LP 44/2020 Flag States Arrangements for Extending Ship Surveys and Seafarer Certificates Under the COVID-19 Pandemic Situation
Under the United Nations Convention on the Law of the Sea, the flag state effectively exercises administrative, technical and social control over ships flying its flag. As countries and regions strengthening their prevention and control measures to prevent further spread of the COVID-19 pandemic, flag states’ obligations on ship control have also been affected. Flag state administrations of entered ships have all introduced temporary measures to facilitate normal operation of ships and the Club has put together such measures regarding ship inspections and seafarers for Members’ reference.
China
— Notice on Extension of Duration of Related Certificates of Chinese Flagged Ships and Chinese Seafarers Engaged in International Voyages
1. Validity of ship survey certificates, Safety Management Certificate (SMC), Document of Compliance (DOC) and International Ship Security Certificate (ISSC) with dates of expiry falling between 20th January 2020 and 30th September 2020 will be extended to 30th September 2020 in case that it is impossible to proceed with the surveys, audits and inspections due to impact of the COVID-19. The anniversary dates of above-mentioned certificates will be unchanged after extension.
2. Validity of Certificate of Competency (CoC) and Certificate of Proficiency (CoP) for seafarers of the People’s Republic of China engaged in international voyages and Medical Certificate for seafarers of the People’s Republic of China currently serving international voyages, with dates of expiry falling between 20th January 2020 and 30th September 2020, will be extended for 6 months starting from the next day of expiry dates of the certificates automatically in case that it is impossible for seafarers to go through with the trainings, examinations/assessments or medical examinations due to the impact of the COVID-19. Furthermore, the extension of Medical Certificate requires the seafarer’s written declaration of compliance with seafarer’s medical requirements which shall be agreed and signed by the ship’s Master.
— Notice on Revalidation of Certificates of Seafarers Engaged in International Voyages
Seafarers that have been serving on board or plan to get on board and whose Class A Seaman’s Book or Certificate of the Training for Seafarers was expired after 1 December 2019 or within 12 months of validity period may apply for revalidation by submitting a company-issued responsibility letter. Other document as required shall be submitted later after the COVID-19 epidemic.
— Notice on Suspending Maritime Services for Chinese Flagged Ships Engaged in Domestic Transportation
1. Annual inspections, audits and renewal that cannot be arranged by regional maritime administrations or surveyors during the COVID-19 epidemic can be postponed without any administrative penalties imposed.
2. For passenger ships, ships carrying dangerous goods, ships carrying sands and gravels, ships carrying solid bulk cargo that may liquefy, and ships transporting anti-epidemic resources, owners/operators shall carry out stringent self-inspections and report to ship survey institutions in a timely manner if onsite surveys cannot be arranged due to the COVID-19 situation.
— Notice on Crew Replacement for Chinese Flagged Ships Engaged in International Voyages
1. SEA or the contracted service period may be extended with written consent of the seafarer. A supplementary contract shall be signed, and the overall service period shall be less than 12 months.
2. Companies shall report to the maritime authority at the ship’s port of registry within the first month after the SEA/contract is extended.
3. For crew members who have served continuously for 12 months, the company shall immediately arrange for a shift. If it cannot be arranged due to epidemic prevention and control measures, no more work shall be allocated to the crew member. Where the ship cannot meet the requirements of the Minimum Safety Manning Certificate may apply to the maritime authorities for an exemption with adequate justification provided.
— Notice on Issuance of Seaman’s Book During the COVID-19 Epidemic
1. Seafarers currently serving on board ships and whose seaman’s book is about to be expired within 6 months may apply for remote issuance.
2. The issuing authority will issue a temporary seaman’s book with one-year validity for qualified seafarers.
3. Seafarers holding temporary seaman’s book should return it to the issuing authority within the 10 working days after they get back to China.
Source: China MSA Notices
Hong Kong, China
— Extension of Crew Agreement Service Period
1. An extension of a seafarer’s service period can be exercised pursuant to section 3A of the Merchant Shipping (Seafarers) (Repatriation) Regulation (Cap.478Q), provided that such extension is agreed by the seafarer voluntarily in writing. Such extension should also be set out properly in the crew agreement and should be submitted to HKMD within 28 days after signing in accordance with the requirement as stipulated in section 6 of the Merchant Shipping (Seafarers) (Crew Agreements, Lists of Crew and Discharge of Seafarers) Regulation (Cap. 478L).
2. No exemption or dispensation is required.
— Seafarers’ Qualifications
1. For seafarers with sea service period beyond expiry date of Certificate of Competency (CoC) or Consolidated Receipt of Application (CRA), please refer to the following arrangements:
a) If as a result of the Covid-19 pandemic, ship managers are unable to deliver the Hong Kong License (HKL) on board before the expiry of the CRA, ship managers may apply via email or fax for MD to issue an official email with scanned copy of the applicant’s HKL to prove the original HKL has been issued and being is sent to the applicant.
b) If the seafarer is unable to revalidate his/her foreign issued CoC and consequently the HKL due to the Covid-19 pandemic, the ship manager may submit an application form to MD, accompanied by a confirmation of extension of validity by the seafarer’s CoC issuing administration. MD will issue a confirmation to extend the HKL to enable the seafarer to continue to serve on that specified Hong Kong registered ship.
c) For Hong Kong CoC holders, MD will consider extending the validity of their CoC up to three months from the date of expiry.
2. For seafarers with expired medical fitness certificates, the ship manager may apply for an exemption to allow the seafarer to continue to serve on board that vessel.
3. All applications as mentioned above may be submitted to the Seafarers’ Certification Section by email, fax or by telephone:
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Fax: (852) 2541 6754
Tel: (852) 2852 3148
— Surveys, Audits and Statutory Certificates
1. In light of the COVID-19 pandemic, MD may extend the validity of statutory certificates issued by Recognized Organization (RO) on behalf of the Government of HKSAR for a period up to three months from the window end date or expiry date of the certificates.
2. For the benefit of doubt, the above-mentioned statutory certificates include Document of Compliance and Safety Management Certificate.
3. Under extreme situation, owners may require further extension of the certificates. MD may consider issuing extension of another three months with the support of the respective RO and documented attempt with best effort to comply with the survey requirements.
4. Remote audit is acceptable for DOC annual audit (but not renewal audit) provided prior agreement from MD with each RO is reached. Remote audit for SMC is not acceptable.
5. Enquiries can be sent via email, fax or by telephone:
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Fax: (852) 2545 0556
Source: Special Arrangements by the Hong Kong Marine Department under COVID-19 Pandemic Situation
Singapore
— Extension of Sea Service beyond Contract Period
SRS owners and managers unable to repatriate seafarers who have completed the employment duration may submit a request to MPA for extension of the sea service period.
a) Documents to be submitted include employment details of the affected seafarers, confirmation of consent by the affected seafarers and the Crew List.
b) The extension of contractual period of the seafarers should be reflected on the corresponding SEA of the affected seafarers.
— Extension of Sea Service Period beyond Qualification Revalidation Deadline
1. Consideration will be given to allow seafarers who hold foreign issued Certificates of Competencies (COC) to continue serving onboard SRS, if they are unable to revalidate their COC before the expiry date due to the COVID-19 outbreak. SRS owners and managers may submit such request in-writing to MPA, accompanied with a confirmation of continued validity from the issuing authority of the seafarer’s COC.
2. MPA will issue a flag administration confirmation letter for the seafarer to continue serving onboard SRS. No fees will be charged for this endorsement.
3. For Singapore COC holders, MPA will issue a letter to extend validity of the COC of the holders who may not be able to disembark due to the captioned grounds, similarly without fees.
— Extension of Mandatory Surveys, Audits and Expiry of Statutory Certificates
1. Application for extension of surveys/inspections/audits or validity of statutory certificates may be submitted to MPA, accompanied by recommendation from the recognised organisation (RO) that issued the relevant certificate on behalf of MPA.
2. MPA advises SRS owners and managers to submit such application before the due date of the surveys/audits or expiry date of the statutory certificate in order to avoid Port State Control issues.
3. All application for dispensations may be submitted to MPA at email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Panama
— Extension of Seafarers Employment Agreement
SEGUMAR shall issue letters to extend the SEA for a period of 3 months upon receiving emails requesting such extensions.
— Extension of Seafarers Certificates
1. SEGUMAR shall issue letters to extend the certificates for a period of 3 months from the date of expiration upon receiving required documents, and review whether the granted extension shall require additional period considering the condition of the COVID-19.
2. The period of validity for the full-color copy of the Transitory Certificate stated on MMC-313 is extended for ninety (90) calendar days, counting from the issuing date of the CT.
3. If any Third-Party member of the STCW 78 Convention, who issued the Seafarers Certificate has not extended it due to the coronavirus outbreak, SEGUMAR shall grant a Dispensation Letter to the capacity under the requirements stated in the MMC No. 175 and the form established by the circular MMC-191 shall be submitted.
4. If the Medical Certificates expires, it shall continue in force in this exceptional circumstance for a period of three (3) months from its expiry date.
— Extension of statutory certification and services
1. All surveys, audits and inspections are extended for a period of three (3) months and the RO is authorized to maintain the validity of the statutory certificate for the grace period.
2. Annual services of life saving appliances and firefighting equipment with due date between March and May 2020, are allowed for an extension valid for one month subject to the agreement of the Recognized Organization. Extensions required for a maximum period of three months will be granted on a case by case basis.
3. Shipowners/operators of those ships currently holding a Conditional Certificate related to a deficiency or damage onboard, if the RO agrees with the conditions on board, shall contact SEGUMAR if the necessary malfunction, repair or administrative related matter is not possible to rectify, carry out or be provided; an email along with supporting evidence shall be sent to This email address is being protected from spambots. You need JavaScript enabled to view it..
4. The validity of all statutory certificates (except for Conditional Certificates) expiring between March and May 2020 are extended exceptionally for three months.
5. Color copy of original signed Ships Registry Certificates (Patent) and Radio Station License issued by SEGUMAR are considered valid for three months from its issue date.
6. Soft copy Exemption Certificates and Minimum Safe Manning Certificates for MODU/MOU issued by SEGUMAR are considered valid for three months, from the issue date.
7. The postponement of the inspection of the outside ships’ bottom is subject to the guidelines provided in MMC No.204.
Source: MMN-03/2020-CORONAVIRUS AND SEAFARERS EMPLOYMENT AGREEMENT AND CERTIFICATES
MMN-07/2020 COVID-19 Request for Postponement- Extension of Statutory Certification & Services
The Republic of Marshall Islands
— Ship surveys and statutory certificates (MSA14-20, MSA11-20, Tech Circ-13)
In extreme cases where neither a physical attendance nor a remote survey can be organized, then the RO may recommend a period of grace of up to three months.
— Seafarers’ certificates (MSA12-20)
1. The validity of RMI issued original CoCs, CoPs, and STCW Medical Certificates will be granted an extended validity of six months (from date of expiry) or until 1 October 2020.
2. RMI will honor all extensions allowed by the certificate issuing Administration by extending RMI Certificates of Endorsement accordingly.
— Crew contracts (MSA12-20)
1. RMI allows for extended SEAs as provided in Marine Notice 7-052-2 and is handling these issues on a case-by-case basis with recognition on Port States and ITF requirements.
Source: UPDATES REGARDING THE CORONAVIRUS DISEASE (COVID-19)
The Republic of Liberia
— The ISM audit and SMC
1. The administration will authorize an extension for up to one month to the internal initial ISM audit.
2. The internal annual ISM audit can be conducted remotely in lieu of the onboard audit.
3. The external initial ISM audit is granted an extension of validity for 6 months, and the administration will extend the interim SMC with adequate justification provided.
4. The external renewal audit is granted an extension of validity for 3 months.
— The ISPS audit and ISSC
1. The administration will extend the internal initial ISPS audit for up to one month.
2. The internal annual ISPS audit cannot be extended further.
3. The interim ISSC cannot be extended, but the administration will authorize the RO to issue a subsequent interim ISSC with adequate justification provided.
4. The external renewal audit is granted a period of three months extension.
— MLC 2006
1. The MLC 2006 inspection and certificate cannot be extended.
2. The Administration may issue a letter authorizing the vessel to sail to the next available port where the audit, or inspection can take place.
— SEA
Per paragraph 3.5.4 of Marine Notice MLC-003, the administration allows a seafarer to postpone his/her annual leave and continue to be engaged beyond the 11 months, provided:
1. Both the seafarer and shipowner agree for seafarer to forego annual leave, if the period of engagement on board will exceed 11 months;
2. A proper risk assessment is carried out by the shipowner taking into account the ship’s trading pattern, rest hours, and fatigue and other identified hazards.
— COC
1. If the Country issuing the seafarer’s national COC is asked to issue an extension of the national COC, Liberia will issue an endorsement of the extension.
2. If this cannot be accomplished, the Administration may, on a case by case basis, issue a short-term dispensation letter allowing the seafarer to continue to sail in their present capacity until the vessel reaches the first port where he/she can be replaced and repatriated.
The Bahamas
— Surveys, audits and inspections
1. Where a surveyor is not able to undertake scheduled surveys due to restrictions imposed by COVID-19, the BMA authorises its RO to consider applications for extension/postponement under force majeure or unforeseen exceptional circumstances and administratively issue short term statutory certificates for up to 3 months without prior approval of the BMA.
2. For statutory surveys delegated to Bahamas RO, the RO shall consider the application, which should include full supporting information, before issuing short-term certification. The Master shall provide a statement to the RO confirming the structure or equipment to be surveyed remains fit for purpose and has not been subject to any damage.
3. The BMA permits extensions to annual ISM and ISPS internal audits for up to 3 months.
4. For interim ISM DOC audits, SMC audits and ISPS external audits where it is not physically possible to attend and remote audit is not practicable, the BMA permits the issue of interim DOC, SMC and ISSC.
5. For initial ISM DOC, SMC audits and ISPS external audits where it is not physically possible to attend and remote audit is not practicable, the BMA permits the issue of a second interim DOC/SMC for up to 6 months, without prior approval of the BMA.
6. For ISM DOC, SMC and ISSC intermediate audits, if these are not completed within the range date the certificate ceases to be valid, the RO may issue a new SMC or ISSC valid for 3 months, without prior approval of the BMA.
7. For DOC, SMC and ISSC renewal audits, the BMA authorises its RO to issue 3-month extensions without prior approval of the BMA.
8. For interim MLC inspections where it is not physically possible to attend and remote inspection is not practicable, the BMA permits the issue of an interim MLC for up to 6 months, without prior approval of the BMA.
9. For initial MLC inspections where it is not physically possible to attend and remote audit is not practicable, the BMA permits the issue of a second interim MLC for up to 6 months, without prior approval of the BMA.
10. The BMA authorises its RO to issue a short-term Maritime Labour Certificate for 3 months, without prior approval of the BMA, in cases where the renewal or intermediate inspection cannot be conducted due to COVID-19 restrictions.
The above measures will temporarily remain in place until 30 June 2020 and are subject to review as the situation develops.
— Seafarer employment
A new SEA shall be arranged with the following text inserted:
The seafarer is permitted to terminate the contract giving 7 days’ notice when the force majeure situation caused by the COVID-19 pandemic permits him/her to travel to his/her destination safely and securely.
— Seafarer medical certificates
1. If any seafarer’s Medical Certificate expires whilst he/she is on board, the seafarer can continue his/her service for up to 3 months. If the medical certificate expires prior to 01 July 2020 the validity of the certificate is automatically extended to 01 October 2020.
2. Seafarers, who are on leave, and their Medical Certificates have expired after 31 March 2020, are permitted to commence their service onboard ships until 01 July 2020.
— STCW certificates
1. If a CoC or a COP that The Bahamas has endorsed expires and the issuing State has extended the period for which the certificate is valid, this document/endorsement shall automatically be extended by The Bahamas for the same period.
2. If a CoC or a CoP that The Bahamas has issued expires prior to the 01 October 2020, the validity period is extended until latest 01 October 2020.
3. All STCW, MLC and Minimum Safe Manning Documents will be issued electronically by e-mail during COVID-19 restrictions and will not be printed.
Source: COVID-19: General BMA information: Technical Alert 20-03
Tuvalu
— SEA (MC-2/2020/2)
A seafarer’s service period may be extended on condition that any such extension is:
1. Agreed by the seafarer voluntarily in writing; and
2. Is properly set out in the SEA which shall be in accordance to the Tuvalu Merchant Shipping (MLC 2006) Regulations.
— Surveys, audits and statutory certificates (MC-4/2020/2)
Where adequate justification shows that surveys, audits and certificates renewal is not possible, the Administration will, in consultation with the RO, consider taking the below measures under force majeure on a case-to-case basis:
1. Statutory surveys and certificates: postponement of survey, servicing of equipment, and/or certificate extension beyond the maximum three (3) months in the event where scheduled surveys are unable to be performed, either by physical attendance or remote means.
2. DOC: extending the DOC where the company cannot complete the required initial or annual verifications.
3. SMC, ISSC, MLC: extending the interim certificates where the initial ISM shipboard audit cannot be carried out; extending the intermediate audits and authorize RO to issue short-term certificates with corresponding validity; extending the certificates where the renewal audits cannot be carried out.
St. Vincent and the Grenadines
— Statutory surveys and dry-docking surveys
In cases where schedules surveys and servicing cannot be practiced due to restrictions imposed by COVID-19, shipowners/ship operators can apply for extension under force majeure as per GEN 001 circular.
— Audits
1. The administration will extend annual ISM internal audits for up to 3 months.
2. The administration may authorize its RO to issue 3-month extensions to existing SMC and ISSC certificates.
3. Due to COVID-19 restrictions this Administration may authorize its RO to issue a MLC for 3 months where the renewal inspection cannot be conducted.
— SEA and repatriation
The administration will consider extensions of SEA to be force majeure and a new SEA shall be signed by both parties with the clause that the seafarer is entitled to repatriation at no cost to the seafarer at 7 days notice.
— STCW certificates
Application for extensions should be submitted to the administration including CoC or CoP endorsed with a new expiry date by the issuing Administration.
— Medical certificates
Seafarers with a medical certificate about to expire or no longer valid will be allowed to keep serving on board for a period of up to 3 months.
These temporary measures shall remain in place for a period of 3 months starting from 18 March 2020 and are subject to review as the situation develops.
Source: GEN 025-Rev.1 COVID-19 Advice From Maritime Administration
Malaysia
— Seafarer documentation (MSN 02/2020 Annex II)
1. SEA which expires during the period may apply for an extension of additional 1 month, as long as the total period of the SEA including the extension is not more than 13 months.
2. For the Malaysian seafarer serving on board any ship, and his/her seafarer documentation has expires during the period, may apply for an extension until 30th of June 2020. The application is recommended to be made through online system and using the exemption form provided in MSN 09/2019.
3. For foreign seafarer who is currently on board Malaysia flagged-ship and his/her COR has expires during the period, the extension of his/her CoC or CoP validity must first be approved by the Flag State of Issuance. The application for an extension period until 30th of June 2020 is recommended to be made through online system and using the exemption form provided in MSN 09/2019.
— Surveys, audits and statutory certificates (MSN 02/2020 Annex V)
1. MMD authorizes RO to issue an extension for a period not exceeding 3 months or until 30 June 2020, whichever is earlier.
2. For intermediate dry-docking surveys, MMD approves an extension for a period not exceeding 2 months or until 30 May 2020 (whichever is earlier); for renewal audits, MMD approves a 1-month extension or a 3-month one if the interval between the two dry-docking surveys is less than 36 months.
Source: Malaysia Shipping Notice
Belize
— IMMARBE’s Technical Department granting extension on mandatory surveys and audit up to May 31st, 2020
1. Requests shall be submitted by the RO in charge of the mandatory certification.
2. RO shall submit temporary measures based on their procedures and requirements to be followed on board to keep the vessel in good standings during this period.
3. Shipowners/Operators shall submit the Self-Inspection Checklist in accordance with MMN 20-001 through the RO.
— IMMARBE’s Technical Department granting dry-docking extension up to May 31st, 2020
1. Request shall be submitted by the Deputy Registrar of the vessel using the form TDF-006.
2. The request shall contain a shipyard rejection letter along with a written confirmation of acceptance issued by the RO.
Any vessel falling under above measures shall be provided with electronic certificates by the authorized RO to be valid until May 31st, 2020.
Source: MMN-20-002 Technical Department Novel Coronavirus (COVID-19) Temporary Measures
Bermuda
— SEA
Owners and managers may submit a request to BSMA for extension of the sea service period with the employment details of the affected seafarer and his/her confirmation of consent attached. The extension of the contractual period of the seafarers should be reflected on the corresponding SEA of the affected seafarers.
— Medical certificate
The administration approves a 6-month extension of expiring medical certificates.
— STCW certificate
Where a Seafarer’s CoC has been extended by the issuing authority, the BSMA agrees that the corresponding Bermuda Endorsement may be considered as extended by the same duration. No further application is required.
— Surveys, audits and statutory certificates
1. Consideration will be given to the extension of mandatory statutory surveys, inspections or audits under force majeure or other unforeseen exceptional circumstances.
2. Where ISM Internal Audits may be exceeded due to the current exceptional circumstances related to Covid-19, an appropriate entry should be made in the ship’s Official Log Book to document that the audit will be arranged at the next possible date.
3. Where ISM (SMC), ISPS (ISSC) and MLC Initial audits cannot be arranged, the administration will extend these certificates for an additional 6 months, to the maximum 12 month validity upon receipt of the ship Master’s Self Declaration (Form FSUR T357).
4. Where ISM (SMC), ISPS (ISSC) and MLC Intermediate and Renewal audits cannot be arranged, the administration will issue short term SMC, ISSC and MLC certificates, valid for three months, upon receipt of the ship Master’s Self Declaration (Form FSUR T357).
5. Where DOC initial audits cannot be arranged, BSMA will issue a short term DOC certificate valid for three months, upon receipt of the company DPA’s Company Self Declaration (Form FSUR T356).
6. Where DOC annual and renewal audits cannot be arranged, BSMA will issue a short term DOC certificate valid for three months, upon receipt of the company DPA’s Company Self Declaration (Form FSUR T356).
Source: Bermuda Guidance Notice 2020-03 - COVID-19 Continuity of Ship Certification
Bermuda Guidance Notice 2020-01 UPDATED - Corona Virus (Covid-19)
Bermuda Guidance Notice 2020-04(01) - COVID-19 Arrangements for Seafarer Documents
Indonesia
— Seaman’s book
If a Seaman’s Book expires while the relevant crew member is onboard and not permitted to enter the port or the transit country has implemented a lockdown in response to COVID-19, the expired Seaman’s Book may be deemed as valid until the relevant authorities in the transit country allow the crew member to disembark and renew the Seaman’s Book at the Indonesian Embassy.
— Seafarers service agreement and repatriation
1. Where the seafarer’s service period has due, his/her original SEA will remain valid before the seafarer is repatriated or the contract is extended. The company, however, will have to repatriate or replace the seafarer as soon as possible.
2. The additional costs of repatriation, medical services or any other expenses related to COVID-19 pandemic are to be borne by the company.
3. For crew members have obtained permits to be disembarked in certain ports and have booked tickets, the Indonesian authority will approve the leave, taking into account health of the crew and the anti-epidemic measures in destination countries.
— CoC and COR
1. Seafarers whose CoC or CoP expires between March 1 and May 31, 2020 may email a copy of their certificate to DGPL at This email address is being protected from spambots. You need JavaScript enabled to view it. and a temporary certificate valid for three months will be issued.
2. Foreign nationals working on Indonesian-flagged ships whose Certificate of Recognition (COR) expires between March 1 and May 31, 2020, may email a copy of their certificate to DGPL at This email address is being protected from spambots. You need JavaScript enabled to view it. and a temporary certificate valid for three months will be issued.
3. Even if the ship is affected by the pandemic, the crew’s qualification should be considered to be in accordance with STCW requirements.
4. For intern/apprentice that is conducting practice on board and cannot continue the practice due to the outbreak, a competency certificate will be issued if he/she has completed 9-month practice on board and will finish the rest by means of training.
— Minimum Safe Manning Document
The administration will provide an exemption for the Minimum Safe Manning Document on a case by case basis if the crew must be lowered due to COVID-19 and the owner or operator has not been able to provide substitute after risk assessment.
— Medical certificates
Pursuant to STCW and MLC 2006 regulation, the administration allows the certificate to remain valid for an additional 3 months after its expiration in certain circumstances such as the COVID-19 pandemic.
Source: DGST Circular Letter No.11 of 2020 ACTIVITY PLANNING (CONTINGENCY PLAN) FOR COVID-19 OPERATORS AND OWNERS OPERATORS
For more information, please contact your manager at the Club.