DTTS – Temporary Contingency Planning for the Surveying & Certification

Information in relation to seafarer Certificates of Competency and Proficiency, medical certificates and seafarer employment agreements can be found in Marine Notice 14 of 2020. 

In light of the position of the European Union and of the International Maritime Organisation, the Irish Maritime Administration (IMA) of the Department of Transport, Tourism and Sport (DTTAS) is adopting the following measures in order to minimise the impact of Covid-19 on the maritime sector as much as possible and to protect the health of employees in the sector. 

The Irish Maritime Administration (IMA) of the Department of Transport, Tourism and Sport (DTTAS) has received enquiries regarding postponement of inspections and extending the validity of mandatory certificates due to difficulties caused by the COVID-19 outbreak. 

This includes an extension of statutory certificates or postponement of bottom inspections as a result of unavailable dry-dock facilities as well as timely completion of ISM Internal Audits and ISM/ISPS/MLC periodical verification. 

DTTAS considers the COVID-19 outbreak to be a force majeure situation and is implementing the following procedures with immediate effect. 

The shipowner/ISM Company is at all times responsible for ensuring that all its ships are operating according to all the applicable regulations, international Conventions, domestic and EU legislation. 

2/. Survey and Certification of Irish Ships-in-Service engaged in international trade 

DTTAS has agreements with recognised organisations (RO) for the survey, verification and certification of Irish ships in compliance with relevant international Conventions. Companies should endeavour to arrange surveys within the applicable time window as normal. 

Temporary Contingency Planning for the Surveying and Certification of Irish Registered Ships – COVID-19. Where this is not possible, due to personnel and travel restrictions that are currently in place around the world, the DTTAS has decided that all ships’ certificates which expire on or after the issue date of this Marine Notice will remain valid for 3 months from the date of expiry of the certificate without approval from the DTTAS or the RO. This extension applies to certificates issued by service providers, recognised organisations and recognised security organisations (RSO’s) carrying out surveys, verifications and inspections on behalf of the IMA. 

The extension also applies to certificates issued by service providers conducting services on behalf of the Administration or RO, including, but not limited to service providers recertifying life-saving equipment, fire-fighting equipment or radio equipment. 

The subject ship certificates are not required to be replaced by new certificates on which the extended date of expiry is stated. The above also applies in relation to expiration of the validity of certificates due to the fact that required annual/periodical/intermediate/renewal/bottom surveys cannot be held within the expiry window. 

In such cases where surveys are to be held/completed outside the time window, DTTAS will agree that and a note should be made on the certificate explaining the circumstances. The scope of survey that is to be used may be the same as if subject survey was held within the original window.

Annual ISM internal audits may be postponed for 3 months, as described in paragraph 12.1 of the ISM Code in cases where audits cannot be carried out due to travel restrictions imposed by COVID-19. The ship owner shall notify the ROs in cases where they make use of the above-mentioned provision. Similarly annual internal audits under the ISPS Code may also be postponed for 3 months with notification to the RSO as above. 

3/. Survey and Certification of Irish Ships-in-Service engaged in Domestic Voyages including fishing vessels

The survey of ships, passenger ships and passenger boats engaged in domestic voyages and fishing vessels will be considered on a case-by-case basis. Owners should apply for survey in the usual manner and they will be contacted by the Marine Survey Office (MSO) to discuss arrangements. 

4/. Survey and Certification of New-Building ships of all types for the Irish Flag 

Due to increased travel restrictions it is currently not possible for MSO Surveyors to travel to shipyards overseas. Therefore, the survey of new-building ships for the Irish flag of all types will be considered on a case-by-case basis in consultation with the shipyard and shipowner. In such cases the shipyard and shipowner should make direct contact with the MSO who will discuss arrangements. 

5/. Ships Radio Licences and Registration of EPIRBs 

Ship Radio Licence/Transfer Applications, EPIRB Registrations and general maritime radiocommunications related queries should be e-mailed directly to RadioSurveyors@dttas.gov.ie 

Relevant forms are available in an editable format at the following link, https://www.gov.ie/en/service/1d6ea4-maritime-radio/ 

As there may be delays in issuing hard copies of licences, a PDF version of the Ships Radio Licence and associated documentation may be emailed to applicants during this period. This PDF should be printed and retained onboard the vessel and be available for inspection purposes.

6/. Life Saving Appliances 

Routine Servicing of Life Saving Apparatus under SOLAS III Regulation 20.8.1.1 and national legislation permits an Administration to extend the period of servicing of inflatable liferafts, inflatable lifejackets and Marine Evacuation Systems (MES) to 17 months where servicing at the required interval is impracticable. The MSO recognises that servicing facilities may not be available due to the restrictions caused by the COVID-19 outbreak and therefore, subject to an onboard inspection by the Master, the MSO hereby extends the servicing of inflatable liferafts, inflatable lifejackets and MES by five months after expiry to a maximum total of 17 months. Operators are not required to approach the MSO to use this extension to service periods but should retain a copy of this Marine Notice on board for the guidance of officials should it be required. Routine on-board inspections of Life Saving Apparatus should continue as normal on equipment subject to the above extensions.

7/. Port State Control 

The Paris MoU on Port State Control has issued Temporary Guidance to its Member Authorities related to COVID-19 in which they require that when a ship does not comply with the requirements of the surveys, inspections and audits contained in the relevant conventions, the ship must provide evidence to the port State that the flag State has agreed to an exceptional delay specific to COVID-19. There should also be evidence that the ship has a plan that covers how the ship will be brought back into the regular survey or audit cycle. 

8/. Support 

All queries relating to this Marine Notice and to any issues affecting the operation of Irish ships should be addressed to the IMA. 

The IMA recognises the importance of ships and shipping in maintaining supplies and will endeavour to assist Irish ships and shipping companies where possible during this period. 

This Marine Notice will expire on 31 August 2020 and thereafter the provisions contained within will no longer be applicable. 

A further Marine Notice will issue before end of August to clarify the situation on this matter. 

Note: Marine Notices are issued purely for maritime safety and navigation reasons and should not be construed as conferring rights or granting permissions. 

Irish Maritime Administration, Department of Transport, Tourism and Sport, Leeson Lane, Dublin 2, D02 TR60, Ireland.

For any technical assistance in relation to this Marine Notice, please contact: The Marine Survey Office, tel: +353-(0)1-678 3400.

For general enquiries, please contact the Maritime Safety Policy Division, tel: +353-(0)1-678 3418. 

Written enquiries concerning Marine Notices should be addressed to: Dept. of Transport, Tourism and Sport, Maritime Safety Policy Division, Leeson Lane, Dublin 2, D02 TR60, Ireland. email: MarineNotices@dttas.gov.ie or visit us at: www.dttas.gov.ie