The COVID-19 pandemic has posed a serious challenge for ship certificates and all the associated surveys and audits, with the result being that ships are in a position where their certificates are expiring because of difficulties arranging the necessary surveys, audits or drydocks in order to renew their certificates.
In light of the above, the International Maritime Organization issued a circular, highlighting the importance of rapid of implementation and enforcement of relevant IMO Instruments, urging no unnecessary delays to ships.
Following the Administrations followed IMO's call, intending to apply the same reasonable and pragmatic approach for at least three months during PSC inspections of foreign ships calling at their ports.
The following are some of the main elements of the national circulars/advisories issued to date on the subject of ship certificates and associated surveys:
- Statement that the validity of certificates is extended for a certain period of time;
- Statement that surveys are postponed and shore-based activities related to ship certificates are suspended;
- Statement on whether the extension of validity of certificates will be on a case-by-case basis or a ‘blanket’ approach to ship certificates;
- Statement on whether the extension of validity of certificates applies onto those issued by the Administration or also to those certificates issued by ROs on its behalf;
- Specification of any documentation that will be issued to the ship to evidence the extension given to its certificates;
- Specification of a deadline where certificates expiring after which are not within the scope of the extension;
- Specification of a date when normal statutory survey and certification activities will resume or the suspension of activities will be removed;
- Specification of the alternative or short-term certificates or documents that can be issued to the ship (e.g. electronic short-term certificates);
- Specification of the procedures required to be followed to obtain extensions to the certificates;
- Specification of the supporting document(s) required to evidence that the necessary survey(s) could not take place (e.g. letter from the port authority about the placement of quarantine on the ship);
- Information on temporary or alternative arrangements available where the attendance of a surveyor is not possible (e.g. remote inspections or self-inspection protocols);
- Information on the legal basis or justification relevant to the extension of ship certificates being provided (e.g. provisions from SOLAS and MARPOL);
- Statement that the validity of any certificate can be verified by contacting the flag State.
Furthermore, the Association highlights that
Shipowners and operators are advised that only the Administration can make decisions about the approach they will pursue in cases where necessary surveys and audits cannot take place in time and result in the expiration of ship certificates.
When it comes to the validity of ship certificates, ICS recommends that shipowners and operators should:
- Contact their Administration(s), or ROs providing statutory services on behalf of the Administration(s), to confirm their approach to the extension of ship certificates in light of difficulties undergoing surveys and audits during the COVID-19 pandemic;
- Contact their classification society (or societies) to confirm their approach to the extension of class certificates in light of difficulties undergoing surveys and audits during the COVID-19 pandemic;
- Document all actions and correspondences performed to endeavour to arrange all necessary surveys and audits required for the normal renewal of ship certificates and more.
In addition, ICS pays a closer attention to other issues arising from the COVID-19, such as the installation and commissioning of Ballast Water Management Systems (BWMS), the potential implications of the expiration of ship certificates during the COVID-19 pandemic on P&I cover, as well as the potential implications of the expiration of ship certificates during the COVID-19
pandemic on charterparties.
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