COVID-19 Impacts Ship Surveys and Certificates

SOLAS chapter 1 regulation 14(e) allows Administrations to extend the period of validity of certificates under specific circumstances. It allows for an extension of three months. Many organisations are considering using this allowed extension in circumstances where surveys cannot be arranged due to COVID-19 restrictions.

Regional PSC organisations:

Temporary guidance has been issued by the Paris, Tokyo, Caribbean and Indian Ocean MOUs and the United States Coast Guard, which recognises the need for flexibility under these special circumstances. The COVID 19 restrictions taken by individual States have impacted the PSC inspection regime, and PSC authorities are responding with a pragmatic approach.

The guidance issued recognises that delayed surveys, inspections, extensions for ship’s certificates, extended periods of service on board, and delays with personnel certification may be due to COVID-19. It is recognised that crew may also struggle to attend training courses and re-validate their tickets.

A practical approach will be used on a case by case basis for extension periods up to three months. Flag State and, if appropriate the Recognised Organisation may be actively involved in reviewing the plan made by the vessel to bring it back to full compliance with requirements.

Whether an inspection takes place remains the decision of the port State. This may be influenced by COVID-19 cases or self-isolating vessels.

MOUs have issued specific guidance for COVID-19 which can be accessed below:

• Paris MOU
• Tokyo MOU
• USCG
• Vina Del Mar Agreement
• Indian Ocean MOU
• Riyadh MOU
• Black Sea MOU
• Caribbean MOU
• Abuja MOU

Statutory surveys and certificates – Marine Administrators and Classification societies

If the Recognized Organization (RO) considers that there is a reasonable case which has been affected by COVID-19, the Administrator may accept an application to extend survey windows by three months if the vessel is not deemed substandard.

In addition to a vessel being quarantined examples of problems created by COVID-19 may include a surveyor, auditor, essential superintendent, technician or service team being restricted for travel or if specialised equipment, repair facilities or essential spares can’t be supplied to the vessel.

In many cases short term certificates may only be valid for 3 months from the expiration date of the previous certificate or the closure of the appropriate survey window.

Many Classification Societies have noted a recent increase in their remote survey programmes. Remote surveys can assist shipowners and classification societies to keep inspections and certification valid.

The specific Marine Administrator or RO for your vessel will advise on extensions related to Safety Management Certificates (SMC), ISM, ISPS Audits and other matters not covered by the three-month extension.

The latest IMO guidance on COVID-19 can be found here.

Stay up to date with the coronavirus impact on shipping at our dedicated COVID-19 expertise area here.