations for Inflatable Liferafts.
g) Bulletin 08 – Permits Exemptions and Equivalences.
h) International Life-Saving Appliance Code (LSA Code).
i) MSC.1/Circ.1490/Rev.1 Revised unified interpretation of SOLAS regulation III/31.1.4 (MSC.1/Circ.1490)

2. Purpose

2.1 This Bulletin is to establish a uniform, safe and documented standard for maintenance, inspections and servicing of Life Saving Appliances (LSA) in compliance with SOLAS III/Reg. 20 and Reg. 36 and with IMO Resolution MSC.402(96) and Resolution MSC.404(96), which both took effect on the 1st of January 2020.

3. Application

3.1 This Bulletin applies to all LSA installed on board all Barbadian vessels.

4. Competent Person

4.1 A “competent person” is one possessing the knowledge and experience necessary to enable them to satisfactorily perform the duties required by SOLAS III/Reg.20 and Reg. 36. Such knowledge and experience can be obtained in a variety of ways. For example, a "competent person" might obtain the necessary knowledge through training provided by the manufacturer of equipment or by "inhouse" or "on the job" training provided within the organisation or on the vessel.

4.2 SOLAS does not define who can be considered a “competent person". It is for the Company to decide who is a "competent person" for a particular duty. A member of the vessel’s crew might, if they have the appropriate knowledge and experience, be considered a "competent person" for the purpose of carrying out routine inspections, whereas a "competent person" able to carry out tests of lifting equipment may need to be provided by a company specialising in such testing. It should also not be assumed that possession of a Certificate of Competency means that the person holding that Certificate is automatically a “competent person” for the purposes of this bulletin. Much will depend on the work to be undertaken, the qualifications required to undertake it and the individual's knowledge of the particular equipment.

4.3 The Company are responsible for assessing and selecting a suitable “competent person”. Appropriate procedures relating to this activity must be established within the Company’s Safety Management System (SMS). Documentary evidence of personnel competence must be available on board for verification by Barbados Appointed Nautical Inspectors (ANIs) and Recognised Organisations (ROs).

5. Equipment Servicing

5.1 SOLAS III/Reg. 20.8 requires inflatable life rafts, inflatable life jackets, marine evacuation systems, and inflated rescue boats to be serviced at approved servicing facilities.

5.2 Before endorsing or issuing the Cargo Ship Safety Equipment Certificate, the RO surveyors must be satisfied that the servicing has been completed satisfactorily. The surveyor’s attendance during servicing is not mandatory because they are taken ashore.

5.3 The servicing interval and procedures for inflatable rescue boats must be according to the manufacturer’s requirements. The facility performing the servicing must be an approved service provider by a Barbados RO, as detailed in Resolution A.761(18).

5.4 It may be necessary to temporarily carry on board more persons than currently authorised. When physically possible, the installed lifeboats must be recertified to provide the necessary capacity. If the existing lifeboats are already certified to their maximum capacity, the BMSR may allow with a permit, as per Bulletin 008, substituting inflatable life raft capacity to increase the required lifeboat complement for legitimate, verifiable reasons. The permit will be limited to the minimum time required for the additional persons to be on board and, in general, will not exceed two months.

6. Inspections and Maintenance

6.1 Weekly and monthly inspections, routine maintenance of life-saving appliances, including lifeboat equipment as specified in the equipment maintenance manual can be conducted by a competent person, in accordance with the maintenance manual(s), and such activities do not require BMSR authorisation.

6.2 Monthly inspections of LSA, including lifeboat equipment, shall be carried out using a checklist as required by SOLAS III/Reg. 36.1 and a report of the inspection shall be entered in the official log-book.

6.3 SOLAS III/Reg. 20.11 requires annual and five-year thorough examinations, any overhaul and overload operational tests to be carried out for:

.1 Lifeboats (including free-fall lifeboats), rescue boats and fast rescue boats; and
.2 Launching appliances (including primary and secondary means of launching appliance for freefall lifeboats), and release gear for all lifeboats type, rescue boats, fast rescue boats and davit launched liferafts.

6.4 The annual and five-year thorough examination, any overhaul or overload operational tests of equipment listed in Sec. 6.3 above shall be conducted ONLY by a service provider with a Barbados Approved Service Provider (BASP) authorisation document issued by the BMSR as per Bulletin 041.

6.5 Instructions, maintenance and record keeping shall be implemented through the vessel’s instructions for on-board maintenance of life saving appliances or a planned maintenance system which meets the requirements of SOLAS III.

6.6 Records must clearly state that the annual periodical inspection has been carried out and the results of the examination. If end-for-end turning of wires has been carried out this should also be recorded. The renewal of falls at the required intervals (according to the maintenance procedure adopted) must be included. These records must be verified by the surveyor attending for the Safety Equipment Survey.

6.7 There are no provisions in SOLAS III to postpone the 5 yearly service and load test. The Company shall make arrangements for the 5-yearly service to be carried out, including the dynamic load test, prior to the expiry of the 5-year term.

6.8 In exceptional cases where it is not possible to conduct the 5-yearly service within the required period, the BMSR may consider short postponements of up to 3 months to allow the service to be completed. In such cases, the BMSR will issue a permit as per Bulletin 008.  

7. Maintenance of LSA falls

7.1 As required by SOLAS III/Reg. 20.4, falls used for launching lifesavings appliances must be inspected periodically with special regard for areas passing through sheaves. Deteriorating falls must be renewed as necessary or at intervals of not more than five (5) years, whichever is the earlier. The intermediate turning of the falls end for end is no longer required.

7.2 Wire rope grips, such as bulldog grips, are not acceptable for any primary load-bearing terminations. Where wire rope grips are found to have been used on primary load-bearing terminations, arrangements must be made for their replacement.

7.3 If the Company chooses to end-for-end fall wires, special attention must be paid to the method of joining and terminating wires. The BMSR recognises that there are a number of alternative methods that can be used to form these terminations and that the suitability of each type of connection for the intended service is varied. The Company shall ensure the correct method of joining and terminating the wires, taking into consideration any design or manufacturers’ requirements.

7.4 The periodic inspection shall be carried out by a competent person within the window before, or at the time of, the Safety Equipment survey.

8. Lifeboats

8.1 Vessels must be fitted with lifeboats on-load release mechanisms compliant with Sec. 4.4.7.6.4 to 4.4.7.6.6 of LSA Code as required by SOLAS III/Reg. 1.5.

8.2 The vessel’s Master must ensure that when a lifeboat on-load release hook with a secondary safety system is fitted, this is used during all drills (both launch and recovery) and when the lifeboat has crew or other personnel aboard. After the drill finishes, the secondary safety system must be removed or disengaged.

8.3 When any lifeboat is damaged, declared unseaworthy, or needs repair and if no replacement boat is readily available, life raft(s) capacity for all the persons on board may be substituted as a temporary measure. This substitution may only take place with a permit as per Bulletin 008, which, in general, will not exceed three (3) months. The minimum survival craft capacity prescribed by SOLAS III must be maintained.

9. Rescue Boats

9.1 SOLAS and the LSA Code do not require boats used solely for rescue to be fitted with on-load release mechanisms; however, many are fitted with these devices. The BMSR recommends that all on-load release mechanisms should meet the same standards, regardless of whether installed on a lifeboat or rescue boat. Accordingly, the rescue boat on-load release mechanisms should also comply with Sec. 4.4.7.6 of the LSA Code.

10. Liferafts

10.1 Liferafts provided under SOLAS III/Reg. 31.1.4 may be stowed in protected positions, provided they are always readily available. Care must be given to their accessibility when deck cargoes are carried.
10.2 For Barbadian vessels, IMO MSC.1/Circ.1490/Rev.1 must be applied to liferafts as required by SOLAS III/Reg. 31.1.4. This unified interpretation covers:

.1 stowage arrangements;

.2 embarkation and embarkation ladders;

.3 illumination; and

.4 lifejackets and immersion suits.

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

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) IMO Resolution MSC.255(84) Code of the International Standards and Recommended practices for a safety investigation into a Marine Casualty or Marine Incident (Casualty Investigation Code).
c) The International Safety Management Code (ISM Code).
d) Bulletin 035 - Piracy and Armed Robbery.
e) Bulletin 010 - Barbados Reporting Requirements.

2. Purpose

2.1 This Bulletin provides information on BMSR’s reporting requirements for reporting Marine Accidents and Marine Safety Investigations.
2.2 This Bulletin does not cover reporting of Piracy incidents, which are addressed in Bulletin 035.
2.3 This Bulletin does not cover reporting of Birth and Deaths, Occupational Diseases and Breach of Security (Stowaways), which are addressed in Bulletin 010.

3. BMSR Contact Details

3.1 In case of emergency the BMSR contact details are as per below:
.1 Email: accidents@barbadosmaritime.com
.2 Emergency 24-hour phone: +44 (0) 7494 116 754

4. Application

This Bulletin applies to all Barbadian vessels engaged in international voyages.

5. Definitions

For the purposes of Section 229 of the CAP 296, “marine accident” refers to both a marine casualty and a marine incident as defined in this section.
5.1 A marine casualty is an event, or a sequence of events, that has resulted in any of the following which has occurred directly in connection with the operations of a vessel:
.1 The death of, or serious injury to a person. In this context, a serious injury renders the person unable to perform their usual duties for >72 hours and includes occupational accidents;
.2 The loss of a person from a vessel;
.3 The loss, presumed loss, or abandonment of a vessel;
.4 Material damage to a vessel or marine infrastructure. In this context, material damage means the structural integrity, performance or operational characteristics of the vessel or infrastructure are significantly affected and require major repair or replacement of a major component or components.
.5 The vessel is unfit to proceed or requires flag state approval or a condition of class before it is allowed to proceed.
.6 At sea, a breakdown of the vessel, required towage.
.7 The stranding or disabling of a vessel, or the involvement of a vessel in a collision.
.8 Damage to marine infrastructure external of a vessel that could seriously endanger the safety of the vessel, another vessel or any individual.
.9 Pollution, caused by damage to a vessel or vessels.
5.2 A very serious marine casualty means a marine casualty involving the total loss of the vessel or the death of a person or severe damage to the environment.
5.3 A marine incident, is an event or sequence of events, which has occurred directly in connection with the operation of a vessel that does not meet the criteria to be classified as a marine casualty (as in Section 5.1 above) but that endangered or, if not corrected would endanger, the safety of the vessel, its occupants or any other person or the environment.
5.4 A marine incident or marine casualty does not include a deliberate act or omission, with the intention to cause harm to the safety of a vessel, an individual or the environment.

6. Marine Accident Reporting

6.1 The Master or senior surviving officer of a Barbadian vessel must notify the BMSR of any marine accident, regardless of location.
6.2 The vessel’s owner or manager must notify the BMSR of any marine accident unless they are satisfied that the Master or senior surviving officer has made the report.
6.3 All notifications are treated confidentially, and a reporter’s identity will not be released.
6.4 Any notification of a marine accident made to the BMSR does not remove any obligation to notify other Organisations, such as Coastal and Port State authorities.
6.5 The BMSR should be informed immediately if a port or coastal State initiates an investigation or takes any other action in relation to an accident.
6.6 An Initial Report of any accident must be sent to the BMSR within 24 hours of the occurrence, via telephone or email. The Initial Report should provide brief details of the incident, such as:
.1 vessel’s name and IMO number;
.2 the nature of the accident, date, and time;
.3 vessel’s location, and next port of call if at sea;
.4 confirmation that port or coastal State authorities have been notified; and,
6.7 Notification must not be delayed until the completion of an internal company investigation.
6.8 And follow up to the initial report, Form 45 - Accident / Incident reporting must be submitted within 24 hours.

7. What not to Report

7.1 There is no requirement to report:
.1 Defects to equipment and vessel detentions unless they are related to a marine casualty or marine incident.
.2 Injuries to passengers that did not result from activities connected with the operation of the vessel. For example: a passenger suffering a fall on board a vessel, where the vessel’s movement, design, or acts or omissions by crew were not contributing factors.
.3 Damage or injuries occurring ashore, which do not involve the vessel’s equipment.
7.2 Notwithstanding the list of serious marine casualties contained in Section 6.1, Owners and the Master are encouraged to report to the BMSR any accident which may fall within the scope of their ISM Code reporting requirements.

8. Evidence

8.1 Following a marine accident, the BMSR may require access to additional information and evidence. Therefore, all charts, logbooks, recorded data (hard copy or electronic) relating to the period prior to, during and after the marine accident, and all other documents, records and equipment which may be pertinent to the marine casualty or marine incident must be preserved.
8.2 Where a vessel is fitted with a Voyage Data Recorder, the data recorded by it must be saved immediately and steps taken to prevent the data becoming overwritten. Preservation is mandatory for marine casualties.

9. Accident follow up and Marine Safety Investigation

9.1 Following a preliminary review of the facts provided in the initial reporting and Form 45 - Accident / Incident reporting (when applicable), the BMSR may seek to obtain such information as it considers necessary concerning the marine accident and any remedial action taken. A description of actions taken and/or recommendations made to prevent recurrence may be requested. In some cases, the Company’s investigation report will be sufficient, but the BMSR may seek further details if required.
9.2 A Marine Safety Investigation (MSI) will be conducted for all the very serious marine casualties, as defined in Sec. 5.2 above.
9.3 A marine safety investigation might be conducted into marine casualties (other than very serious marine casualties) and marine incidents if it is considered likely that an MSI will provide information that can be used to prevent marine accidents in the future.
9.4 The purpose of an MSI is to help prevent further avoidable accidents from recurring, it does not seek to apportion blame or establish liability. Instead, it works alongside shipowners to help ensure that lessons learned from a casualty are implemented and the likelihood of recurrence is reduced.
9.5 When an MSI is carried out, the BMSR publishes the MSI report that includes safety recommendations and safety learning to improve safety at sea.

10. Offences

10.1 Under Section 314(1) of the CAP 296 it is an offence not to report a marine accident or provide information required without reasonable cause. This may result in the suspension of the certificate of registry (COR) of the vessel until the contravention is rectified, or in the deletion of the vessel from the register.
10.2 Under Section 315 of the CAP 296, a person who contravenes Section 314(1) is guilty of an offence, and, unless a specific penalty is otherwise provided by CAP 296, is liable on summary conviction to a fine of USD50 000, or imprisonment for 6 months, or both.

Revision History:

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

1. References

• a) IMO circular A.959(23)
• b) SOLAS XI-1/5 Continuous Synopsis Record
• c) DNV Notification - Continuous Synopsis Record (dated 08/Feb/2021)

2. Purpose

• 2.1 This Bulletin is issued by the Barbados Maritime Ship Registry (BMSR) to advise ship owners, managers and other interested third parties of the validity of certification issued by DNVGL AS on behalf of Barbados, following the change in name of the Society to DNV AS.
• 2.2 A copy of this Bulletin should be retained on board for presentation to interested parties, including Port State Control Authorities.

3. Recognition of Statutory Certificates

• 3.1 DNVGL AS is a Barbadian Recognized Organization (RO) and Recognized Security Organization (RSO) and authorized to perform statutory services and issue statutory ertificates on behalf of Barbados. The existing Agreement with DNVGL AS is considered as the current Agreement under which DNV AS will perform statutory services and issue statutory certificates on behalf of Barbados.
• 3.2 Existing certificates issued by DNVGL will remain valid, until their expiry date or until reissued.
• 3.3 The BMSR also recognises statutory certification now issued by DNV AS.

4. Continuous Synopsis Record (CSR)

• 4.1 The Continuous Synopsis Record (CSR) requires the Classification Societies and issuing bodies for the Safety Management Certificate, Document of Compliance, and International Ship Security Certificate to be identified on the CSR.
• 4.2 In order to reduce the administrative burden to owners and the BMSR, the BMSR does not require CSRs to be re-issued to reflect the change of name of DNVGL AS to DNV AS. The name changed to DNV AS will only be reflected on new CSRs issued due to a change of other mandatory information on the CSR document - i.e., change of name, change of owner/manager details, transfer of class, etc.
• 4.3 Existing CSR’s which identify DNV GL as the class society, RO or RSO should be treated as identifying DNV AS and will remain valid, until issuance of a new CSR is required, due to change of other required information.

Revision History

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

1. References
a) The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, (STCW Convention).
b) The Seafarers’ Training, Certification and Watchkeeping Code (STCW Code).
c) Statutory Instruments, Shipping (Safe Manning, Watchkeeping and Hours of Works) Regulations (S.I 2001 No. 44)

2. Definitions

2.1 Certificate of Competency (COC)” means a certificate, issued, and endorsed by an STCW Convention Party for masters, officers and GMDSS radio operators in accordance with the provisions of Chapters II, III, IV or VII of the STCW Code and entitling the lawful holder thereof to serve in the capacity and perform the functions involved at the level of responsibility specified therein;
2.2 “Certificate of Proficiency (COP)” means a certificate, other than a certificate of competency issued by STCW Convention Party to a seafarer, stating that the relevant requirements of training, competencies or seagoing service in the Convention have been met;
2.3 “Endorsement (COE)” means a valid document, that attests the recognition of a certificate issued by STCW Convention Party in accordance with the provisions of the STCW Convention I/10, to acknowledge that a holder has the right to occupy a position according to the Barbados S.I 2001 No. 44;

3. Purpose

3.1 This bulletin is to provide the list of Administration whose COCs and COPs are recognised by the BMSR under STCW Convention Regulation 1/10 and the list of relevant COEs issued by the BMSR.

4. BMSR COEs

4.1 The list below, as per STCW Code Part B, Chapter I Table B-1/2 and the Barbados S.I 2001 No. 44, identifies all certificates that have to be addressed by the BMSR for seafarer who works on Barbadian vessels.
List of BMSR COEs

List of BMSR COEs

5. Administrations recognised by the BMSR   

5.1 the list of Administration whose COCs and COPs are recognised by the BMSR under STCW Convention Regulation 1/10 is as per below table.

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

1. References

• a) Guidelines for the Use of Electronic Certificates - FAL.5/Circ.39/Rev.2.

2. Purpose

• 2.1 This Bulletin establishes the requirements for electronic documents issued by the BMSR. It contains information for their features, conveyance, and verification.

• 2.2 All electronic certificates issued, in compliance with the IMO Facilitation Committee FAL.5/Circ.39, by the BMSR or by a Barbados Recognised Organisation (RO) shall be deemed valid in accordance with all applicable international conventions and instruments to which Barbados is a Party.

• 2.3 A copy of this Bulletin should be placed on board Barbadian vessels to facilitate the acceptance of electronic certificates by other relevant authorities.

3. RO Statutory Certificates

• 3.1 Several ROs are now able to issue electronic certificates to ships in lieu of traditional paper certificates.

• 3.2 The use of electronic certificates is accepted by the BMRS, provided that are issued in compliance with the provisions of FAL.5/Circ.39.

4. BMSR Documents

• 4.1 The BMSR has now moved to full implementation of electronic documents for vessel certificates and seafarers’ documents.

• 4.2 The electronic documents issued by the BMSR contain all elements required by FAL.5/Circ.39.

• 4.3 Original hardcopy documents issued by the BMSR shall remain valid (up until the indicated expiry date) and be carried on board until they have been reissued electronically or otherwise superseded, and the new electronic certificates are available on board.

• 4.4 Hard copy documents may be issued in exceptional circumstances and may have either a manual signature or a scanned signature printed on the document. Paper documents are generally printed on BMSR headed paper (with the exception of Certificates of Inspection).

• 4.5 All documents and certificates issued electronically by the BMSR must be able to be viewed and printed out onboard the vessel when required.

• 4.6 Electronic documents are issued in Portable Document Format (PDF), and a suitable PDF viewer, such as Adobe Reader, or similar, is required to view and print the electronic documents.

• 4.7 Adobe Reader can be downloaded free of charge from www.Adobe.com.

5. List of Electronic Documents issued

• 5.1 Provisional Certificate of Registry (COR).

• 5.2 Permanent Certificate of Registry (COR).

• 5.3 Carving and Marking Note (CMN).

• 5.4 Maritime Labour Certificate (MLC).

• 5.5 Declaration of Maritime Labour Compliance (DMLC I).

• 5.6 Safe Manning Document (SMD).

• 5.7 Continuous Synopsis Record (CSR).

• 5.8 Ship Station Licence (SSL).

• 5.9 Certificate of Insurance for Civil liability for bunker oil pollution damage (Bunker Certificate).

• 5.10 Certificate of Insurance for Civil liability for oil pollution damage (CLC Certificate).

• 5.11 Certificate of Insurance or other financial security in respect of liability for the death of and personal injury to passengers (Athens Convention Certificate).

• 5.12 Exemptions and Dispensations (Permits).

• 5.13 Barbadian Authorisation of Service Prover (BASP).

• 5.14 Transcript.

• 5.15 Officer Certificate of Receipt of Application (CRA).

• 5.16 Officer Endorsements.

• 5.17 The lists above is not exhausted of all electronic documents issued by the BMSR.

6. BMSR Document Validation

• 6.1 Electronic documents either in printed or electronic form may be verified online in two ways:
• 1. by using the Quick Response (QR) Code found in in the bottom right-hand corner; or
• 2. via the online BMSR Portal.

• 6.2 For the validation of an electronic document the Document Control Number (DCN) is located in the bottom of the document.

• 6.3 Once the DCN has been entered, the “Document Authenticity Checked” page shows the details of the vessel or seafarer and on the bottom of the page the “Document Expiry Date” (if applicable) and the “Document Validity.”

• 6.4 Queries regarding the validation of electronic documents may be addressed to registry@barbadosmaritime.com.

7. BMSR Document Validity

• 7.1 When a document or a vessel is deleted from the registry, the validation of the electronic documents gives “VALIDATION FAILED: Barcode for that document type does not exist in our system.”

• 7.2 When a vessel is suspended from the registry the electronic documents still remain valid unless they have been deleted.

• 7.3 Withdrawn and expired electronic documents “Document Validity” reads “Superseded”.

Revision History

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

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) Barbados Shipping (Oil Pollution) Act (CAP296A).
c) International Convention for the Prevention of Pollution from Ships (MARPOL).
d) NOX Technical Code 2008 (NTC 2008).
e) MEPC.1/Circ.892 Guidelines for exemption of unmanned non-self-propelled (UNSP) barges from the survey and certification requirements under the MARPOL Convention.
f) Resolution MEPC.340(77) 2021 Guidelines for Exhaust Gas Cleaning System.
g) MEPC.1/Circ.795/Rev.2, Unified Interpretations to MARPOL Annex VI.
h) Resolution MEPC.364(79) 2022 Guidelines on the Method of Calculation of the Attained EEDI for New Ships.
i) Resolution MEPC.333(76) 2021 Guidelines on the Method of Calculation of the Attained (EEXI).
j) Resolution MEPC.324(75) Procedures for sampling and verification of the sulphur content of fuel oil and the Energy Efficiency Design Index (EEDI).
k) Resolution MEPC.320(74) 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.
l) MEPC.1/Circ.881 Guidance for port State control on contingency measures for addressing non-compliant fuel oil;
m) MEPC.1/Circ.864/Rev.1 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships.
n) MEPC.1/Circ.889 2020 Guidelines for on board sampling of fuel oil intended to be used or carried for use on board a ship.
o) MEPC.1/Circ.884/Rev.1 Guidance for best practice for Member State/coastal State.
p) Resolution MEPC.346(78) 2022 Guidelines for the development of a ship energy efficiency management plan (SEEMP).
q) Res. MEPC.388(81) Amendments to the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (res. MEPC.346(78)).
r) Bulletin 008 – Permits Exemptions and Equivalences.
s) Resolution MEPC.348(78) 2022 Guidelines for Administration verification of ship fuel oil consumption data and operational carbon intensity.
t) MEPC.1-Circ.876 Sample Format for The Confirmation Of Compliance, Early Submission Of The SEEMP Part II etc.
u) Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport, and amending Directive 2009/16/EC.
v) SI 2018/1388 The Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions) (Amendment) (EU Exit) Regulations 2018.
w) MIN 669 (M+F) Amendments 1 - Reporting Emissions Data into the UK MRV Regime.
x) Resolution MEPC.335(76) 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve.
y) Resolution MEPC.375(80) Amendments to the 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve (res. MEPC.335(76)).
z) IACS recommendation 175 - SEEMP/CII Implementation Guidelines.
aa) Resolution MEPC.347(78) Guidelines for the verification and company audits by the Administration of part III of the Ship Energy Efficiency Management Plan (SEEMP).
bb) Res. MEPC.389(81) Amendments to the 2022 Guidelines for Administration verification of ship fuel oil consumption data and operational carbon intensity (resolution MEPC.348(78)).
cc) Res. MEPC.385(81) Amendments to MARPOL Annex VI, regulations 2, 13, 14, 18, 27, appendices I and IX (Low-flashpoint fuels and other fuel oil related issues, marine diesel engine replacing steam system, accessibility of data and inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS)).
dd) MEPC.1/Circ.913 Guidance on the application of the amendments to Appendix IX of MARPOL ANNEX VI on inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS) as adopted by Resolution MEPC.385(81).

2. Purpose

2.1 This Bulletin outlines the requirements of MARPOL Annex VI, and specifically Chapter 3 requirements for control of emissions and Chapter 4 requirements to reduce the carbon intensity for Barbadian vessels.

2.2 MARPOL Annex VI sets limits on vessel sulphur oxide (SOX) and nitrogen oxide (NOX) emissions. It regulates the deliberate emissions of ozone-depleting substances (ODS), the emissions of volatile organic compounds (VOCs) from tankers, and the incineration of certain products on board vessels. It also establishes fuel oil quality standards.

3. Application

3.1 The MARPOL Annex VI Chapter 3 requirements apply to all Barbadian vessels, regardless of tonnage, except where expressly provided otherwise.

3.2 The MARPOL Annex VI Chapter 4 requirements apply to Barbadian vessels of 400 gross tonnage (GT) and above, except where expressly provided otherwise as detailed in the relevant sections below.

3.3 The MARPOL Annex VI Chapter 4 requirements do not apply to vessels not propelled by mechanical means, platforms including Floating Production, Storage and Offloading Facilities (FPSOs) and Floating Storage Units (FSUs), and drilling rigs regardless of their propulsion and vessels operating in Barbados national waters.

4. Definitions

4.1 For the purposes of the MARPOL Annex VI Chapter 4, the definition of “New ship”, Major conversion MARPOL Annex VI Reg. 2, as per MEPC.1/Circ.795/Rev.2 defines the following terms:

.1 “New ship” means a vessel:

          i) for which the building contract is placed on or after 01 January 2013; or
          ii) in the absence of a building contract, the keel of which is laid, or which is at  a similar stage of construction on or after 01 July 2013; or
          iii) the delivery of which is on or after 01 July 2015.

.2 “Major Conversion” means a conversion of a vessel:

          i) which substantially alters the dimensions, carrying capacity, or engine power of the vessel; or
          ii) which changes the type of the vessel; or
          iii) the intent of which in the opinion of the Administration is substantially to prolong the life of the vessel; or
          iv) which otherwise so alters the vessel that, if it were a new ship, it would become subject to relevant provisions of the present Convention not applicable to                   it as an existing vessel; or
          v) which substantially alters the energy efficiency of the vessel and includes any modifications that could cause the vessel to exceed the applicable required Energy Efficiency Design Index (EEDI) as set out in MARPOL Annex VI Reg.21.

.3 A vessel delivered on or after 01 September 2019 means a vessel:
          i) for which the building contract is placed on or after 01 September 2015; or
          ii) in the absence of a building contract, the keel of which is laid, or which is at a similar stage of construction on or after 01 March 2016; or
          iii) the delivery of which is on or after 01 September 2019.

4.2 For the purposes of MARPOL Annex VI Chapter 4, the categories defined in MARPOL Annex VI Reg.: 2.2.5 Bulk carrier; 2.2.7 Combination carrier; 2.2.9 Container ship; 2.2.11 Cruise passenger ship; 2.2.14 Gas carrier; 2.2.15 General cargo ship; 2.2.16 LNG carrier; 2.2.20 Passenger ship; 2.2.22 Refrigerated cargo carrier; 2.2.26 Ro-Ro cargo ship; 2.2.27 Ro-Ro cargo ship (vehicle carrier); 2.2.28 Ro-Ro passenger ship; 2.2.29 Tanker.

5. Exceptions and Exemptions (MARPOL VI Reg.3)

5.1 MARPOL Annex VI regulations do not apply to emissions necessary for securing the safety of the vessel, saving life at sea, or those resulting from accidents and damage suffered to the vessel or its equipment:

.1 provided that all reasonable precautions have been taken after the occurrence of the damage or discovery of the emission for the purpose of preventing or minimizing the emission; and

.2 except if the Owner or the Master acted either with intent to cause damage, or recklessly and with knowledge that damage would probably result.

5.2 The requirements of MARPOL Annex VI Reg. 18 on fuel oil availability and quality shall not apply to the use of hydrocarbons that are produced and subsequently used on site as fuel and this exemption shall be annotated on the International Air Pollution Prevention Certificate (IAPPC).

5.3 The BMSR may exempt unmanned non-self-propelled (UNSP) barges from the survey and certification requirements of MARPOL Annex VI by means of an International Air Pollution Prevention Exemption Certificate for Unmanned Non-self-propelled (UNSP) Barges for a period not exceeding five years as per MEPC.1/Circ.892.

6. Equivalents (MARPOL VI Reg. 4)

6.1 Requests for equivalencies or alternative arrangements must be submitted to the BMSR at Ops@barbadosmarime.com. As per Bulletin 008, they must include a recommendation from the Recognised Organisation (RO) confirming that the alternative arrangement is at least as effective in terms of emissions reductions as required MARPOL Annex VI.

6.2 Upon satisfactory review of the application, the BMSR will notify the International Maritime Organization (IMO) of the acceptance of the equivalent/alternative compliance by making an entry in the IMO Global Integrated Shipping Information System (GISIS).

7. Surveys and Certification (MARPOL VI Reg. 5 to 9)

7.1 Barbadian vessels of 400 GT and above, engaged on international voyages, and every fixed and floating drilling rig or other platform shall be surveyed and certificated for compliance with the requirements of MARPOL Annex VI Reg. 5.1 and be issued with an IAPPC.

7.2 As per MARPOL Annex VI Reg. 13.1.1, each marine diesel engine with a power output over 130 kilowatt (kW) that is installed (or undergoes major conversion) on a vessel, irrespective of tonnage, must be surveyed and certified in accordance with the NTC 2008.

7.3 Barbadian vessels of 400 gross tonnage and above, to which MARPOL Annex VI Chapter 4 applies, shall undergo surveys in accordance with MARPOL Annex VI Reg. 5.1 and be issued with an International Energy Efficiency Certificate (IEEC).

7.4 Barbadian vessels which are not required to keep a Ship Energy Efficiency Management Plan (SEEMP) do not require an IEEC.

7.5 The ship type on the IEEC shall refer to the ship type in accordance with definitions specified in MARPOL Annex VI Reg. 2.2. which are indicated in Sec. 4.2 above.

7.6 If the vessel does not fall into the ship types defined in Sec. 4.2 above, in the IEEC the ship type shall be entered as “Ship other than ship types defined in in MARPOL Annex VI Reg. 2.2" and “the type of ship is exempt in accordance with MARPOL Annex VI Reg. 22.1/23.1/24.1/25.1” as applicable, shall be ticked in the IEEC relevant section.

7.7 If needed, the BMSR can issue a waiver letter as confirmation by this flag Administration of the ship type and to address Sec. 7.6 above.

7.8 The BMSR considers that the ship type stated on the IEEC should usually replicate the ship type designated at the stage of design and construction on which the Certificate of Class and Statutory Certificates of the vessel are based and with the ship type of the Barbados Certificate of Registry (COR).

7.9 In situations where, owing to operational necessity, an existing vessel may be required to change the ship type on the IEEC, the BMSR will consider such requests, where supported by the RO that issues the IAPPC of the vessel, provided that the ship type on the Certificate of Class, Statutory Certificates and COR of the vessel are amended accordingly.

7.10 The Owners of a vessel certificated to the ISM Code should be aware that where a change of ship type is requested, the vessel’s Safety Management Certificate (SMC) and the Company Document of Compliance (DOC), including associated safety management documents and procedures, may require to be amended.

8. MARPOL VI – RO’s Degree of Authorisation

8.1 The BMSR has authorised all Barbados ROs to:

.1 Issue or endorse an IAPPC;

.2 Issue or endorse an Engine International Air Pollution Prevention (EIAPP) certificate;

.3 Verify VOC management plans (Sec. 12.2 below);

.4 Carry-out Type Approval of shipboard incinerators (Sec. 13 below);

.5 Approve SOX Emissions Compliance Plans and issue a SOx Emission Compliance Certificate to vessels which use an Exhaust Gas Cleaning Systems (EGCSs) as an approved equivalent;

.6 Verify attained EEDI values calculated for each vessel (Sec. 14 below);

.7 Verify attained EEXI values calculated for each vessel (Sec. 16 below);

.8 Issue an IEEC after completion of the relevant surveys referred to in Sec. 7 above. The IEEC is to remain valid for the life of the vessel, except for the cases specified under MARPOL Annex VI Reg. 9.11 (vessel withdrawn from service, major conversion, or upon transfer of the vessel to the flag of another State).

.9 Verify the Ship Energy Efficiency Management Plan (SEEMP) Part II (Ship Fuel Oil Consumption Data Collection Plan) and issue Confirmation of Compliance (Sec.17.6 below );

.10 Verify Ship Fuel Oil Consumption Data Collection from each vessel operator, per vessel and issue an Annual Statement of Compliance (SoC) (Sec. 18 below);

.11 Submit data to the IMO Ship Fuel Oil Consumption Database.

9. Ozone-Depleting Substances (MARPOL VI Reg. 12)

9.1 Deliberate emissions of ozone-depleting substances (ODS) are prohibited and all vessels with installations containing ODS must comply with MARPOL Annex VI Reg. 12, except for permanently sealed equipment where there are no refrigerant charging connections or potentially removable components that contain ODS.

9.2 The ODS Record Book is required for the vessel of 400 GT and above, and drill rigs and platforms regardless of tonnage, which have rechargeable systems containing ozone-depleting substances. The BMRS ODS Record Book can be ordered on Shipboard Document Online Form.

10. Nitrogen Oxide (NOX) Emissions (MARPOL VI Reg. 13)

10.1 It is prohibited to operate a marine diesel engine with a power output of more than 130 kW, and which is installed, or undergoes a major conversion on or after 01 January 2000, unless it complies with the applicable NOX emission limits and requirements specified in MARPOL Annex VI Reg. 13, which applies to any vessels (including yachts and fishing vessels) irrespective of tonnage.

10.2 Marine diesel engines installed on a vessel must comply, based on the date of vessel construction, with the NOx Tier III emission standards when the vessel is operating in an Emission Control Area (ECA) as specified in MARPOL Annex VI Reg. 13.5.1.2.

10.3 Emergency diesel engines and engines installed in lifeboats, devices, or equipment intended to be used solely for emergencies are exempted from the MARPOL Annex VI Reg. 13 requirements.

10.4 Emissions from fixed or floating platforms and drilling rig engines that are solely dedicated to the exploration, exploitation and associated offshore processing of seabed mineral resources are exempted from the regulations regarding NOx controls. However, any emissions from engines that jointly supply power to exploration and processing machinery and also the platform domestic load are NOT exempted.

10.5 Each engine on board a Barbados vessel subject to MARPOL Annex VI is required to have an associated Engine Technical File. The Technical file shall remain on board the vessel for as long as the engine remains on board and shall be available for inspection by duly authorised officers.

10.6 The Technical File shall include an on-board NOx verification procedure, the parent engine’s emission test report and the Engine International Air Pollution Prevention Certificate (EIAPPC).

10.7 Boilers and gas turbines are not covered under the NOx controls regulations.

11. Sulphur Oxides (SOX) and particulate matter (MARPOL VI Reg. 14)

11.1 The carriage of fuel oil for use on board the vessel with a sulphur content exceeding 0.50% m/m is prohibited under MARPOL Annex VI Reg. 14.1. This prohibition does not apply to non-compliant fuel oil carried for use onboard a vessel with an approved EGCS installed as an alternative means of compliance and to fuel oil carried on board as a cargo.

11.2 The global sulphur limit is a mandatory requirement and is applicable to all vessels on all voyages, covering all fuel carried on board for consumption – this includes fuel oil used in emergency systems (emergency generator, lifeboats, rescue boat, etc.), and concerns about the safety of the vessel and machinery do not exempt the vessel from the requirement to bunker and/or consume compliant fuel oil.

11.3 In ports where the discharge of wash water from open loop EGCS (scrubbers) is not permitted, vessels fitted with open loop/hybrid EGCS may be expected to consume compliant fuel oil or to switch to closed loop mode. Documents related to changeover procedure and records should be kept on board.

11.4 IMO Resolution MEPC.340(77) requires the EGCS Technical Manual (ETM) and Onboard Monitoring Manual (OMM) to be approved by the RO on behalf of Barbados.

11.5 While a vessel is operating within an Sulphur Emission Control Area (SECA) as defined under MARPOL Annex VI Reg. 14.3, the sulphur content of fuel oil used on board that vessel shall not exceed 0.10% m/m as per MARPOL Annex VI Reg. 14.4.

11.6 Vessels using separate fuel oils when operating within a SECA must carry a written fuel oil changeover procedure, developed specifically for the vessel. A record of the changeover operation shall be recorded in the MARPOL Annex VI Record Book.

11.7 The BMSR MARPOL Annex VI Record Book can be ordered on Shipboard Document Online Form.

12. Volatile Organic Compounds (MARPOL VI Reg. 15)

12.1 Tankers subject to vapour emissions control must be fitted with a vapour collection system approved by an RO on behalf of Barbados, within three years after a port/terminal has notified the IMO of its regulation of tanker VOC emissions. See GISIS module for ports or terminals where VOCs are controlled.

12.2 The VOC management plan, required for all tankers carrying crude oil, must be approved by an RO on behalf of Barbados.

12.3 Gas carriers must comply with the requirements of this section only if their loading and containment systems allow safe retention of non-methane VOCs on board, or their safe return ashore.

13. Shipboard Incineration (MARPOL VI Reg. 16)

13.1 All vessels, irrespective of tonnage, must comply with the regulations on shipboard incineration under MARPOL Annex VI Reg. 16. Special rules on incineration under domestic law may apply in some ports and may exist in some special areas. Operation of shipboard incinerators may require permission from individual coastal or port authorities concerned.

13.2 Incinerators installed in accordance with the requirements of MARPOL Annex VI Reg. 16 shall be provided with a manufacturer’s operating manual and personnel responsible for the operation of an incinerator shall be trained to implement the guidance provided in the manufacturer’s operating manual.

13.3 An incinerator on a vessel constructed on or after 01 January 2000, or installed on or after 01 January 2000 must be approved by an RO on behalf of Barbados, taking into account the standard specification for shipboard incinerators as per MARPOL Annex VI Reg. 16.3 and 16.6.1.

14. Fuel Oil Quality - BDN and FONAR (MARPOL VI Reg. 18)

14.1 For every vessel of 400 GT and above, details of fuel delivered for combustion purposes must be documented by means of a Bunker Delivery Note (BDN) in the format specified under Appendix V of MARPOL Annex VI.

14.2 BDNs shall be kept on board for at least 3 years after the delivery of the fuel oil and shall be accompanied by a representative sample (“MARPOL delivered sample”) which is to be sealed and signed by the Master or officer in charge of the bunker operations and retained under the vessel’s control until the fuel oil is substantially consumed, but in any case, not less than 12 months from the time of delivery. Representative samples of fuel already consumed may be retained in an appropriate shore side facility under control of the Company.

14.3 Coastal and port State authorities of a Party to MARPOL Annex VI, as appropriate, may utilise the sampling point(s) which is(are) fitted or designated for the purpose of taking representative sample(s) of the fuel oil being used on board as outlined in IMO Circulars MEPC.1/Circ.864/Rev.1, MEPC.1/Circ.889 and Resolution MEPC.324(75). The competent authority shall take fuel oil samples as expeditiously as possible without causing the vessel undue delays, and the sample must be sealed by the representative of the competent authority in the presence of the vessel's representative and the vessel shall retain a duplicate sample.

14.4 For every vessel of 400 GT and above on scheduled services with frequent and regular port calls which would render compliance with the requirements of this section impracticable, an alternative documentation and sampling storage plan may be approved by the BMSR, after consideration of the circumstances involved and consultation with the affected States concerned.

14.5 Where, despite all reasonable efforts, compliant fuel oil is not received at the scheduled port of call, and no feasible alternative exists, the vessel will be required to prepare and submit a Fuel Oil Non-Availability Report (FONAR) as per Sec. 5 of Resolution MEPC.320(74), which shall be submitted to both the BMSR and the Coastal State authorities of the port(s) of destination.

14.6 When a vessel has presented evidence of the non-availability of compliant fuel oil, the BMSR will subsequently notify the IMO through “MARPOL Annex VI” GISIS module. The following information shall be provided to the BMSR:

.1 a record of actions taken to attempt to achieve compliance;

.2 copies of Bunker Delivery Note(s);

.3 post-bunkering laboratory analysis of drip samples taken to determine the percent concentration of sulphur found within the stemmed fuel oil; and

.4 evidence that the vessel attempted to purchase compliant fuel oil in accordance with its voyage plan and, if it was not made available where planned, that attempts were made to locate alternative sources for such fuel oil and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase.

14.7 Providing the information above does not indemnify the vessel from Port State Control (PSC) action in the event compliant fuel oil could not be obtained. The relevant authorities of a Party to MARPOL Annex VI will consider all relevant circumstances in addition to the evidence provided when determining the appropriate action to take based on the guidance for Port State Control on how to address the provision of non-compliant fuel oil , as per IMO Circular MEPC.1/Circ.881.

14.8 Follow-up actions may be considered when arranging the supply of compliant fuel oil following bunkering of non-compliant fuel oil under a FONAR:

.1 De-bunker any remaining non-compliant fuel oil at the first port where compliant fuel is available; and

.2 Specific preparations to ensure bunker tanks and fuel transfer, treatment and preparation systems are sufficiently cleaned and are suitable for compliant fuel oil without the risk of contamination by residues of non-compliant fuel oil. Such actions may include tank cleaning, system pipelines and equipment flushing or mechanical cleaning.

15. Attained EEDI and Required EEDI (MARPOL VI Reg. 22 and 24)

15.1 Energy Efficiency Design Index (EEDI) represents the equivalent amount of carbon dioxide that a vessel as a whole emits, in relation to the amount of cargo carried per mile sailed.

15.2 The attained EEDI is defined under MARPOL Annex VI Reg. 2.2.3 as the EEDI value achieved by an individual vessel in accordance with MARPOL Annex VI Reg. 22. The attained EEDI should be lower than the required EEDI prescribed in MARPOL Annex VI Reg. 24, which is the maximum value of attained EEDI allowed for the specific vessel type and size.

15.3 The attained EEDI and required EEDI are applicable for a “new ship” as defined in Sec. 4.1.1 above or an existing one which has undergone a major conversion so extensive that it is regarded as newly constructed, which falls into one or more of the categories defined in Sec. 4.2 above.

15.4 The attained EEDI shall be calculated taking into account Resolution MEPC.364(79) and verified by a Barbados RO. The attained EEDI shall be specific to each vessel and shall indicate the estimated performance of the vessel in terms of energy efficiency and be accompanied by the EEDI Technical File that contains the information necessary for the calculation of the attained EEDI and shows the process of calculation. When a vessel may be identified as falling under more than one category listed above, the more stringent criteria in calculations shall apply.

15.5 Starting from 01 April 2022 for all vessels to which requirements of MARPOL Annex VI Reg. 22and 24 apply, the attained EEDI and required EEDI shall be reported to the IMO as follows:

.1 For vessels constructed on or after 1 April 2022 within 7 months from the date if the IEEC Initial Survey; or

.2 for vessels constructed prior to 1 April 2022 by 1 November 2022.

16. Attained EEXI and Required EEXI (MARPOL VI Reg. 23 and 25)

16.1 Energy Efficiency Existing Ship Index (EEXI) is a measure of a vessel’s energy efficiency, expressed in grams of carbon dioxide per amount of cargo carried per mile sailed.

16.2 The attained EEXI shall be calculated as per MARPOL Annex VI Reg. 23. taking into account Resolution MEPC.333(76) and verified by a Barbados RO. The Required EEXI is the maximum value of attained EEXI allowed for the specific vessel type and size and is calculated as per MARPOL Annex VI Reg. 25.

16.3 The attained EEXI and required EEXI are applicable for each existing vessel and each vessel which has undergone a conversion, which fall into one or more of the categories defined in Sec. 4.2 above.

16.4 Where a vessel may be identified as falling under more than one category listed above, the more stringent criteria in calculations shall apply. The process of calculation and the necessary information to produce the EEXI calculation shall be addressed in the vessel specific EEXI Technical File.

16.5 Notwithstanding Sec. 16.2, for each vessel to which MARPOL Annex VI Reg.22 applies, the attained EEDI may be taken as the attained EEXI if the value of the attained EEDI is equal to or less than that of the required EEXI as required by MARPOL Annex VI Reg. 25. In this case, the attained EEXI shall be verified based on the EEDI Technical File and the provisions contained within the EEDI Technical File may be used in place of an EEXI Technical File.

16.6 The EEXI Technical File shall be reviewed and accepted by the Verifier. The Verifier may issue a statement affirming the completion of an EEXI Technical File review; however, such a statement does not form part of the survey requirements of MARPOL Annex VI Reg. 22.

17. Shaft / Engine Power Limitation Systems and use of Reserve of Power
17.1 As per Resolution MEPC.335(76) the following definitions are to be used:

.1 Shaft power means the mechanical power transmitted by the propeller shaft to the propeller hub. It is the product of the shaft torque and the shaft rotational speed. In case of multiple propeller shafts, the shaft power means the sum of the power transmitted to all propeller shafts.

.2 Engine power means the mechanical power transmitted from the engine to the propeller shaft. In case of multiple engines, the engine power means the sum of the power transmitted from the engines to the propeller shafts.

.3 Overridable Shaft Power Limitation (SHaPoLi) system means a verified and approved system for the limitation of the maximum shaft power by technical means that can only be overridden by the vessel's Master or the officer in charge of navigational watch (OICNW) for the purpose of securing the safety of a vessel or saving life at sea.

.4 Overridable Engine Power Limitation (EPL) system means a verified and approved system for the limitation of the maximum engine power by technical means that can only be overridden by the vessel’s Master or OICNW for the purpose of securing the safety of a ship or saving life at sea.

.5 Power reserve means shaft/engine power above the limited power which cannot be used in normal operation unless in the case when SHaPoLi/EPL is unlimited for the purpose of securing the vessel safety.

17.2 Any SHaPoLi and EPL system installation on board of Barbadian vessels shall be approved and verified by a Barbadian RO for compliance with Resolution MEPC.335(76).

17.3 The SHaPoLi/EPL system shall be accompanied by the Onboard Management Manual (OMM) for SHaPoLi/EPL, which shall be verified by a Barbadian RO after a survey verifying the vessel's attained EEXI and shall be permanently on board the vessel for inspection.

17.4 The use of a power reserve is only allowed for the purpose of securing the safety of a vessel or saving life at sea, consistent with MARPOL Annex VI Reg. 3.1 such as: operating in adverse weather and ice-infested waters, participation in search and rescue operations, avoidance of pirates and engine maintenance.

17.5 As per Resolution MEPC.335(76) the use of power reserve (override) shall be allowed only for the following cases:
.1 operating in adverse weather;
.2 operating in ice-infested waters;
.3 participation in search and rescue operations;
.4 avoidance of pirates;
.5 engine maintenance;
.6 description of other reasons consistent with MARPOL Annex VI Reg. 3.1.
17.6 The use of power reserve for engine maintenance as Sec. 17.5.5 above, depends on the engine type and auxiliary systems. Hence, if the maintenance, as per manufacturer's specifications, cannot be done with normal power, the use of a power reserve can be considered for engine maintenance for any applicable regular and irregular maintenance by the RO when approving the OMM.

17.7 The RO, in this case, approves the use of a power reserve for regular maintenance only after assessment of the manufacturer's specifications as per above. In this case, the authority for this should be clearly set out in the OMM and/or the SMS manual, as appropriate.

17.8 Any use of a power reserve should be recorded in the record page of the OMM for SHaPoLi/EPL, signed by the Master and should be kept on board and in the format as per appendix of Resolution MEPC.375(80).

17.9 Where an EPL/ SHaPoLi override is activated but the power reserve is not subsequently used, this event should be recorded in the bridge and engine-room logbooks. The engine-room logbook should record power used during the period when the override was activated. The EPL/SHaPoLi should be reset as soon as possible, and details of the reset should also be recorded in the bridge and engine-room logbooks.

17.10 In case of having used a power reserve, the vessel shall without delay (within 24 hours) notify the RO responsible for issuing the relevant certificate and the competent authority of the relevant port of destination with the information recorded as per Sec. 17.8 above. The notification need not be done to the BMSR.

17.11 On an annual basis by 30 June every year, the RO responsible for issuing the relevant certificate shall report to the IMO Secretariat uses of a power reserve over a 12 month period from 1 January to 31 December for the preceding calendar year with the information recorded in accordance with Sec. 17.8 above. As of the date of issue of this Bulletin , the IMO is yet to develop guidance of the year reporting and the IMO GISIS Module “MARPOL Annex VI” does not allow yet notification required by MARPOL Annex VI Reg. 23 and 25.

17.12 Once the risks have been mitigated, the vessel shall be operated below the certified level of engine power under the SHaPoLi/EPL.

17.13 The SHaPoLi/EPL system should be reactivated or replaced by the crew immediately after the risks have been prevented and the ship can be safely operated with the limited shaft/engine power. The reactivation or replacement of the SHaPoLi/EPL system should be confirmed (e.g. validation of mechanical sealing) with supporting evidence (e.g. engine power log, photo taken at the occasion of resetting the mechanical sealing) by the RO at the earliest opportunity.

17.14 The type of evidence and the timing of submission shall be stated in the OMM and SMS manual. The submission is to be at the earliest opportunity, hence as soon as the use of power reserve and within 24 hours.

17.15 Supporting evidence includes engine power log, photo taken at the occasion of resetting the mechanical sealing and these can be verified remotely by the RO. The BMSR does not request an additional survey for reactivation of the SHaPoLi/EPL after engine maintenance.

17.16 The RO shall carry out an additional survey in case of replacement of the SHaPoLi/EPL systems and any alteration in the systems.

18. Ship Energy Efficiency Management Plan (SEEMP) (MARPOL VI Reg. 26)

18.1 Every vessel of 400 GT and above shall keep on board a ship specific Ship Energy Efficiency Management Plan (SEEMP). This may form part of the ship's Safety Management System (SMS). The SEEMP shall be developed and reviewed, taking into account Resolution MEPC.346(78) and MEPC.388(81).

18.2 The SEEMP shall be provided on board before issuance of the IEEC.

18.3 There are three parts to a SEEMP:
.1 SEEMP Part I. The purpose of this part is to provide an approach to monitor vessel and fleet efficiency performance over time and describe ways to improve the vessel's energy efficiency performance and carbon intensity. Part I of the SEEMP applies to any vessel of 400 GT and above;
.2 SEEMP Part II. The purpose of this part is to provide a description of the methodologies that should be used to collect the Ship Fuel Oil Consumption Data required pursuant to MARPOL Annex VI Reg. 27 and the processes that the vessel should use to report the data to the Barbados RO. Part II of the SEEMP applies to any vessel of 5,000 GT and above.
.3 SEEMP Part III. The purpose of this part is to provide:
i) A description of the methodology that should be used to calculate the vessel's attained annual operational Carbon Intensity Indicator (CII) required by MARPOL Annex VI Reg. 28 (Sec. 19 below);
ii) The processes that should be used to report this value to the Barbados RO;
iii) The required annual operational CII for the next three years;
iv) An implementation plan documenting how the required annual operational CII should be achieved during the next three years;
v) A procedure for self-evaluation and improvement; and
vi) For vessels rated as D for three consecutive years or rated as E, a plan of corrective actions to achieve the required annual operational CII.

18.4 Part III of the SEEMP applies to any vessel of 5,000 GT and above which falls into one or more of the categories defined 4.2 above.

18.5 The SEEMP Part I does not require verification or approval by the Administration/RO. This may form part of the vessel’s SMS.

18.6 The SEEMP Part II should be verified by the nominated Reporting Organisation/Verifier, prior to commencement of Ship Fuel Oil Consumption Data reporting. On successful verification of the amended SEEMP, the Reporting Organisation/Verifier is to issue a Confirmation of Compliance as per MEPC.1-Circ.876 to the vessel, in accordance with MARPOL Annex VI Reg.5.4.5.

18.7 Where there is a change of nominated Reporting Organisation/Verifier, the new Reporting Organisation/Verifier shall obtain the SEEMP Part II verified by the previous Recognised Organisation/Verifier and the related Confirmation of Compliance and take those to their files as a basis for later verifications.

18.8 The SEEMP Parts I & II & III and Confirmation of Compliance shall be kept on board.

18.9          According to the resolution MEPC.347(78) the SEEMP Part III verification process should involve initial verification, periodical verifications and additional verifications (where applicable) :

.1                        Initial verification shall be carried out for each vessel to which regulation 26.3 of MARPOL Annex VI applies;

.2                         Periodical verification shall be carried out if any of the elements in regulation 26.3.1 of MARPOL Annex VI is updated and, in any case, every three (3) years;

.3                        Additional verification shall be carried out in case of one or more vessels rated as D for three (3) consecutive years or one or more vessels rated as E in any calendar year.

18.10           Additionally, periodical and additional company audits should be performed to verify that the vessel is being operated in accordance with the SEEMP Part III as per the following :

.1                        Periodically at least once every 3 years; and

.2                        When one or more vessels in the company obtain an E rating in any calendar year (20XX), an additional company audit should be performed within 30 Nov of the year 20XX + 1; and

.3                        When one or more vessels in the company obtain a D rating in three (3) consecutive years (20XX, 20XX + 1, 20XX + 2) an additional company audit should be performed within 30 Nov of year 20XX + 3.

18.11 Upon successful verification of SEEMP part III, as per above, the RO shall issue to the vessel the Confirmation of Compliance as per Annex of MEPC.347(78).

18.12 Res. MEPC.385(81) will enter into force on 1st August 2025 and, as per MEPC.1/Circ.913, and, for Barbadian vessels which implement the amendments the entry-into-force date (1 August 2025):
.1 Vessels for which MARPOL Annex VI Reg. 27 ( Sec. ) applies shall update their SEEMP to align with the revised reporting requirements. SEEMP should undergo revision and verification by the RO to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2026. Those planning to retrofit flow meters or employ other methodologies should complete these actions within the same time frame;
.2 Data will be collected with the existing level of granularity throughout the entire year of 2025 and, therefore, the data reported at the beginning of 2026 will be based on this consistent level. Data will be collected and reported with the enhanced level of granularity from 1 January 2026 and beyond; and
.3 Vessels delivered on or after 1 August 2025 should collect data at the enhanced level of granularity from the date of delivery and the data reported at the beginning of 2026 will be based on appendix IX of MARPOL Annex VI in the annex to resolution MEPC.385(81), as this provides consistent data collection and reporting for such ships on or after the entry-into-force date.

18.13 For Barbadian vessels which voluntarily implement the amendments early (1 January 2025):
.1 The SEEMP should undergo revision and verification by the RO to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2025 or the delivery date for ships delivered on or after 1 January 2025. Those planning to retrofit flow meters or other methodologies should complete these actions within the same time frame; and
.2 Data will be collected and reported with an enhanced level of granularity throughout the entire year of 2025 and beyond.

19. Collection and Reporting of Ship Fuel Oil Consumption Data (MARPOL VI Reg. 27)

19.1 The Company shall ensure that fuel consumption data and the attained annual operational CII index for the previous year for vessels to which MARPOL Annex VI Reg. 27 and 28 apply is submitted to the Reporting Organisation/Verifier by not later than 31 March. The Statement of Compliance required by MARPOL Annex VI Reg. 6.4 is to be issued by the Reporting Organisation/Verifier by 31 May each year.

19.2 Verified fuel consumption and attained annual operational CII index data is to be uploaded to the IMO Global Integrated Shipping Information System (GISIS) by the Reporting Organisation/Verifier within 1 month after issuing the Statement of Compliance but not later than 30 June each year.

19.3 When preparing the annual fuel consumption reports for their fleet, the Company should be aware that submission is also required for a part of a year if a vessel has left or been accepted to their management, joined, or left the Barbados flag, or has been recycled before 31 December. The reporting of the fuel consumption data is required on the day of completion of the transfer from one flag to another or of the change from one Company to another, or as close thereto as practical.

19.4 Notwithstanding 19.3, where a vessel changes flag to the Barbados at any time after 01 January the attained annual operational CII index shall be reported to the Reporting Organisation/Verifier for the entire 12 months period by 31 March the next year. As of the date of issue of this Bulletin , the IMO is yet to develop the detailed guidance on the end of year reporting where only partial fuel consumption information is available.

19.5 Recognising that on occasions or review of aggregated and verified data cannot be completed due to missing data from previous shipowners and flag States, the BMSR exercises a pragmatic approach in allowing the Reporting Organisation/Verifier additional time to complete the submission and issue a Statement of Compliance based on partial data, with the following conditions:

.1 The SOC shall clearly state that the calculation is based on partial data;
.2 The RO shall records emails sent from the new shipowners to previous shipowners, flag State, and RO/Verifier for request of the data under their responsibility.

19.6 A request for a permit, as per Bulletin 008, for a conditionally issued short term IEEC should be submitted via the RO or Company for every vessel where any of the limit date(s) in Sec. 18.1 cannot be met.

19.7 In accordance with Appendix IX of MARPOL Annex VI, the following information is to be included in the annual cumulative fuel consumption data report:

.1 Identity of the vessel: IMO number, ship type, gross tonnage, net tonnage, deadweight, rated power of each main and/or auxiliary reciprocating internal combustion engine over 130 kW, Attained EEDI (where applicable), Ice Class;
.2 .2 Every type of fuel oil consumed on board for any purpose (engines, boilers, incinerator, inert gas generators, heaters etc.), in metric tonnes. This requirement also applies to ships consuming boil-off gas (BOG) for the purpose of propulsion or shipboard operational needs (the quantity of consumed BOG should be reported in metric tonnes in reference to the original quantity of liquified gas);
.3 distance travelled over ground;
.4 hours underway;
.5 information on the method used to collect fuel consumption data as required by MARPOL Annex VI Reg. 22A.

19.8 Reporting of direct CO2 emission measurements is not mandatory. This method may however be utilised concurrently where the necessary equipment is installed on board to supplement the fuel consumption data report.

19.9 When the Reporting Organisation/Verifier has received fuel consumption data from a ship and verified that it has been collected and reported correctly as per Resolution MEPC.348(78) and MEPC.389(81), a Statement of Compliance shall be issued to the vessel confirming the submission of the data required for the period. The format of the Statement of Compliance can be found in Appendix X of MARPOL Annex VI.

19.10 Each Statement of Compliance will remain valid for the duration of the calendar year when it was issued and for the first five months of the next calendar year.

19.11 Expired Statements of Compliance are not required to be retained beyond their expiration date, once a new statement has been issued and delivered on board.

19.12 In situations where a vessel is not in a position to obtain a new Statement of Compliance following the end of a calendar year due to lay-up, conversion of period of inactivity, the last issued Statement of Compliance shall be retained on board for inspection.

20. Operational Carbon Intensity (MARPOL VI Reg. 28)

20.1 Starting from 01 January 2024, each vessel of 5,000 GT and above which falls into one or more of the categories specified in Sec. 4.2 above shall calculate the attained annual operational Carbon Intensity Indicator (CII) over a 12-month period from 1 January to 31 December for the preceding calendar year, using the data collected in accordance with MARPOL Annex VI Reg. 27.

20.2 The attained annual operational CII for the preceding year shall be reported by the Reporting Organisation/Verifier by 01 April each year.

20.3 Notwithstanding the above, in the event of a change of flag of a ship completed after 1 January 2023, the vessel shall, after the end of the calendar year in which the transfer takes place, calculate and report the attained annual operational CII for the full 12- month period from 1 January to 31 December in the calendar year during which the transfer took place, for verification by the RO.

20.4 The attained annual operational CII shall be verified by the Reporting Organisation/Verifier against the required annual operational CII to determine an operational carbon intensity rating of A, B, C, D or E, indicating the ship’s preceding year performance level, as outlined in MARPOL Annex VI Reg. 28.6.

20.5 A ship rated as D for three consecutive years, or when rated as E, shall develop a plan of corrective actions to achieve the required annual operational CII.

20.6 The SEEMP shall be reviewed to include the above plan of corrective actions accordingly. The revised SEEMP shall be submitted to the Reporting Organisation/Verifier for verification, not later than 1 month after reporting the attained annual operational CII. Implementation of corrective actions shall commence immediately following the verification by the Reporting Organisation/Verifier.

21. EU/UK MRV Reporting

21.1 The EU requires the monitoring, reporting and verification (MRV) of carbon dioxide emissions from maritime transport as applicable, for vessels above 5,000 GT on EU related voyages and to be in compliance with Regulation (EU) 2015/757.

21.2 As a result of the United Kingdom leaving the EU, the EU MRV no longer applies to the UK. However, the UK has adopted with SI 2018/1388 UK MRV regulations, based on the EU MRV, which are applicable for vessels above 5,000 GT trading in or out of any UK ports and reporting shall be done as per UK Marine Information Notice MIN 669 (M+F).

21.3 The EU and UK MRV are in addition to the provisions of MARPOL Annex VI.

21.4 It is anticipated that the EU/UK MRV and MARPOL Annex VI fuel consumption data submission requirements will eventually be aligned to reduce administrative burden, as some vessels will need to report the same data twice. However, so far there are no firm indications of the timescale for alignment of the EU/UK MRV and MARPOL Annex VI requirements.

21.5 Fuel consumption data for voyages between ports in the UK, whilst at berth in any UK ports, between ports in the UK and non-EEA ports and vice-versa shall be included in UK MRV reporting.

21.6 To avoid duplication, fuel consumption data covering voyages between the UK and EEA ports and vice versa shall not be reportable under the UK MRV regulations and shall continue to be submitted as part of EU MRV data.

21.7 Where a Barbados RO acts as a Reporting Organisation/Verifier (DCS) and has been accredited as an MRV verifier, the BMSR has no objection to fuel consumption data and MRV reporting being combined, provided that the combined reports provide all of the information required by MARPOL Annex VI Reg. 22A.

21.8 A Document of Compliance covering the EU/UK MRV fuel consumption data submission shall be provided on board every applicable vessel.

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

1. References
a) Barbados Merchant Shipping Act (CAP 296).
b) Barbados S.I 2001 No. 44 - Shipping (Safe Manning, Watchkeeping and Hours of Work) Regulations, 2001.
c) SOLAS, International Convention for the Safety of Life at Sea.
d) IMO Assembly Resolution A.1047(27), Principles of minimum safe manning, adopted 30 November 2011.
e) Maritime Labour Convention 2006 (MLC).
f) The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, (STCW Convention).
g) The Seafarers’ Training, Certification and Watchkeeping Code (STCW Code).
h) The International Ship and Port Facility Security Code (ISPS Code).
i) Form 159 – Table of Shipboard working Arrangements.
j) Form 12 – Application for Safe Manning Document.
k) IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements and formats of records of seafarers’ hours of work or hours of rest.

2. Purpose

2.1 This Bulletin sets out the measures adopted by the Barbados Maritime Ship Registry (BMSR) to ensure Barbadian vessels comply with Barbados CAP 296 Section 211, Barbados S.I 2001 No. 44 , SOLAS Regulation V/14, IMO Assembly Resolution A.1047(27), MLC, STCW Convention Regulation VIII/2 and STCW Code Section A-VIII/2.

2.2 The requirements of this Bulletin are to ensure that Barbadian vessels are sufficiently, effectively, and efficiently manned to provide safety and security of the vessel, safe navigation and operations at sea, safe operations in port, prevention of human injury or loss of life, the avoidance of damage to the marine environment and to property, and to ensure the welfare and health of seafarers through the avoidance of fatigue.

3. Application

3.1 The safe manning requirements of Section 4 and the Barbados shipboard working arrangements requirements of Section 5, apply to all Barbadian vessels.

3.2 The requirements for a Safe Manning Document (SMD) of Section 5 apply to vessels engaged on international voyages and commercial yachts of 500 GT and greater.

3.3 The requirements for a Safe Manning Document (SMD) of Section 5 do not apply to :
.1 Ships of war and troopships.
.2 Cargo ships of less than 500 gross tonnage.
.3 Vessels not propelled by mechanical means.
.4 Wooden ships of primitive build.
.5 Pleasure yachts not engaged in trade.
.6 Fishing vessels.

4. Safe Manning Requirements

4.1 The Company and the Master shall ensure that all persons joining a vessel or unit are immediately given appropriate familiarization training with respect to the vessel for emergency, safety, security and environmental responsibilities in addition to their respective duties and functions.

4.2 The Company and the Master of a vessel shall ensure that watch standards and arrangements as outlined in STCW Convention Chapter VIII are always maintained.

4.3 The Company and the Master shall meet the relevant requirements of MLC 2006 and STCW Convention Chapter VIII with respect to periods of rest and prevention of alcohol abuse for any person assigned or performing designated safety, prevention of pollution and security duties.

4.4 Vessel’s Cook

.1 In all cases where the total manning consists of 10 persons or more, there shall be a dedicated certified cook.

.2 As per MLC A3.2.5, on vessels operating with a prescribed manning of less than 10 the company should have one person designated as the Cook. If the appointed person does not hold a vessel’s cook certificate, then the person is to be trained or instructed in areas including food and personal hygiene as well as handling and storage of food on board vessel.

4.5 Ship Security Officer (SSO)

.1 All persons, onboard vessels to which the International Code for the Security of Ships and Port Facilities (ISPS Code) applies, shall have received security training in accordance with STCW Convention Regulation VI/6. One appropriately trained person shall be designated as the Ship Security Officer (SSO) as required under the ISPS Code.

.2 The SSO may be the Master, or any other person designated by the Company. The designated officer shall meet the training requirements in accordance with the provisions of STCW Regulation VI/5 and shall be directly responsible to the Master (if the SSO is not the Master) and the Company Security Officer (CSO) in compliance with vessel’s SMS.

.3 The Company shall ensure that one of the capacities proposed to be included on the SMD is also able to carry out the duties of the SSO.

4.6 Persons Assigned Electronic and Electrical Duties

.1 A vessel powered by main propulsion machinery of 750 kW propulsion power or more may carry persons who are specifically assigned the specific duties, tasks and responsibilities relating to electrical and electronic tasks. If required to be carried, these persons should be certified as Electro-Technical Officers or Electro-Technical Ratings and satisfy the requirements of STCW Regulations III/6 or III/7 respectively.

.2 The SMD need only include these persons if they are additional to the Engineering Officers and they have been assigned shipboard duties to satisfy the requirements of the maintenance of a safe engineering watch, emergency as specified in the Muster List or operation and maintenance of the vessel’s electrical, electronic and control systems.

4.7 Person Designated for Safety

.1 All vessels shall have a person, who may be the Master, who has responsibility for implementation of and compliance with the vessel’s occupational safety and health policy and programme.

4.8 Manning During Hours of Darkness and Restricted Visibility
.1 Companies shall ensure that the vessels have sufficient trained navigational watch-keeping personnel to ensure that the navigation control room/bridge is manned by at least 2 watch keepers during hours of darkness and conditions of restricted visibility. One of these watch keepers shall be a Deck Officer. 

4.9 Manning Onboard Specific Ship

.1 Vessels with propulsion power of less than 750 kW

i) Vessels with propulsion power of less than 750 kW are not required to have an engineer certificated in accordance with STCW Convention. However, such vessels must have at least one person, other than the Master, who is trained and certified to operate the machinery onboard the vessel. If the training is not in accordance with STCW Convention then the person should have documentary evidence of his training and capability to perform the assigned tasks.

.2 Vessels with Unattended Machinery Space (UMS)

i) The UMS notation assigned by a Classification Society shall be considered when determining whether the machinery space can be unattended.
ii) If the manning of a vessel with propulsion power of more than 3000kW is based on UMS notation, then the vessel shall carry an additional watch-keeping engineer officer if the UMS systems are inoperative for more than seven days. The Company shall notify affected Classification Society and the BMSR of the related equipment failure affecting the UMS notation.

.3 Tankers

i) Companies operating tankers shall ensure that all officers, ratings, and persons involved in cargo operation hold a basic training in accordance with the provisions of STCW requirements relating to the type of tanker on which the person is serving.
ii) Officer shall have the Certificate of Proficiency STCW V/1-1 and V/1-2 endorsed by the BMSR.

.4 Vessels Fitted with ECDIS

i) The Company should ensure that if the vessel is fitted with ECDIS, the Master and navigating officers have appropriate generic and type specific ECDIS training.
ii) The Master shall ensure that all affected officers have documentary evidence ECDIS training prior to be assigned their onboard navigational duties.

4.10 Employment of Additional Seafarers by the Company.

.1 A Company may decide to employ more seafarers than stipulated in the SMD. These seafarers shall be trained to a level appropriate to their duties in addition to having the minimum basic training for emergency, safety, and survival. The statutory certificates will detail the maximum number of persons on board and there must be sufficient accommodation satisfying the MLC 2006 (as amended) standards for that number.

.2 There are a number of capacities that are not identified in STCW and accordingly the SMD may not refer to them. The Company should decide on their qualification or experience in accordance with the objectives of their Safety Management System but if the persons are employed and assigned shipboard safety, security, environmental protection, cargo operations or watch-keeping duties, the person must complete STCW basic training before joining the vessel and receive shipboard familiarization training before being assigned their shipboard tasks/duties.

4.11 Employment of Seafarers for vessel with no SMD requirements

.1 On a vessel that is not required to comply with the SMD requirements, either because not engaged on international voyages or exempted as per Sec. 3.3 above, the seafarers are not required to have STCW qualifications but they shall be trained to a level appropriate to their duties in addition to having the minimum basic training for emergency, safety, and survival.
.2 The Company should decide on their qualification or experience in accordance with the objectives of their Safety Management System but if the persons are employed and assigned shipboard safety, security, environmental protection, cargo operations or watch-keeping duties, the person must complete STCW basic training before joining the vessel and receive shipboard familiarization training before being assigned their shipboard tasks/duties.
.3 The statutory certificates will detail the maximum number of persons on board and there must be sufficient accommodation satisfying the MLC 2006 (as amended) standards for that number.

5. Watchkeeping

5.1 The company responsible for the operation of the vessel shall ensure that all watch standers on board its vessels adhere to the minimum limits of hours of rest in accordance with international regulations.

5.2 For vessels of 3000 GT and above and propulsion power of 3000 KW and above the Master and the chief engineer should not be part of the vessel watches and a three-watch system should be adopted for both the deck and engine watches.

5.3 For vessels of less than 3000 GT and with propulsion power of less than 3000 KW two-watch system may be adopted provided that the requirements for work and rest hours are met.

5.4 For deck watches that are normally limited in numbers, a routine for providing additional assistance without delay shall be established and standby personnel shall be identified and immediately contactable.

5.5 On vessels with periodically unattended machinery spaces (UMS) notation and of less than 2000 KW propulsion power and in case of limited number of cabins and bunks a watch with only the Chief engineer may be adopted during the daytime (0800-2000) provided that the requirements for work and rest hours are met and that additional assistance without delay is established.

5.6 When the engine watch is only with the Chief engineer, the Company shall anticipate the number of hours that the Chief engineer must devote to unscheduled work in case of emergency. As soon as practicable after the normal situation has been restored, the Chief engineer shall have an adequate period of rest.

6. Radio Watchkeeping

6.1 On Barbadian vessels with the GMDSS, all officers with radio duties shall hold a valid BMSR endorsed GMDSS radio operators Certificate of Competency (COC), as per STCW IV/2. Therefore, a Barbadian vessel shall have on board at least two officers to carry out radio duties in their own respective watch, when a 2-watch system is in place.

6.2 In case of a 3-watch system, to ensure a continuous radio watch while at sea, the third watch should either be supported by one of the two officers as per Sec.

6.1 above or manned with a third officer who also holds a BMSR endorsed GMDSS radio operators COC.

6.3 When the officers of Sec. 6.1 above provide support for the third watch their total hours of work and rest are to be maintained at all times.

6.4 The BMSR endorsed GMDSS radio operators COC is to be adequate for the Sea Areas (A1, A2,A3, A4) on which the vessel operates.

7. The Barbados Shipboard Working Arrangements

7.1 In compliance with the Barbados S.I 2001 No. 44 and with IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements, the company shall produce a shipboard working arrangements (SWA) of hours of work and rest for all seafarers on board which includes regular watchkeeping duties and non-watchkeeping duties at sea and in port.

7.2 The SWA shall be based on the BMSR format as per Form 159 – Table of Shipboard Working Arrangements, which is to be signed by the Master and be posted or maintained to be easily accessible and capable of being verified by Barbados Appointed Nautical Inspectors and Port State Control Officers.

7.3 A Copy of the Form 159 – Table of Shipboard Working Arrangements shall be submitted to BMSR in order to verify the vessel is safely manned.

7.4 Records of each seafarers’ daily hours of work or rest shall be maintained on board and with a model format as per Appendix 4 of the IMO/ILO Guidelines for the development of tables of seafarers’ shipboard working arrangements.

8. Safe Manning Document - Requirements

8.1 The Company shall make an application for a SMD following an assessment that takes into consideration Sections 8.2, 8.3 and 8.4 of this Bulletin.

8.2 The minimum safe manning of a vessel should be established by taking into account all relevant factors, including the following:

.1 size and type of vessel;

.2 number, size and type of main propulsion units and auxiliaries;

.3 level of vessel automation;

.4 construction and equipment of the vessel;

.5 method of maintenance used;

.6 cargo to be carried;

.7 frequency of port calls, length, and nature of voyages to be undertaken;

.8 trading area(s), waters, and operations in which the vessel is involved;

.9 extent to which training activities are conducted on board;

.10 degree of shoreside support provided to the vessel by the company;

.11 applicable work hour limits and/or rest requirements; and

.12 the provisions of the approved Ship's Security Plan.

8.3 In determining the minimum safe manning of a vessel the following principles should be observed.

.1 The capability to:

i) Maintain safe navigational, port, engineering, and radio watches in accordance with regulation VIII/2 of the STCW Convention, as amended, and also maintain general surveillance of the vessel;
ii) moor and unmoor the vessel safely;
iii) manage the safety functions of the vessel when employed in a stationary or near stationary mode at sea;
iv) perform operations, as appropriate, for the prevention of damage to the marine environment;
v) maintain the safety arrangements and the cleanliness of all accessible spaces to minimize the risk of fire;
vi) provide for medical care on board vessel;
vii) ensure safe carriage of cargo during transit;
viii) inspect and maintain, as appropriate, the structural integrity of the vessel;
ix) operate in accordance with the approved Ship's Security Plan;

.2 The ability to:

i) operate all watertight closing arrangements and maintain them in effective condition, and also deploy a competent damage control party;
ii) operate all onboard firefighting and emergency equipment and life saving appliances, carry out such maintenance of this equipment as is required to be done at sea, and muster and disembark all persons on board;
iii) operate the main propulsion and auxiliary machinery including pollution prevention equipment and maintain them in a safe condition to enable the vessel to overcome the foreseeable perils of the voyage.

8.4 The following onboard functions, when applicable, should also be taken into account:

.1 ongoing training requirements for all personnel, including the operation and use of fire fighting and emergency equipment, life-saving appliances, and watertight closing arrangements;

.2 specialized training requirements for particular types of vessels and in instances where crew members are engaged in shipboard tasks that cross departmental boundaries;

.3 provision of proper food and drinking water;

.4 need to undertake emergency duties and responsibilities; and

.5 need to provide training opportunities for entrant seafarers to allow them to gain the training and experience needed.

9. Safe Manning Document - Temporary Exemption

9.1 In cases of Force Majeure, where the manning level falls below that of the SMD e.g., due to crew illness, unexpected repatriation on compassionate grounds etc., the vessel may as a temporary measure, sail with one person less than that stipulated in the SMD and in exemption of SOLAS V/14 provisions. This does not apply to the capacities of Master and chief engineer.

9.2 In all such cases the Master, in consultation with the chief engineer where the shortage relates to an engineer officer, should ensure that there is a continuity of watches by duly qualified persons without affecting the statutory minimum periods of rest.

9.3 The shortage must be filled at the earliest opportunity and in any case not later than fourteen (14) days or at the next port if the intended voyage is more than fourteen (14) days.

9.4 In circumstances of exceptional necessity, as per MLC Standard A3.2.6, where a Company is unable to achieve the minimum manning due to the lack of a duly certificated Cook, a temporary exemption from the provision of MLC Regulation 3.2.3 may be granted and permitting a non-fully qualified cook to serve in a specified vessel for a specified limited period, until the next convenient port of call or for a period not exceeding 1 month, provided that the person to whom the dispensation is issued is trained or instructed in areas including food and personal hygiene as well as handling and storage of food on board vessel.

9.5 The BMSR must be notified and provided with the following information, which must also be duly recorded in the Official Logbook:

i) Name and IMO Number of the vessel
ii) Capacity and rank of the officer
iii) Reason for exemption
iv) No. of crew onboard, excluding the affected officer
v) The Port of departure and arrival with the shortage
vi) Date of departure and ETD

10. Safe Manning Document – Application

10.1 The Company shall submit of a proposal for minimum safe manning defining the nature of the operation of the vessel, taking into account the requirements of Section 8 of this Bulletin.

10.2 The minimum SMD can be issued with a designation of “Unlimited” or “Limited” trading areas, for those vessels which have operations to a limited geographical area.

10.3 “Limited” trading areas are when:

.1 The voyages do not exceed 24 hours between ports of calls; or

.2 Voyages are within 200 nm from the nearest shore; or

.3 Enclosed areas.

10.4 Enclosed areas, may include, but are not limited to:

.1 Mediterranean Sea, Red Sea, Caspian Sea, Black Sea, Azov Sea, North Sea, Gulf of Aden, Baltic Sea, Persian Gulf;

.2 Caribbean Sea (restricted areas 1, II, and/or III, as defined in CCSS Code);

10.5 A vessel which operates part of the time within a limited areas and part of the time on more extensive voyages may elect to have two (2) SMDs.

10.6 To apply for an SMD the Form 12 – Application for Safe Manning Document shall be used.

10.7 The fields of the SMD application Form are to be completed with accurate information. If an item does not apply to the vessel, “N/A” is to be placed in the space. The application is to be completed and signed by a person appointed by the Company.

10.8 A guideline of the minimum manning levels required by the BMSR for unlimited and limited trading areas is provided in Appendix A of this Bulletin.

10.9 If there are special considerations that may affect manning levels, they should be included on the form at the bottom of the second box where it says “Comments/Special Considerations or vessel configurations that may affect manning.” This could include operations such as coastal or domestic trade, number of cabins and/or bunks on the vessel, the vessel’s intended port schedule, etc.

10.10 In assessing minimum deck manning, the BMSR shall consider the vessel’s dimensions, layout of crew accommodation, and internal communications systems, all of which affect crew capabilities and response reactions, the vessel’s propulsion power, the engine room layout and proximity to boiler rooms, etc.

10.11 In this respect the BMSR may increase the scale of manning from that proposed by the Company. The BMSR will not normally reduce the manning level from that proposed by the Company unless it considers certain references in the SMD application proposed by the Company are unnecessary or inconsistent with standard practices.

11. Safe Manning Document – Validity

11.1 In compliance with the requirements of Annex 5 of the IMO Assembly Resolution A.1047(27) an SMD issued to a vessel shall have a validity of 5 years from the date of issue.

11.2 A new SMD is also required to be issued when:

i) there is a change of vessel’s name; or
ii) there is a change of trading area; or
iii) change of ISM Managers; or
iv) any other changes/alterations to the vessel, its crew, construction, machinery, equipment, operation, maintenance, or management that affects the manning level required to continue safe operations.

12. Port State Control

12.1 The STCW Convention, Regulation I/4, enables port State authorities to verify conditions on any vessel, particularly as to the qualifications and ability of personnel on board. Port State authorities may pay particular attention to the following:

.1 that all seafarers on board who are required to be certificated hold an appropriate Barbados certificate or provide documentary proof that an application for an endorsement has been submitted to the BMSR; and/or

.2 the numbers and certificates of the seafarers serving on board conform to the applicable safe manning requirements of the BMSR.

12.2 In accordance with section A-I/4 of the STCW Code, port State authorities may assess the ability of the seafarers of the vessel to maintain watchkeeping standards as required by the STCW Convention, if there are clear grounds for believing that such standards are not being maintained because of any of the following having occurred:

.1 the vessel has been involved in a collision, grounding, or stranding;

.2 there has been a discharge of substances from the vessel when underway, at anchor or at berth, which is illegal under any international convention;

.3 the vessel has been manoeuvred in an erratic or unsafe manner whereby routing measures adopted by the IMO or safe navigation practices and procedures have not been followed; or

.4 the vessel is otherwise being operated in such a manner as to pose a danger to persons, property, or the environment.

12.3 Regulation 2.7 of the MLC requires vessels to have a sufficient number of seafarers employed on board to ensure that they are operated safely, efficiently, and with due regard to security under all conditions, taking into account concerns about seafarer fatigue and the particular nature and conditions of the voyage. Port State Control (PSC) officers are entitled to verify that this is the case when there are grounds for carrying out a more detailed inspection.

Appendix A

The tables given below are provided for guidance/reference and are samples only, to assist Owners/Managers when making a proposal for minimum safe manning levels.

Deck Department

(1) See Sec. 10.3 
(2) BMSR may request one ONW be added, following review of vessel’s operational area and type of ship.
(3) BMSR will accept alternative manning for ranks II/4 and II/5 as far as the total number is as per table.

Engine Department

(4) See Sec. 10.3
(5) For UMS notation ONLY, BMSR might accept an OICEW in lieu of the Second Engineer III/2.
(6) Manning may be reduced by one at this rank if vessel classed with UMS.
(7) BMSR may request one additional one at this rank.
(8) Tankers of 1000 GT or more shall add one additional Engineering Watch Rating.
(9) BMSR will accept alternative manning for ranks III/4 and III/5 as far as the total number is as per table.
(10) Manning may be reduced by one see Sec. 5.5.
(11) See Sec. 4.9.1.
(12) BMSR might accept an OICEW in lieu of the Chief Engineer III/3.

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

Download Bulletin  

a) International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS).
b) ISM Code, International Safety Management Code, as amended.
c) Form 34 – International Safety Management (ISM) Code Declaration.
d) IMO Circular MSC-MEPC.7/Circ.6 Guidance on the qualifications, training, and experience necessary for undertaking the role of the Designated Person under the provisions of the International Safety Management (ISM) Code.
e) IMO Circular MSC-MEPC.7/Circ.8 Revised guidelines for the operational implementation of the International Safety Management (ISM) Code by Companies.
f) Bulletin 008 – Permits Exemptions and Equivalences Rev.2.0.
g) Maritime Labour Convention (MLC), 2006.
h) The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW).
i) IMO Resolution A.1188(33) 2023 Guidelines on the implementation of the International Safety Management (ISM) Code by Administrations.
j) IACS PR 9 Procedural Requirements for ISM Code Certification.
k) IMO Circular MSC-FAL.1/Circ.3 Guidelines on Maritime Cyber Risk Management.

2. Purpose

a) This Bulletin provides information on the application of the International Safety Management (ISM) Code to Barbadian vessels.

3. Application

3.1 The ISM Code, under the provisions of Chapter IX of SOLAS, is mandatory for the following vessels engaged in international voyages:
.1 Passenger ships including Passenger Yachts, and passenger high-speed craft, regardless of tonnage;
.2 Oil tankers, chemical tankers, gas carriers, bulk carriers, cargo high-speed craft, special purpose ships, commercial yachts of 500 gross tonnage and upwards; and
.3 Other cargo ships, Self-propelled Mobile Offshore Units (MOUs) and Dynamically Positioned (DP) vessels of 500 gross tonnage and upwards.
3.2 A Floating Production Storage and Operations Unit (FPSO), Floating Storage and Offloading Unit (FSO), Floating Production Unit (FPU), Floating Storage Unit (FSU), Mobile Offshore Storage Unit (MOSU), Mobile Offshore Drilling Units (MODUs), and similar units are exempt from ISM Code compliance:
.1 if the propulsion system is removed or disabled; or
.2 if the propulsion system functions, the unit is on a fixed station for an extended period and the propulsion equipment will only be used in an emergency or to reposition or
.3 service the unit under a “single voyage exemption” with no cargo on board.

4. Definitions

4.1 Company is the owner of the vessel or any other organisation or person such as the manager, or the bareboat charterer who has assumed the responsibility for the operation of the vessel from the Shipowner and who, on assuming such responsibility, has agreed in writing to take over all the duties and responsibilities imposed by the ISM Code.
4.2 Designated Person or Designated Person Ashore (DPA) is the person ashore appointed by the Company under its Safety Management System, having direct access to the highest level of management with whom direct communications may be had at any time. The responsibility and authority of the DPA must include but is not limited to, monitoring the safety, security, and pollution prevention aspects of each vessel’s operation under the Company’s control and ensuring that adequate resources and shore-based support are provided. See IMO Circular MSC-MEPC.7/Circ.6 for the qualifications, training and experience necessary for undertaking the DPA role.
4.3 Safety Management System (SMS) is a structured and documented system enabling Company personnel to effectively implement the Company safety and environmental protection policy.

5. Communication to the BMSR (ISM Code Sec. 3)

5.1 When the Company, as defined in Sec. 4.2, is other than the Owner, at registration the Owner shall notify the BMSR of the appointment of the Company and DPA by sending Form 34 by email to registry@barbadosmaritime.com. Thereafter, Form 34 is to be issued anytime a new Company is appointed.
5.2 For changes of the DPA the notification can be made simply by email to registry@barbadosmaritime.com.
5.3 Owners of vessels to which the ISM Code applies shall still appoint a shore-based point of contact for the BMSR using the same procedures outlined in Sec. 5.1 above.

6. Development of plans for shipboard operations (ISM Code Sec. 3)

6.1 Companies shall establish safety objectives and accordingly develop, implement and maintain an SMS which includes functional requirements as listed in section 1.4 of the ISM Code and in accordance with MSC-MEPC.7/Circ.8.
6.2 The Company should establish procedures, plans and instructions, including checklists as appropriate, for key shipboard operations concerning the safety of the personnel, vessel and protection of the environment. The various tasks should be defined and assigned to qualified personnel.
6.3 Companies shall ensure full implementation and compliance as part of their SMS where MLC and STCW requirements overlap with those of the ISM Code. These provisions include medical certification, training, qualifications, BMSR endorsements, hours of work and rest, manning levels and medical care on board and ashore.
6.4 The SMS shall define and document the Master's responsibility with regard to reviewing the SMS and reporting its deficiencies to the shore based management and include a statement that its contents do not remove the Master’s authority and responsibility to take such steps and issue any orders, whether or not they are in accordance with the contents of the documentation, which the Master considers to be necessary for the preservation of life; the safety and security of the vessel, crew and cargo, and the protection of the marine environment.
6.5 The SMS shall ensure implementation of the measures of the Ship Security Plan (SSP), the Shipboard Oil Pollution Emergency Plans (SOPEPs) and Marine Pollution Emergency Plans (SMPEPs) and address Cyber risks in compliance with MSC-FAL.1/Circ.3. The SMS might also include the Ship Energy Efficiency Management Plan (SEEMP).
6.6 The SMS shall include systematic maintenance plans to ensure that items and systems are covered by class and statutory surveys and to ensure that the vessel’s condition is always satisfactorily maintained and procedures to inform the BMSR at Ops@barbadosmaritime.com with immediate effect in case of any defect found on board for the request of appropriate permission as per Bulletin 008.
6.7 The Company SMS shall include a means for documenting corrective actions taken to rectify deficiencies and nonconformities identified during internal audits, external audits, surveys and PSC and flag State inspections. Notification given to the designated RO on the corrective actions taken and measures to prevent their recurrence must also be documented.
6.8 The SMS shall contain procedures to ensure that non-conformities, observations and hazardous occurrences are reported to the responsible person of the management. The Company should have a system in place for recording, investigating, evaluating, reviewing and analysing such reports, and to take action as appropriate.

7. Internal Audit

7.1 As per Sec. 12 of the ISM Code, the Company shall carry out internal safety audits on board and ashore at intervals not exceeding twelve (12) months to verify whether safety and pollution-prevention activities comply with the SMS.
7.2 The internal audits are in addition to external audits carried out by the Recognised Organisation issuing the DOC and SMC.
7.3 In exceptional circumstances, this interval may be exceeded by not more than three (3) months. Request for extension shall be submitted to the BMSR at Ops@barbadosmaritime.com as per Bulletin 008.

8. Certification and verification

8.1 All Barbadian vessels shall be operated by a Company which has been issued with a Document of Compliance (DOC) on behalf of Barbados and which shall not exceed five (5) years. A copy of the DOC shall be placed on board of each Barbadian vessel managed by the Company.
8.2 The DOC shall be issued by a Barbadian Recognised Organisation (RO) only to Companies that manage or have already expressed interest in registering and managing a vessel, hence in possession of the BMSR “Statement to intent to register” letter.
8.3 All Barbadian vessels shall be issued with a Safety Management Certificate (SMC) by an RO and such SMC shall not exceed five (5) years.
8.4 DOC and SMC are to be issued by a Barbadian RO in compliance with Res. A.1188(33) and IACS PR 9, and the certification process normally involves the following steps: interim verification; initial verification; annual (DOC) or intermediate verification (SMC); renewal verification; and additional verification.
8.5 An Interim DOC is issued for a period not exceeding 12 months and when:
.1 The Company is newly established; or
.2 New ship types are to be added to an existing DOC.
8.6 An Interim SMC is issued for a period not exceeding 6 months and when:
.1 It is a new vessel on delivery;
.2 A Company takes on responsibility for the operation of a vessel which is new to the Company; or
.3 When a vessel changes flag.
8.7 The BMSR, in special cases, might extend the validity of an Interim SMC only for a further period which shall not exceed 6 months from the date of expiry.
8.8 Renewal verification audits must be performed before the validity of the DOC and the SMC expires. They may be carried out within three months before the expiry date of the DOC or the SMC.
8.9 If a vessel at the time when an SMC expires is not in a port in which it is to be verified, the BMSR may extend the period of validity of the SMC, but this extension should 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 then only in cases where it appears proper and reasonable to do so.
8.10 No SMC should be extended for a period of longer than three (3) months, and the vessel to which an extension is granted should 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 SMC. When the renewal verification is completed, the new SMC shall be valid to a date not exceeding five (5) years from the expiry date of the existing SMC before the extension was granted.
8.11 Request for extension of the SMC shall be submitted to the BMSR at Ops@barbadosmaritime.com as per Bulletin 008.

9. Flagging in with BMSR

9.1 The scope and type of audit for change of flag shall be done on site/on board as per Annex 5 of IACS PR 9 for a Company and those as per Annex 5 of IACS PR 9 for a vessel.
9.2 When due the location of the vessel the audit cannot be carried out on board the RO shall contact the BMSR for permission to carry the audit in remote, where such request shall be submitted to the BMSR at Ops@barbadosmaritime.com as per Bulletin 008.
9.3 When a Company is to be issued with a Barbadian DOC, at the change of flag, the RO shall carry out an additional audit on site, to verify the availability of BMSR instructions and their incorporation into the SMS. The Barbadian DOC shall have the same expiry date as the DOC issued on behalf of the other flag State(s).
9.4 When the Company audit cannot be carried out on site for any unforeseen reasons RO shall contact the BMSR for permission to carry the audit in remote, where such request shall be submitted to the BMSR at Ops@barbadosmaritime.com as per Bulletin 008.
9.5 When a vessel is to be issued with a Barbadian SMC, at the change of flag, the RO shall carry out an Interim audit on board as required by Sec. 14.4 of the ISM Code and issue an interim SMC. The BMSR, in special cases, might allow Interim audit to be carried out remotely.

Revision History:

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

1. References

a) The International Convention for the Control and Management of Ships' Ballast Water and Sediments, 2004 (BWM Convention).

b) IMO Circular BWM.2/Circ.62 Guidance on contingency measures under the BWM Convention.

c) IMO Circular BWM.2-Circ.80 Guidance on ballast water record keeping and reporting.

d) IMO Circular BWM.2/Circ.70/Rev.1, 2020 Guidance for the commissioning testing of ballast water management systems.

e) IMO Circular BWM.2/Circ.42/Rev.2, 2020 Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines (G2)

2. Purpose

2.1 This Bulletin provide the requirements for implementing the BWM Convention, entered into force globally on 8 September 2017.

3. Application

3.1 This Bulletin applies to all Barbadian vessels in accordance with Article 3 of the BWM Convention.

3.2 The BWM Convention does not apply to those vessels that:

.1 Are not designed or constructed to carry ballast water (Article 3.2(a));
.2 Operates only in waters under the jurisdiction of their Flag State, unless discharge of ballast water is considered to be a threat to the environment, human health, property or resources, or those of adjacent or other States (Article 3.2(b));
.3 Operates only in waters under the jurisdiction of another State which is a Party to the Convention, subject to authorisation of the Coastal State (Article 3.2(c));
.4 Operates only in waters under the jurisdiction of another State which is a Party to the Convention and on the high seas, subject to authorisation of the Coastal State (Article 3.2(d));
.5 Are warships, naval auxiliaries or other vessels owned or operated by a State and on governmental non-commercial service (Article 3.2(e));
.6 Use permanent ballast in sealed tanks, not subject to discharge (Article 3.2(f)).

4. Background

4.1 Ballast water may be taken onboard by vessels for stability and can contain thousands of aquatic or marine microbes, plants and animals, which are then carried across the globe. Untreated ballast water released at the vessel’s destination could potentially introduce a new invasive marine species. Hundreds of such invasions have already taken place, sometimes with devastating consequences for the local ecosystem.

4.2 The BWM Convention, entered into force on 08 September 2017, aims to prevent the spread of harmful aquatic organisms from one region to another, by establishing standards and procedures for the management and control of vessels’ ballast water and sediments.

4.3 The BWM Convention regulations are divided in to five sections, where section D sets the Standards for Ballast Water Management, specifically:

.1 Regulation D-1 (Standard D1) Ballast Water Exchange Standard – Vessels performing Ballast Water exchange shall do so with an efficiency of 95 per cent volumetric exchange of Ballast Water. For vessels exchanging ballast water by the pumping-through method, pumping through three times the volume of each ballast water tank shall be considered to meet the standard described. Pumping through less than three times the volume may be accepted provided the vessel can demonstrate that at least 95 percent volumetric exchange is met.
.2 Regulation D-2 (Standard D2) Ballast Water Performance Standard - Vessels conducting ballast water management shall discharge less than 10 viable organisms per cubic metre greater than or equal to 50 micrometres in minimum dimension and less than 10 viable organisms per millilitre less than 50 micrometres in minimum dimension and greater than or equal to 10 micrometres in minimum dimension; and discharge of the indicator microbes shall not exceed the specified concentrations.

5. Standard D2 - IMO and BMSR deadlines

5.1 Standard D1 is being phased out and by 08 September 2024 all vessels must meet Standard D2.

5.2 The BMSR is now taking a drastic approach for the implementation of Standard D2 and will issue any permit for an extension of compliance with Standard D2 maximum until the 8th of August 2024.

5.3 Vessels which have a IBWMC renewal after the 08 August but before the 08 September are not subject to the Sec. 5.2 above.

6. Exceptions and Exemptions

6.1 While the general scope of application covers virtually any vessel provided with ballast tanks, the BWM Convention also provides for possible exceptions, exemptions, or equivalent compliance methods, each with specific criteria and conditions to be met.

.1 Regulation A-3 of the BWM Convention allows exceptions to the requirements of the Regulation B-3 for:
.2 ensuring the safety of the vessel in emergency situations;
.3 accidental damage to the vessel;
.4 the purpose of avoiding or minimizing pollution;
.5 uptake and discharge on the high seas of same ballast water and sediments; or
.6 discharge of ballast water and sediments from a vessel at the same location where the ballast water originated, and provided that no mixing with unmanaged ballast water and sediments from other areas has occurred.

6.2 Regulation A-4 of the BWM Convention allows permanent exemptions to any requirements to apply regulations B-3 or C-1, in addition to those exemptions contained elsewhere in this Convention, but only when they are:

.1 granted to a vessel or vessels on a voyage or voyages between specified ports or locations; or to a vessel which operates exclusively between specified ports or locations;
.2 effective for a period of no more than five years subject to intermediate review;
.3 granted to vessels that do not mix ballast water or sediments other than between the ports or locations specified in Sec. 6.2.1 above; and
.4 granted based on the Guidelines on risk assessment developed by the IMO.

7. BWMS initial commissioning and testing

7.1 For BWMS installed on board Barbadian vessels:

.1 A test confirming that the installed BWMS meets the required performance standard shall be conducted to the satisfaction of the attending RO surveyor, as per BWM.2/Circ.70/Rev.1.
.2 An effluent test confirming the BWMS discharge meets Regulation D-2 standards shall be completed in accordance with the maker’s recommendations or where appropriate laboratory facilities are available locally. Methodologies and approaches to sampling and analysis testing are to be done as per BWM.2/Circ.42/Rev.2.

8. Ballast Water Management System Failures

8.1 Any BWMS failure must be reported to the BMSR or vessel’s RO without delay. A brief description of the failure along with a proposed BWMS repair plan must also be communicated in a timely manner. The malfunctioning BWMS must be recorded in the Ballast Water Record Book (BWRB). When the repairs are concluded.

8.2 Where the vessels have to manage non-compliant ballast water discharges, the port State control authorities must be contacted by the vessel or company to discuss contingency measures in line with BWM.2/Circ.62.

8.3 The BMSR will issue a permit for Ballast Water Exchange (BWE) Standard D1, in lieu of using the BWMS (Standard D2) when this method is included as a contingency measure in the vessel’s approved BWMP. Concurrence from the coastal State must be obtained before this option is used.

9. Ballast Water Record Books

9.1 Ballast Water Record Books (BWRB) are available for purchase from the BMSR Ship Document Online Form.

9.2 The BMSR BWRB first revision was issued in compliance with Appendix II “Form of ballast water record book” of the BWM Convention, which will be valid until the 01/Feb/2025.

9.3 The new revision of the BMSR BWRB is instead based on the new revision of the Appendix II, applicable from 02/Feb/2025, which totally replace the previous form, and which implements the new amendments as per BWM.2-Circ.80, which gives examples of Ballast Water Record Book entries, ballast water reporting form and tank-by-tank log form.

9.4 The new revision of the BMSR BWRB also include BWM.2-Circ.80 examples of Ballast Water Record Book entries to help officers to correctly populate the entries.

Revision History:

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

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.

Revision History

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

1. References

• a) 1982 United Nations Convention on the Law of the Sea (UNCLOS)
• b) MSC.1/Circ.1334 Guidance to shipowners and ship operators, shipmasters and crews on preventing and suppressing acts of piracy and armed robbery against ships
• c) Form 147 Part 1 – Memorandum of Agreement
• d) Form 172 – Piracy and Armed Robbery Report Form
• e) Resolution A.917(22) Guidelines for the onboard operational use of shipborne Automatic Identification Systems (AIS) as amended by Resolution A.956(23)
• f) BMP5 Best Management Practices to Deter Piracy and Enhance Maritime Security in the Red Sea, Gulf of Aden, Indian Ocean and Arabian Sea
• g) Regional Guide 2 to Counter Piracy and Armed Robbery against Ships in Asia (2022)
• h) IMO Circular Letter No.3684

2. Purpose

• 2.1 This Bulletin is to provide advice on the risks to vessels from piracy and armed robbery, and outlines the process for reporting attacks, both successful and unsuccessful, to the BMSR.

3. Application

• 3.1 This Bulletin applies to all Barbadian ships and yachts.

4. Western Indian Ocean and the Gulf of Aden

• 4.1 Attention is drawn to BMP5 Best Management Practices to Deter Piracy and Enhance Maritime Security in the Red Sea, Gulf of Aden, Indian Ocean and Arabian Sea.
• 4.2 The BMSR requires all Barbadian ships to register with the MSCHOA at least four days prior to entry into the vessel registration area. Vessel operators and masters should note that reporting is still required even if the vessel does not intend to enter the HRA. The registration form can be found on the MSCHOA website at www.mschoa.org. Users will be required to register an account in order to submit vessel reports.
• 4.3 The UK Maritime Trade Operations Office (UKMTO) operate a Voluntary Reporting Area (VRA). Vessels must submit an initial report to UKMTO and subsequent daily position reports whilst in the VRA. Routine position reports should not be sent to MSCHOA.
• 4.4 Companies are reminded that following the BMP and ensuring their vessels are registered and reporting correctly will assist naval forces to manage their resources efficiently to offer the best protection against piracy and ensure an effective response should military intervention be required.
• 4.5 The BMSR and military forces in the area use Long Range Identification and Tracking (LRIT) data to monitor compliance with the reporting schemes. However, the MSCHOA registration and UKMTO reporting schemes require more information about the ship and crew than can be obtained through LRIT reporting. Therefore, companies and masters of Barbadian vessels must continue to report in line with MSCHOA and UKMTO procedures, and not rely solely on LRIT transmissions.

5. West Africa including the Gulf of Guinea

• 5.1 The Maritime Domain Awareness for Trade – Gulf of Guinea (MDAT-GoG) is a voluntary reporting mechanism that has been established to share information regarding piracy incidents in the area.
• 5.2 Full details of the scheme are provided in IMO Circular Letter No.3684.
• 5.3 Barbadian vessels should participate in the scheme by reporting their positions whilst inside the voluntary reporting area, indicated on chart Q6114.
• 5.4 Reports can be made by telephone (+33 (0)2 98 22 88 88) or by email (watchkeepers@mdat-gog.org).

6. Southeast Asia and the South China Sea

• 6.1 Attention is drawn to the Regional Guide 2 to Counter Piracy and Armed Robbery against Ships in Asia (2022).
• 6.2 Piracy in the Asian region takes a different form to that of the African Regions. Rather than the violent kidnap and ransoming of crew, the perpetrators usually board to steal unsecured items, ships stores and engine parts. However, the number of incidents in this region is still higher than in other parts of the world, and the dangers posed to the crew and vessel must not be ignored.
• 6.3 A Voluntary Community Reporting (VCR) scheme is in operation in the area, as depicted in charts Q6112 and Q6113. All Barbadian ships operating within the VCR area are strongly encouraged to participate in the scheme. Further details can be found in Annex C of the Regional Guide 2.

7. Automatic Identification System (AIS) Policy

• 7.1 In accordance with Resolution A.917(22) Guidelines for the onboard operational use of shipborne Automatic Identification Systems (AIS) as amended by Resolution A.956(23), if the master believes that the continual operation of AIS might compromise the safety or security of his/her ship or where security incidents are imminent, the AIS may be switched off.
• 7.2 Unless it would further compromise the safety or security, if the ship is operating in a mandatory ship reporting system, the master should report this action and the reason for doing so to the competent authority.
• 7.3 When the AIS is switched off, this must always be recorded in the ship’s logbook together with the reason for doing so, and the master should restart the AIS as soon as possible after the source of danger has disappeared. The ship should routinely transmit its position to the shipping company at given intervals, thereby giving the shipping company a first notice that something is amiss if the transmissions are interrupted.
• 7.4 When an attack is expected, or suspicious activity is detected, the AIS should be switched on as soon as possible to enable security forces to locate the vessel.

8. Long Range Identification & Tracking (LRIT) Policy

• 8.1 The LRIT equipment must not be switched off whilst the vessel is transiting or in the vicinity of a High-Risk Area.
• 8.2 Should it be necessary to switch off the LRIT equipment, the BMSR must be informed before doing so by email to registry@barbadosmaritime.com

9. Reporting of Piracy or Armed Robbery Incidents

• 9.1 The BMSR considers it vital that all attacks, both successful and unsuccessful, are reported to the nearest RCC (or regional piracy focal point where applicable), to the BMSR, and to the IMB Piracy Reporting Centre.
• 9.2 The BMSR reports all piracy and armed robbery attacks on Barbadian ships to the IMO for distribution in its monthly piracy reports. Form 172 – Piracy and Armed Robbery Report Form should be completed by the master or company to ensure all necessary data is submitted.
• 9.3 All reports are to be made as soon as possible, to enable necessary action to be taken.

10. Use of privately contracted armed security personnel

• 10.1 Barbadian ships can and should take measures to protect themselves from pirates and armed robbers and masters are encouraged to follow the recommendations in MSC.1/Circ.1334 Guidance to shipowners and ship operators, shipmasters and crews on preventing and suppressing acts of piracy and armed robbery against ships.
• 10.2 For legal and safety reasons, firearms should not be carried or used by seafarers for personal protection or for the protection of a ship. Seafarers are civilians, and the presence of firearms on board may encourage attackers to carry their own firearms or other weapons and escalate the situation further.
• 10.3 The BMSR permits the use of privately contracted armed security personnel, subject to approval by the BMSR Technical Department.
• 10.4 The BMSR has set five rules for engagement that must be followed by all armed security personnel on board Barbadian ships.
•      i) Visual demonstration that the ship is under security guard protection;
•      ii) Audible warning to the sea going threat not to approach the vessel, inside 500m range;
•      iii) Warning shot to deter any further approach towards the vessel from the sea going threat, inside 200m range;
•      iv) Engage the vessel with minimal force to dissuade its continued approach, inside 100m range;
•      v) Use of deadly force is sanctioned only where armed insurgents have boarded the ship and there is clear and immediate danger to those persons onboard and the ship.
• 10.5 The requirements for flag state approval to carry armed guards are:
•      i) Form 147 Part 1 – Memorandum of Agreement has been signed as accepted by BMSR and returned to the operator;
•      ii) The BMSR Rules of Engagement, detailed in paragraph 10.4, have been agreed to by the security company;
•      iii) The boarding security personnel shall be under the command of a Team Leader;
•      iv) The Team Leader will be under the command of the vessel’s Master;
•      v) All weapons boarded shall be under the control of the employees of the security company only, and that no unauthorized contact with the weapons will be allowed;
•      vi) The security company will provide all clearances etc. required for embarking and disembarking armed personnel on and off the vessel by the respective port authorities;
•      vii) The security company shall sign their agreement to comply with the BMSR Rules of Engagement, as detailed in paragraph 10.4;
•      viii) The Master shall follow all current practices for reducing the risk of unauthorised boarding, including the registering of the ship and its transit with UKMTO and MSCHOA;
•      ix) The Master will consider suggestions from the Team Leader for the further reduction of risk onboard his/her vessel.

11. Further sources of advice and information

• 11.1 The Maritime Security Centre – Horn of Africa (MSCHOA)
•      i) Website: https://www.mschoa.org/
•      ii) Telephone: 0033 (0) 298 220 220 / 0033 (0) 298 220 170
•      iii) Fax: 0033 (0) 298 220 171
•      iv) Email: postmaster@mschoa.org
• 11.2 ReCAAP Information Sharing Centre (ReCAAP ISC)
•      i) Website: https://www.recaap.org/
•      ii) Telephone: +65 6376 3063
•      iii) Fax: +65 6376 3066
• 11.3 United Kingdom Maritime Trade Operations (UMKTO)
•      i) Website: https://www.ukmto.org/
•      ii) Telephone: +44 (0) 2392 222060
•      iii) Email: info@ukmto.org
• 11.4 Maritime Domain Awareness for Trade – Gulf of Guinea (MDAT-GoG)
•      i) Website: https://gog-mdat.org
•      ii) Telephone: +33 2 98 22 88 88 (emergency)
•      iii) Telephone: +33 2 98 22 13 02 (exercise)
•      iv) Email: watchkeepers@mdat-gog.org
• 11.5 BMSR
•      i) Website: https://barbadosmaritime.org/
•      ii) Telephone: +44 (0)207 636 5739
•      iii) Emergency 24hr phone: +44 (0) 7985 498 475
•      iv) Email: ops@barbadosmaritime.com

Revision History

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

1. References

• a) International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS);
• b) IMO Resolution MSC.402(96) - Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear.

2. Purpose

• 2.1 Beginning 1 January 2020, a service provider, or manufacturer acting as a service provider, must be authorised by the Barbados Maritime Ship Registry (BMSR) according to MSC.402(96). under the provisions of Regulation 20.11.5 of Chapter III of SOLAS prior to providing maintenance, examination, testing, overhaul or repair of:
•      .1 lifeboats (including free-fall lifeboats);
•      .2 rescue boats;
•      .3 fast rescue boats;
•      .4 launching appliances; and
•      .5 on-load and off-load release gear for lifeboats (including primary and secondary means of launching appliances for free-fall lifeboats), rescue boats and davit- launched life rafts.
• 2.2 This bulletin provides guidance on examination, testing, servicing, maintenance, and repairs of the items listed in 2.1 above, on board Barbados flagged vessels.

3. Barbadian Authorisation of Service Provider (BASP)

• 3.1 The BMSR does not approve service providers but only authorises a service provider with an authorisation document, the Barbadian Authorisation of Service Provider (BASP).
• 3.2 The BASP is specific to the vessel requiring servicing of any of the items listed in 2.1 above and is only valid for 3 months from the date of issue.
• 3.3 The BASP is valid subject to the following conditions:
•      .1 The service provider shall hold a valid Approved Service Supplier Certificate (ASSC) issued by a Barbados Recognised Organisation (RO) verifying that the provider meets the requirements of MSC.402(96).
•      .2 Service engineers shall have valid Qualification Certificates issued by the equipment manufacturer or by the Approved Service Provider to whom this BASP was issued. The Qualification Certificate must define the service engineer’s level of qualification and the scope of the certification (e.g. makes and types of equipment);
•      .3 A copy of the BASP shall be attached to each service or maintenance report issued by the authorised service provider to the vessel.
•      .4 A copy of the Qualification Certificate for the service engineer(s) who inspects and/or services the equipment shall also be attached to the report.

4. BASP Application

• 4.1 Requests for a BASP shall be submitted by email to ops@barbadosmaritime.com prior to the servicing and shall be accompanied by a valid ASSC of the service provider.
• 4.2 The application shall be accompanied by:
•      .1 The previous BASP issued for the same Service Provide and vessel; Otherwise,
•      .2 The equipment last service certificate for the vessel proposed;
•      .3 A Copy of the Cargo Ship Safety Equipment Certificate (CS SEC) for the vessel proposed;
•      .4 The ASSC.
• 4.3 The ASSC shall always be full and must state the list of the equipment the service provider is certified, i.e., manufacturer and model of the equipment.
• 4.4 The managers shall make sure that the ASSC’s list includes the equipment fitted on board the vessel on which the service is to be carried out.
• 4.5 In case the ASSC’s list does not include the equipment fitted on board, then the managers and/or service providers shall provide a statement from the RO that issued the CS SEC.
• 4.6 The RO statement shall be based on template as per below, on the RO letterhead, signed stamped and dated not longer than 6 months from the date of application.

RO Template statement letter

Vessel Name:
IMO Number:
Flag: Barbados
Service Provider name:
Service Provider address:

THIS IS TO INFORM THAT this Society has no objection that the
annual service to lifeboat/rescue boat/freefall boat/davits of the
above nominated Vessel be carried out by this Society approved the
above-mentioned Service Provider.

Revision History

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

1. References

a) SOLAS, International Convention for the Safety of Life at Sea.
b) Resolution A.1045(27) Pilot Transfer Arrangements, adopted 30 November 2011.
c) MSC.1/Circ.1375/Rev.1 – Unified Interpretation of SOLAS Regulation V/23, issued 28 May 2012.

2. Purpose

2.1 This bulletin sets out to ensure that the use and maintenance of pilot transfer arrangements onboard Barbadian ships, complies with the standards set out in IMO Assembly Resolution A.1045 (27) and SOLAS V Reg. 23.

2.2 To ensure that all pilot/personnel transfers, using pilot transfer arrangements, are carried out safely.

3. Application

3.1 This bulletin applies to all Barbadian vessels that at any time may require the services of pilots. This includes but is not limited to entering or leaving port, as required during a deep sea passage, when transiting a strait and/or river, or as required by the Coastal State.

4. Pilot Transfer Requirements

4.1 Equipment and arrangements for pilot transfer which are installed on or after 1 July 2012 shall comply with the requirements of SOLAS V/ Reg. 23, with reference to the unified interpretation as per IMO Circular MSC.1/Circ.1375/Rev.1, and as set out in IMO Assembly Resolution A.1045(27).

4.2 These minimum requirements refer to the positioning, construction, rigging and securing of pilot transfer arrangements, as well as the related equipment, lighting, and access.

4.3 Equipment and arrangements for pilot transfer which are provided on ships before 01 July 2012 shall at least comply with the requirements of SOLAS V/ Reg. 23, as was in force prior to that date.

4.4 Further visual, explanatory notes are given in Annex I to this bulletin, as issued by the International Maritime Pilot’s Association (IMPA).

4.5 Owners shall ensure that the vessel is provided with equipment, and has procedures in place, that complies with Resolution A.1045(27) and SOLAS V/ Reg. 23, that appropriate manuals for pilot transfer arrangements are available on board the ship, and that suitable positions are available on each side of the ship for compliant pilot transfer arrangements to be rigged.

4.6 The Master shall ensure that a responsible officer supervises the rigging, testing and use of the pilot transfer arrangements and shall ensure that the crew members engaged in rigging and use of the pilot arrangements have been properly instructed.

4.7 The Master shall also ensure that the pilot transfer equipment and arrangements are accessible, kept clean, properly maintained, properly stowed, and regularly inspected.

Annex I – Required Boarding Arrangements for Pilot

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

Download Bulletin  

1. References

a) International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS).
b) International Life-Saving Appliance (LSA Code).
c) MSC.1/Circ.1662 Guidelines for anchor handling winches.
d) MSC.1/Circ.1663 Guidelines for lifting appliances.
e) Bulletin 008 – Permits Exemptions and Equivalences Rev.2.0.

2. Purpose

2.1 This Bulletin provides information on the application of SOLAS Reg. II-1/3-13 Lifting appliances and anchor handling winches on Barbadian vessels.

3. Definitions

3.1 Lifting appliance means any load-handling vessel’s equipment:
.1 Used for cargo loading, transfer, or discharge;
.2 Used for raising and lowering hold hatch covers or moveable bulkheads;
.3 Used as engine-room cranes;
.4 Used as store cranes;
.5 Used as hose handling cranes;
.6 Used for launch and recovery of tender boats and similar applications; and
.7 Used as personnel handling cranes.
3.2 Anchor handling winch means any winch for the purpose of deploying, recovering and repositioning anchors and mooring lines in subsea operations.
3.3 Loose gear means an article of vessel’s equipment by means of which a load can be attached to a lifting appliance or an anchor handling winch, but which does not form an integral part of the appliance or load.
3.4 The expression “installed on or after 1 January 2026”, as provided in SOLAS Reg. II-1/3-13, means:
.1 For a vessel the keel of which is laid, or which is at a similar stage of construction on or after 1 January 2026, any installation date on the vessel; or
.2 For vessels other than that specified in 3.4.1 above, including those constructed before 1 January 2009, a contractual delivery date for lifting appliance or anchor handling winches, or in the absence of a contractual delivery date, the actual delivery date of the lifting appliance or anchor handling winches to the ship on or after 1 January 2026."
3.5 Certified means that the lifting appliance or loose gear and anchor handling winches or associated loose gear have been verified and documented as compliant to the satisfaction of the Barbadian Recognised Organisation (RO).
3.6 Competent person means a person possessing the knowledge and experience required for the performance of duties specified in these guidelines MSC.1/Circ.1662 and MSC.1/Circ.1663, and for Barbadian vessels shall be a Recognised Organisation (RO) surveyor.
3.7 Thorough examination means a detailed assessment carried out by a competent person to determine whether or not the lifting appliance or loose gear and the anchor handling winches or associated loose gear are in compliance with the applicable requirements of the RO.

4. Application

4.1 SOLAS Reg. II-1/3-13, applicable from the 1st of January 2026, shall apply to lifting appliances and anchor handling winches, and loose gears utilised with the lifting appliances and the anchor handling winches.
4.2 SOLAS Reg. II-1/3-13 does not apply to:
.1 Lifting appliances on MODUs;
.2 Lifting appliances used on offshore construction vessels, such as pipe/cable laying/repair or offshore installation vessels, including vessels for decommissioning work, which comply with standards acceptable to the BMSR;
.3 Integrated mechanical equipment for opening and closing hold hatch covers; and
.4 Life-saving launching appliances complying with the LSA Code.
4.3 SOLAS Reg. II-1/3-13 paragraphs 2.1, and 2.4 do not apply to lifting appliances which have a safe working load (SWL) below 1,000 kg. However, lifting appliances shall be permanently marked and provided with documentary evidence for the SWL.

5. Design, Construction , Installation, Maintenance, Operation, Inspections and testing

5.1 Lifting appliances and loose gears installed on or after 1 January 2026 shall be designed, constructed and installed in accordance with the requirements of the vessel’s RO, based on MSC.1/Circ.1663.
5.2 Lifting appliances installed on or after 1 January 2026 shall be permanently marked and provided with documentary evidence for the safe working load (SWL).
5.3 Anchor handling winches and loose gears installed on or after 1 January 2026 shall be designed, constructed, installed and tested to the requirements of the vessel’s RO, based on MSC.1/Circ.1662.
5.4 Lifting appliances installed before 1 January 2026 shall be load tested to the satisfaction of the vessel’s RO after installation and before being taken into use for the first time and after repairs, modifications or alterations of a major character.
5.5 Lifting appliances shall be load tested to the satisfaction of the vessel’s RO no later than the date of the first renewal survey on or after 1 January 2026 or after repairs, modifications or alterations of a major character.
5.6 For load testing of lifting appliances intended for use while the vessel is in port or sheltered waters, the test load, as set out in table 1 of MSC.1/Circ.1663, shall be established using the SWL. For lifting appliances intended for open-sea operations, the test loads shall be to the satisfaction of the vessel’s RO, taking into account the applicable dynamic loads.
5.7 Where the SWL of the lifting appliances is undocumented and design information is not available, e.g. for lifting appliances which are installed on board before 1 January 2026 and the manufacturer no longer exists, the test load shall be calculated using table 1 of MSC.1/Circ.1663, based on a SWL nominated by the company, to the satisfaction of the vessel’s RO.
5.8 All loose gears in use with lifting appliances shall have documentary evidence of a proof test and be retested after repairs, modifications or alterations of a major character to the satisfaction of the vessel’s RO. Where an item of loose gear is tested, minimum test loads shall be to the satisfaction of the vessel’s RO, based on table 2 of MSC.1/Circ.1663.

5.9 Lifting appliances and loose gears shall be subject to thorough examination to the satisfaction of the vessel’s RO:
.1 Upon completion of any load test; and
.2 Annually.
5.10 Where a thorough examination of lifting appliances and loose gear does not form part of the renewal survey or annual survey, verification that a thorough examination of lifting appliances has been conducted/completed to the satisfaction of the vessel’s RO shall take place during the renewal survey under SOLAS Reg. I/7 or the annual survey under SOLAS Reg. I/10, as applicable.
5.11 If on completion of a thorough examination, the competent person considers the lifting appliance and/or the loose gear to be unsafe for operation or not in compliance with the applicable requirements of the vessel’s RO, based on MSC.1/Circ.1663, then that lifting appliance and/or loose gear shall be taken out of service until any deficiency is rectified to the satisfaction of a competent person. The lifting appliance shall be clearly marked "not to be used" and the status should be recorded in a register of lifting appliances and loose gear. While out of service, the relevant actions for inoperative lifting appliances and/or Loose gear as outlined under Sec. 6 below should be followed.
5.12 Load testing and thorough examination of lifting appliances and loose gears shall be documented in any convenient form, provided each entry contains the necessary information, is clearly legible and is authenticated by a competent person. The minimum information to be included in the Certificate of test and thorough examination, as set out in appendix 1 of MSC.1/Circ.1663.
5.13 For anchor handling winches loose gears a commissioning test should be carried out according to the manufacturer's instructions and the requirements of the vessel’s RO, based on MSC.1/Circ.1662, which provides an equivalent level of safety.
5.14 Anchor handling winches and associated equipment should be subject to a thorough examination to the satisfaction of the vessel’s RO, based on MSC.1/Circ.1662, before re-entering service after any structural repairs or modifications of a major character and after load testing.
5.15 If on completion of a thorough examination or of an inspection, the competent person considers an anchor handling winch and/or a loose gear to be unsafe for operation or not in compliance with the applicable requirements of the vessel’s RO, based on MSC.1/Circ.1662, then that anchor handling winch and/or loose gear should be taken out of service until any deficiency is rectified to the satisfaction of a competent person. The anchor handling winch should be clearly marked "not to be used" and the status should be recorded as outlined in 3.2.4 of MSC.1/Circ.1662. While out of service, the relevant actions for inoperative anchor handling winches as outlined under Sec. 6 below should be followed.
5.16 All loose gear in use with anchor handling winches and associated equipment shall have documentary evidence of a proof test and be retested after repairs, modifications or alterations of major character acceptable to the vessel’s RO.
5.17 For existing lifting appliances and anchor handling winches and existing loose gears utilised with valid certificates under another international instrument, the vessel’s RO shall seek acceptance from the BMSR for a permanent equivalence compliant with SOLAS regulation II-1/3-13.2.4 and 2.5. Such request shall be sent to Ops@barbadosmaritime.com as per Bulletin 008.
5.18 Maintenance and inspection, operational testing and their respective intervals of lifting appliances and anchor handling winches and loose gears shall be in accordance with the manufacturer's recommendations, industry standards and guidelines or the vessel’s RO considering factors such as the operational profile of the vessel and the lifting appliance and/or loose gear.
5.19 Damaged, broken, worn or corroded ropes, including their terminations connecting loose gear of lifting appliances and anchor handling winches should be inspected and discarded according to manufacturers' recommendations, relevant industry standards, and international standards (e.g. ISO 4309:2017 on Cranes – Wire ropes – Care and maintenance, inspection and discard) or requirements of the vessel’s RO.
 
6. Inoperative lifting appliances and anchor handling winches

6.1 Whenever an accident occurs to a vessel or a defect is discovered, either of which affects the safety of the vessel or the efficiency or completeness of its lifting appliances and anchor handling winches, the master, shipowner or managers shall report at the earliest opportunity to the BMSR at Ops@barbadosmaritime.com for the request of appropriate permission as per Bulletin 008.
6.2 Except as provided in 6.1 above, while all reasonable steps shall be taken to maintain lifting appliances, anchor handling winches and loose gear to which SOLAS Reg. II-1/3-13 applies in working order, malfunctions of that equipment shall not be assumed as making the vessel unseaworthy or as a reason for delaying the vessel in ports, provided that action has been taken by the master to take the inoperative lifting appliance or anchor handling winch into account in planning and executing a safe voyage.

Revision History:

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

1. References

a) Barbados Merchant Shipping Act (CAP 296).
b) IACS PR 1C “Procedure for Suspension and Reinstatement or Withdrawal of Class in Case of Surveys, Conditions of Class or Recommendations Going Overdue”.
c) International Safety Management Code (ISM Code).
d) International Ship and Port Facility Security Code (ISPS Code).
e) Maritime Labour Convention, 2006.
f) Form 12 – Minimum Safe Manning Document Application.
g) Checklist 02 – Ship Registration.

2. Purpose

2.1 This Bulletin describes the requirements for lay-up of Barbadian vessels.

3. Application

3.1 This Bulletin applies to all vessels that are to be laid up temporarily and not in commercial operations for any reason.

4. General

4.1 The term laid up vessel refers to a vessel that is temporarily idle due to lack of cargo, or which are temporarily phased out of commercial operations.
4.2 There are two different ways to lay up vessels: “Hot lay-up” and “Cold lay-up”.
4.3 During “hot lay-up“ the vessel is idle but can be brought back into service at short notice. The machinery is kept in operation for the sake of fast re-commissioning, but measures may be taken to reduce various operational costs. Vessels should normally be laid-up without cargo. Adequate manning for the safe operation of the machinery should be kept.
4.4 During “Cold lay-up“ the vessel is taken out of service due to lack of employment and is moored or anchored at a safe place waiting for new employment. The machinery is taken out of service and the vessel is kept “electrically dead” with the exception of emergency power. Minimum manning covering fire, leakage, moorings and security watches should be kept. Power will be kept to minimum level to ensure emergency equipment and operation of windlass and mooring winch are operational.
4.5 Without a notification of lay-up, vessels are implied to be trading normally and maintaining a full regime of certification, surveys, and inspections, including normal manning for such operations. Therefore, Managers shall advise the BMSR when a vessel is in lay-up.
4.6 The BMSR only requires notification of the vessel being laid up. Failure to notify the BMSR and the relevant Recognised Organisation(s) (ROs) of the vessel entering lay-up and failure to maintain a safe lay-up, will be regarded as a Majon Non-Conformity (MNC) and might result in the vessel being deleted from the registry.
4.7 The Managers are to advise the BMSR of the proposed length of the lay-up and the state of readiness of the vessel to resume trade. The Company should take appropriate advice on lay-up procedures as necessary, including that of the ROs, insurers, and local authorities etc.

5. Statutory and Class Certification

5.1 Statutory certification is normally only required when vessels are trading, while class is to be maintained at all times, as a requirement for continuous registration.
5.2 However, Classification Societies have procedures for laying up vessels and class suspension, which are based on the IACS PR 1C.
5.3 Depending upon the proposed length of the lay-up and taking into account any requirements of the port or coastal State of the lay-up location, the Managers should consider whether to maintain or suspend the statutory and Class certification.
5.4 Any statutory and Class certificates, for which the periodical survey/audit/inspection window has expired during lay-up, is to be considered invalid.
5.5 The Managers and/or ROs shall notify BMSR of suspension or cancellation of class certificates after a decision has been taken by the RO on such suspension or withdrawal.

6. Suspending and Reinstating the Vessel during Lay-up

6.1 If any statutory and class certification are suspended as per above, then the vessel is also suspended from the registry.
6.2 During suspension, all flag certificates and permits issued by the BMSR will be automatically withdrawn and voided and the vessel is prohibited from proceeding to sea.
6.3 When a vessel is suspended from the registry due to lay up, the BMSR will issue the relevant suspension certificate and, for vessel which are required to hold a Continuous Synopsis Record (CSR), the BMSR will issue a CSR with laid up status where the date of entering laying up will be used a date of ceased registration with the BMSR.
6.4 At the end of the lay-up, recommissioning is generally a matter for the Company and the Recognised Organisation to consider. While recommissioning the vessel, the manning must be kept under review, taking into account the reactivation of machinery and equipment and the associated hazards, including potential fire risk.
6.5 All previously cancelled, suspended, or outdated certificates, audits and inspections are to be revalidated and the manning restored to that required by the Minimum SMD before the vessel sails from her port of lay-up.
6.6 The BMSR will re-issue all flag certificates upon submission of all relevant documents and statutory certificates, as applicable, listed in Checklist 02.

7. Safety Management Certificates (SMC)

7.1 If the care of a vessel during lay-up is handed over to an organisation which is not the ISM Manager (e.g. dedicated lay-up providers), the BMSR will accept the suspension of the ISM Code certification of the vessel provided that the company provides evidence that:
.1 all requirements of the coastal State are met;
.2 all requirements of the RO are met; and
.3 the contact details of the organisation that holds responsibility for the safety of the vessel during lay-up.
7.2 if the vessel has been laid up more than 6 months, the SMC becomes invalid and an interim verification audit will be required upon re-commissioning, with the vessel being treated as a new vessel to the company. Upon successful completion of the verification, an interim SMC will be issued.
7.3 If the lay-up period is less than 6 months, but the periodical audit window has expired during lay-up, the SMC will be considered invalid. The vessel will then be required to undergo an interim audit upon recommissioning and an interim SMC will be issued.
7.4 If the vessel has been laid up for less than 6 months and the periodical audit window has not expired, the SMC will still be valid.

8. International Ship Security Certificate (ISSC)

8.1 The continued validity of the vessel's ISPS Code certification is an important element in the reactivation of the vessel. It is strongly recommended that the ISSC is maintained throughout lay-up and at least the Ship Security Plan (SSP) provisions related to security measures.
8.2 The SSP might need the addition of specific procedures depending upon the extent or "depth" of the lay-up. The Managers are to establish measures within the SSP to address risks associated with security breaches during vessel lay-up periods.
8.3 Where the circumstances described in Sec. 7.1 above, the company must communicate with the Recognised Security Organisation (RSO) to ensure that the SSP Plan covers that operation.
8.4 If the vessel is integrated into the port facility security system, the records of suspension and subsequent reactivation of the ISSC should clearly reflect that, to demonstrate continuity of security.
8.5 If the vessel has been laid up for more than 6 months, the ISSC becomes invalid. An interim verification will be required upon re-commissioning, with the vessel being treated as a new vessel to the company. Re-approval of SSP may be required. Upon successful completion of the verification, an interim ISSC will be issued.
8.6 If the lay-up period is less than 6 months, but the periodical audit window has expired during lay-up, the ISSC will be considered invalid. The vessel will then be required to undergo interim verification upon recommissioning.
8.7 If the vessel has been laid up less than 6 months and the periodical audit window has not expired, the ISSC will still be valid.

9. Maritime Labour Certificate (MLC)

9.1 The Company shall take into account any obligations for medical care and repatriation specified in the CAP 296 or Maritime Labour Convention.
9.2 Any failure to provide a basic level of welfare facilities will be regarded as a failure of the vessel Safety Management System and may lead to further measures by the BMSR, in addition to any action which may be taken by the port or coastal State.
9.3 For ships staying in lay-up more than 6 months, an additional MLC inspection is required on reactivation to confirm continued compliance with DMLC Part II with an additional endorsement.
9.4 If the lay-up period is less than 6 months, but the intermediate inspection window expires during lay-up, the MLC will be considered invalid. The vessel will then be required to undergo interim verification upon recommissioning and an interim MLC will be issued.
9.5 If the vessel has been laid up less than 6 months and the intermediate inspection has not expired the MLC will still be valid.

10. Long Range Identification and Tracking (LRIT)

10.1 Normal procedures for LRIT apply.
10.2 If the LRIT equipment is deactivated or switched off, the BMSR is to be advised so that reporting can be suspended correctly.

11. Insurance

11.1 Relevant hull and machinery underwriter and P&I club should be consulted for guidance prior to removal of the vessel from service.
11.2 P&I club rules for protection and indemnity cover will vary, but the owner may, upon negotiation, apply for lay-up return for certain idling period provided the vessel is declared safely laid up.
11.3 If the vessel is laid-up for an extended period of time, most P&I clubs will reserve the right to inspect the condition of the vessel on re-commissioning.
11.4 Most port authorities will require a letter from local P&I club representatives to confirm that the laid-up vessel is covered for port risks, e.g. oil pollution, wreck removal, salvage costs, etc.

12. Manning
12.1 The Minimum Safe Manning Document (SMD) does not apply to ships in lay-up.
12.2 When a vessel is laid up, normal manning may be reduced appropriate to the status and operational requirements of the vessel. Any reduction in manning should be considered in consultation with the relevant port or coastal State Authority.
12.3 If the managers and/or the port or coastal States wish to have a lay-up SMD issued by the BMSR, Form 12 is to be sent to registry@barbadosmaritime.com.
12.4 The BMSR recommends that a suitably qualified person should remain in charge of the vessel for the proposed lay-up period and that the manning available should include a sufficient number of trained persons to meet any emergency situation. In such circumstances, communication must be maintained with the local authorities so that further assistance may be immediately obtained when required.

13. Flag Inspections

13.1 If the duration of lay-up includes the window for the annual flag inspection, the anniversary date may be suspended until the vessel is being prepared for reactivation.

General Information regarding the new LRIT service

Long Range Identification Tracking (LRIT) is a method by which Flag States may know where their ships are located anywhere in the world and any other Flag State’s vessels transiting their waters. The standard accuracy is that of a ship position 6 hours old; in cases of special concern the frequency can be increased to instant ship positions. These changes should they be required are made from the Barbados Data Centre; no adjustments have to be made onboard with the ships equipment.

Conformance Test Report (CTR)

The equipment to be used for these transmissions of LRIT information is tested by a BMSR Approved Application Service Provider (ASP). On successful completion of the tests the vessel is left with a LRIT Conformance Test Report (CTR) confirming that the vessel’s equipment is standing by ready for activation from the BMSR Data Centre. The ship’s copy of the CTR must be kept safely with the ship’s papers.

LRIT Compliance Test Certificate

Once the CRT is produced to the BMSR a LRIT Compliance Certificate will be issued to the ship for keeping with the CRT. Neither the CRT or Compliance Certificates have an expiry date therefore they do not have to be periodically renewed.

New LRIT equipment tests will be required if:-

• The ships equipment fails requiring the replacement of equipment.
• A ship changes Flag and the new Flag State does not recognise the ASP of the previous Flag State.

It is important that the ship board equipment is not switched off or tampered with in any way as this may
affect the transmission of position reports and in turn cause problems with Port or Coastal State authorities.

If your vessel is laid up or in dry dock for any period over 3 weeks you must notify BMSR so that the Data
Centre can be made aware of the reason for the static plots of the vessel.

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Large Commercial Yacht Standards ‘LY2’ Code

Guidance for Yacht Owners and Managers

As mentioned in our Information Bulletin No.209, BMSR is moving towards compliance with the Large Yacht Code ‘LY2, ’ which was drawn up by the Maritime Coastguard Agency (MCA) and applies to Large Commercial yachts over 24m. in load line length and less than 3000gt.

It is planned to achieve full compliance for new yachts by the end of 2013, by which time the appropriate legislation should have been approved by the Barbados Government.

In setting this standard for large commercial yachts, we are aware that the move towards LY2 implies quite a lot of changes for new vessels particularly. However, the LY2 Code is practical in that it allows for equivalent standards, exemptions and allowances for existing vessels by the flag state as may be seen by the following extracts from the Code.

3.2.1 Equivalent standards

Proposals for the application of alternative standards considered to be at least equivalent to the requirements of the Code should be submitted to the Administration for approval. Equivalence may be achieved by incorporating increased requirements to balance deficiencies and thereby achieve the overall safety standard.

3.2.2 Exemptions

Exemptions should be granted only by the Administration. Applications for exemption should be made to the Administration and be supported by justification for the exemption .The granting of exemptions will be limited by the extent to which international conventions allow and should be regarded as exceptional.

3.2.3.2 Existing vessels

When an existing vessel does not meet the Code safety standard for a particular feature and it can be demonstrated that compliance is neither reasonable nor practicable, proposals for alternative arrangements should be submitted to the Administration for approval. In considering individual cases, the Administration should take into account the vessel’s service history and any other factors which are judged to be relevant to the safety standard which can be achieved.

We are also aware that MCA has produced an update to the LY2 Code which is known as the LY3 Code. MCA planned to introduce this simultaneously with MLC on 20th August 2013 (the MLC Convention and LY3 Code are supposed to be complementary). However, there have been difficulties with LY3 implementation which are not expected to be resolved soon. It is our view that LY2 will remain the more practical standard for large commercial yachts under the Barbados flag until at least October 2015.

Owners of any planned new-buildings, however, should apply the LY3 Code to those new-buildings as will be done by any classification society that may oversee the building. The main differences between the LY2 and LY3 Codes involve new-buildings.

Privately Operated Yachts

A privately operated yacht, operated without any commercial charter hire whatsoever, will not need to comply with any Barbados legislation with respect to the LY2 Code, manning or operations. The BMSR policy however is to strongly recommend that private yachts comply with the Large Yacht Code.

The reason for this recommendation is essentially to provide greater safety, by virtue of the construction, equipment, operation and manning requirements of the Large Yacht Code.

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To all Yacht owners, managers, operators

Manning Scales for Commercial Yachts over 24m Load Line Length and under 3000 GRT

COMMERCIAL YACHTS UNDER 500 GRT

Any change to the minimum numbers and/or minimum qualifications shown above must be submitted to Barbados Ships’ Registry for consideration and approval.

A deck officer with an AEC or MEOL qualification will be accepted for the engineering post requiring that qualification providing he is not the Master and minimum safe manning numbers are maintained.

For Yachts under 500 GRT of 3000kW, the requirements for engineers will be as shown above provided there is a simple engine room layout and engine configuration. Where engine power is over 3000 kW and engine room layout and engine configuration are complicated, these requirements may be re-assessed by BMSR.

Manning Scales for Commercial Yachts over 24m Load Line Length and under 3000 GRT

COMMERCIAL YACHTS OVER 500 GRT

Any change to the minimum numbers and/or minimum qualifications shown above must be submitted to Barbados Ships’ Registry for consideration and approval.

All officers holding recognised STCW certificates of competency may apply to Barbados Ships’ Registry for issue of a Barbados Endorsement.

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LRIT APPLICATION SERVICE PROVIDERS (ASPs) AUTHORISED BY BMSR

Application: All ship-owners, operators, masters and officers of merchant ships and authorised classification societies

In accordance with IMO MSC Circular 1307 section 7.2.4, it has been decided that Barbados Maritime will reduce the number of Conformance Testing ASPs to just one: Fulcrum Maritime Systems of Hornchurch, Essex, UK.

This move, which will take effect from 1st January 2016, reflects the limited number of tests that are required by our clients in that we are a relatively small flag state. The move should also help to simplify matters and contain costs.

Any vessels using the service of other Testing ASPs previously authorised by Barbados may continue to do so after 1st January 2016 for the period of validity remaining on their Conformance Test Reports.

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BARBADOS REQUIREMENTS: NAUTICAL PUBLICATIONS

BARBADOS REQUIREMENTS: GENERAL PUBLICATIONS

For a comprehensive list of statutory publications, please see MSC Circ. 1462

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GUIDANCE ON THE IMPLEMENTATION OF THE MANILA AMENDMENTS TO THE STCW CONVENTION

This Bulletin provides information on the certification and training requirements for seafarers engaged on Barbados registered vessels.

Documents referred to in this bulletin notice:

• International Convention on Standards of Training, Certification and Watch-keeping for Seafarers, up to and including the 2010 Manila Amendments (STCW Convention);
• Seafarers’ Training, Certification and Watch-keeping Code, as amended (STCW Code);
• STCW.7/Circ.16: Clarification of transitional provisions relating to the 2010 Manila Amendments to the STCW Convention and Code;
• Barbados Endorsement Application Process;
• Minimum Safe Manning Requirements.

Most regulations and bulletins are available on this website (https://barbadosmaritime.org) or by contacting registry@barbadosmaritime.com.

See here: Bulletin 262

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International Code for Ships Operating in Polar Waters

Guidance and instructions for Barbados Recognised Organisations, Barbados Approved Nautical
Inspectors, Ship Owners, Managers and Masters

See the following bulletin details: 276: Polar Code Guidance

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USE OF ELECTRONIC CERTIFICATES

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

This Bulletin presents advice on the use of electronic certificates on board Barbados registered vessels. The Facilitation Committee (FAL) of the International Maritime Organization (IMO), at its 40th session approved the Guidelines for the use and acceptance of electronic certificates (FAL.5/Circ.39/Rev.2)/

Recognized Organizations issuing statutory certificates to Barbados registered ships are authorised to issue electronic versions of the statutory certificates. Electronic certificates issued by the Recognized Organizations should contain the features as stated in FAL.5/Circ.39/Rev.2, (as may be amended). They may also contain additional security features as deemed appropriate. In addition, clear and simple instructions should be provided on board for any relevant party who may wish to verify the validity and authenticity of the electronic certificates.

The electronic statutory certificates, inter alia, identifies the following features:

• validity and consistency with the format and content required by the relevant international convention or instrument;
• protected from edits, modifications or revisions;
• a unique tracking number for verification;
• reliably and securely verifiable through a conveniently accessible and continuously available platform; and
• a printable and visible symbol that confirms the source of issue.

As stated by FAL.5/Circ.39/Rev.2, electronic statutory certificates issued by the Recognized Organizations should be valid in accordance with all applicable international instruments. Notwithstanding the recognition of electronic certificates by this Administration, all parties are reminded that ships should comply at all times with the local requirements of each specific port. This Bulletin should be kept on board for consultation by Port State Control, Classification Society surveyors/auditors or any other interested party.

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GUIDANCE ON ’TYPE APPROVALS’

and Interpretation of “to the satisfaction of the Administration”

Type Approvals

Equipment will be considered to fall into two different categories:

1) Equipment specified by the International Maritime Organisation (IMO), where there are standards developed by IMO committees. Recognised organisations shall accept such approved/adopted equipment for use on Barbados registered ships; as having been approved by maritime authorities and included in the list of approved equipment.

2) Equipment not specified by IMO, where conventions require “type approved”equipment: Barbados Maritime, in accordance with the provisions of the conventions, willaccept equipment approved by IMO member countries, where those maritime countries have provision for approval of certain types of equipment and organisations must accept the equipment so approved.

3) In cases not covered by either of the above, the Recognised Organisations, acting on behalf of Barbados, shall accept national or international standards, or the standards developed by experienced organisations, for equipment or materials on board Barbados vessels.

4) In such circumstances, the Recognised Organisations must submit to Barbados Maritime the list of equipment that has been approved, when such approvals are required.

“To the satisfaction of the Administration”

5) In all cases where the phrase “to the satisfaction of the Administration” appears in conventions ratified by Barbados, we shall apply the rules or interpretations made by national or international standards, or standards developed by experienced organisations in such cases, such as the unified interpretations of the International Association of Classification Societies (IACS).

6) Barbados Maritime Ship Registry may establish its own interpretations to allow for satisfactory means of complying with certain provisions of the Conventions, in which case, these would be applied exclusively to all Barbados registered ships.

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Application: All ship-owners, operators, masters and officers of merchant ships and authorised Classification societies, Barbados Registrars and Nautical Inspectors

Please be advised that during the 30th Assembly of the IMO in December 2017 it was decided that all new vessels built from the 1 January 2019 should be provided with new ISO standard safety signs as described in Resolution A.1116(30) instead of the current IMO signs.

This means that all ships constructed (keel laying date) on or after 1 January 2019, and existing ships which undergo repairs, alterations, modifications and outfitting within the scope of SOLAS Chapters II-2 and/or Chapter III as applicable, on or after 1 January 2019, will need to ensure that they are compliant with the signs listed in Tables 1, 2 and 3 in the Annex to A.1116(30).

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Large Commercial Yacht Standards ‘LY3’ Code

Guidance for Yacht Owners and Managers

Further to Bulletin 209, BMSR has been operating in compliance with the Large Yacht Code “LY2”, drawn up by the UK Maritime & Coastguard Agency (MCA) and applicable to large commercial yachts over 24 metres load line length and under 3000 grt.

The Large Commercial Yacht Code ‘LY3’ has been developed, by the Red Ensign Group, to enable luxury yachts to operate under an alternative set of requirements given the nature of their use. The Code applies to yachts which are 24 metres and over in load line length, are in commercial use for sport or pleasure, do not carry cargo and do not carry more than 12 passengers. While appropriate legislation is being approved by the Barbados Government, BMSR on a case by case basis will be approving the use of this code.

Owners of any planned new-buildings, however, should apply the LY3 Code to those new-buildings as will be done by any classification society that may oversee the building.

Privately Operated Yachts

A privately operated yacht, operated without any commercial charter hire whatsoever, will not need to comply with any Barbados legislation with respect to the LY3 Code, manning or operations. The BMSR policy however is to strongly recommend that private yachts comply with the LY3 Code. The reason for this recommendation is essentially to provide greater safety, by virtue of the construction, equipment, operations and manning requirements of the LY3 Code.

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Application: all ship-owners, operators, masters and officers of merchant ships and authorised classification societies.

This Bulletin supersedes Bulletin 266 which is hereby cancelled.

However, in light of recent issues in the Straits of Hormuz, this Bulletin provides some additional guidance on security when navigating in the region of the Gulf of Oman, Straits of Hormuz and the Persian Gulf.

All ships in this area are permitted to implement additional security measures for the duration of their time in the region without increasing the security, unless this is required by the coastal states. The managers/owners should ensure a complete risk assessment is carried out prior to undertaking a voyage in the region. Therefore for Barbados flagged ship, the security level remains at level 1, at this time.

Any change to a higher security level, whether it be here or any other part of the world, is to be advised to the Registry.For other countries and sea areas be guided by the government of the country or sea area for setting higher security levels.

Gulf of Aden – all ships should register in advance with MSCHOA and report to UKMTO to obtain the latest information. Operators should also ensure that their ships are following the latest edition of the Best Management Practices available on their website.

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GUIDELINES ON ANNUAL TESTING OF VOYAGE DATA RECORDERS (VDR) AND SIMPLIFIED
VOYAGE DATA RECORDERS (S-VDR)

Application: all ship-owners, operators, masters and officers of merchant ships and authorised classification societies.

The IMO has issued MSC.1/Circ.1222/Rev.1 – please be guided by the attached.

313: Annual Testing of VDRs & SVDRs

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Application: all ship-owners, operators, masters and officers of merchant ships and authorised classification societies

Please be aware that we are currently investigating recent attempts by fraudsters purporting to be from Barbados Maritime administration and sending out emails that appear to have been sent out by a senior officer of the administration. Our bank account details have NOT changed, and we urge all our clients and their personnel, if there is any doubt as to the authenticity of any communication purporting to be from the Barbados Maritime administration, to contact the Ships’ Registry if you receive any similar approach.

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Application: all ship-owners, operators, masters and officers of merchant ships and authorised classification societies

Barbados Flag wishes to bring to the attention of all concerned the new publication for maritime security guidance for ships and seafarers operating off the coast of West Africa and the Gulf of Guinea, replacing the previous guidelines for the area.

This publication is aimed to help mariners detect, deter and delay external threats to their safety. Best Management Practices to Deter Piracy and Enhance Maritime Security off the Coast of West Africa including the Gulf of Guinea (BMP-WA) complements piracy guidance in the latest International Maritime Organisation Resolutions and Circulars (www.imo.org) in this region.

The maritime security situation off the West Coast of Africa is complex and dynamic. BMP (WA) has been developed to help ships and seafarers avoid becoming the victims of maritime security incidents in these waters. The publication aims to help ships plan their voyage and to detect, avoid, deter, delay and report attacks. BMP-WA also outlines risk assessment as an integral part of voyage planning in identifying measures for prevention, mitigation and recovery, combining statutory regulations with supplementary measures.

The consequences of not adopting effective security measures can be severe. The guidance contained in this publication mitigates the risk from piracy and armed robbery. To this effect, all concerned are strongly advised to apply the recommendations in this publication, which will make a significant difference to the safety of seafarers.

Barbados Flag also draws the attention of all concerned to the official website (https://www.gog mdat.org)

of the Maritime Domain Awareness for Trade-Gulf of Guinea (MDAT- GoG), the co-ordination centre tasked to safeguard merchant ships operating in the region. MDAT- GoG is a cooperation centre between the Royal Navy (UKMTO) and the French Navy (MICA-Center) in support of Yaounde Process. The primary output from the MDAT- GoG is to contribute by maintaining coherent maritime situational awareness in the central and western African Maritime areas, with the ability to inform and support industry. It contributes to the safety and security of the Mariner in the regional maritime domain.

To do this effectively, MDAT- GoG needs to know about merchant ships approaching, transiting or operating in the region. The MDAT- GoG website offers ship-owners, ship masters and agents the facility to register their details securely with MDAT- GoG, update positions of their vessels and receive information and guidance designed to reduce the risk of pirate attacks. To this effect, masters and operators of Barbadian ships that operate or that may operate in this area are strongly advised to register on the website.

The publication may be downloaded from www.maritimeglobalsecurity.org, which also includes links to other maritime security information useful to mariners.

06-05.2020

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Officer Endorsements and CRAs will now be issued with a QR code, which can be scanned to verify the authenticity of the document. The aim is to reduce the administrative burden on Administrations, Port State control officials, ships’ crews and other stakeholders in the industry.

In the past, ships have experienced instances of Port State Control actions because a paper certificate, which had been issued, did not arrive on the ship or the paper certificate was damaged or lost.

IMO “Guidelines for the use of electronic certificates” (FAL.5/Circ.39/Rev.2), sets out the necessary features, and recommends stakeholders to accept such certificates.

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Application: All shipowner/operators, masters and officers of merchant ships

IMO has provided Guidelines to ensure a safe shipboard interface between ship and shore-based personnel, to which we wish to draw your attention.

This advice is provided here: .Circular Letter No.4204-Add.16 – Coronavirus (Covid 19) – Covid-19 Related
Guidelines For Ensuring A Safe Shipboard

19/05/2020

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

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

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

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

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

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

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

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

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

3.3.2 Updating of Software:

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

3.3.3 Client/Server Installation:

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

3.3.4 Minimum Data Reporting & Exporting Requirements:

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

3.4.5 Recording of Entries:

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

3.4.6 Back Up and Recovery of Entries:

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

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

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

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

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

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

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

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

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

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

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

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

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

ANNEX – Retention Periods for Entries

The following table provides minimum retention periods for official records.

Record Type

Official Log Book Part I
Official Log Book Part I
Official Log Book Part II
Articles and Crew Agreements
Oil Record Book Part I
Oil Record Book Part II
Noxious Liquid Substances Record Book
Garbage Record Book Part I
Garbage Record Book Part II
Record of navigational activities under SOLAS V/28
Radio records required by SOLAS IV/17

Ballast Water Record Book

Edit

Minimum Retention Period

7 years after entry made
7 years after entry made
7 years after expiry
3 years
3 years
3 years
2 years
2 years

1 year

1 year
2 years onboard

3 years by Company

Reference

s.145(1) Merchant Shipping Act
s.145(1) Merchant Shipping Act
s.82(h) Merchant Shipping Act
MARPOL Annex I Reg.17.6
MARPOL Annex I Reg.36.7
MARPOL Annex II Reg.15.5
MARPOL Annex V Reg.10.3.5
MARPOL Annex V Reg.10.3.5

A.916(22) para. 4.4

Barbados requirement

BWM Convention Regulation B 2.2

BMSR 03/08/2020

Copyright © Barbados Maritime Ship Registry. All Rights Reserved.
Barbados Maritime Ship Registry is an Executive Agency of the Barbados Government |

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

1. Please be advised that Barbados Maritime Ship Registry (BMSR) will no longer receive SSAS alerts directly from any vessels.

2. Shipping companies are required to designate either an internal appointee (preferably the Company Security Officer (CSO) or Alternate Company Security Officer (ACSO) or an external, qualified third party to serve as the “Competent Authority” to receive all SSAS alerts and take appropriate action.

3. BMSR requires that to be considered qualified, a Competent Authority must:

• Be available at all times (on a 24/7 basis) to receive and act upon SSAS alerts;
• Be able to accurately identify and react to real, test, or false alerts;
• Understand the SSAS requirements (Part A) and recommendations (Part B) of the ISPS Code and the Administrator’s SSAS requirements contained in the attached notice;
• Maintain a current contact list of relevant authorities (Administrator, Maritime Rescue Coordination Centres (MRCCs), Coastal State Authorities, Information Sharing Centres) to be used in the event of an actual alert; and
• Participate in drills or exercises involving tests of the SSAS.
• 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 Administration.

4. Only the real SSAS alerts are to be forwarded by the Company to BMSR at: ops@barbadosmaritime.com

5. 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 Administration immediately for cases of real SSAS alert.

6. SSAS alert messages must include the following ship information:

• Vessel Name;
• IMO Ship Identification Number;
• Call Sign;
• Maritime Mobile Service Identity (MMSI) Number;
• Date and Time (UTC);
• Global Navigation Satellite System (GNSS) position (latitude and longitude);
• Course and Speed;
• CSO 24/7 phone number; and
• Alternate CSO 24/7 phone number.

7. In view of above, it is recommended that Companies ensure that the SSAS unit is reprogrammed so that alerts are only transmitted to the designated Competent Authority and BMSR’s email address be removed from the unit’s program.

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

9. Testing of any newly programmed SSAS settings must be conducted to the satisfaction of the Competent Authority and any respective SSP amendment in regards to reprogramming of SSAS must be reviewed and same will be verified during the next scheduled ISPS Code verification audit after 1 January 2021.

BMSR 12/10/2020

Copyright © Barbados Maritime Ship Registry. All Rights Reserved.
Barbados Maritime Ship Registry is an Executive Agency of the Barbados Government |