Reference is made to Technical Circular No. 083/2020 based on DGS Order No. 13 of 2020 in respect of extension to the validity of Seafarers Certificates, Periodical Surveys and Audits in view of COVID-19 pandemic.
While the provisions of DGS Order 13 of 2020 dated, 2lst May 2020 remains applicable for ships with statutory certificates expiring on/prior 30 June 2020, Indian Administration has now issued DGS Order No. 17, dated 29 June 2020 providing revised procedures for grant of extension of statutory certificates to ships whose statutory surveys are expiring after 30th June 2020 but on/prior to 31st August 2020.
The revised procedure for extension to the validity of Statutory Certificates are as follows;
The Risk assessment by RO:
A Risk Assessment will be carried out by RO taking into account past survey and inspection history, satisfactory continuation of past imposed Condition of Class / Statutory Condition, if any, declaration by Master and CE that they have carried out a satisfactory general examination and a declaration by DPA/Owner/Manager that there is no known defect in any part of hull, machinery, fittings and equipment.
Extension of Annual /Periodical Statutory Surveys or Interim / Initial / Intermediate/ Renewal of Audits/Inspections:
All efforts are to be made by Owners / Managers to offer their ships to the RO for surveys within the survey window period to complete the surveys/ inspections / audits.
In general, no extension will be granted /considered unless the Recognized Organization provides in writing that the Surveyor cannot attend the ship due to lock-down at any port visited by the ship, after the issue of the DGS Order No.17 of 2020 (29 June 2020).
For an extension to be considered by the Administration on a case to case basis, same will be after a satisfactory Risk assessment, and will only be granted for the
period to enable the ship to reach a port where Recognized organization Surveyor can attend the ship.
Extension of Intermediate surveys:
No extension will be granted for a period more than 3-months after the due date of intermediate survey or 42 months since last dry-dock or the date of availability of dry-dock plus 15 days, which-ever is earlier.
The extension will be granted only upon submission of a firm evidence of date of dry-dock availability from the selected dry-dock.
The surveys related to Statutory Certificates not requiring dry-dock (such as Safety Equipment/Radio/IOPP/IAPP etc.) are to be completed either prior extension or at the first port, where RO Surveyor can board the ship during the period of extension.
The extension of surveys of Statutory Certificates requiring dry-dock (such as load-line/Safety Construction etc.) will be extended based on RO recommendation after satisfactory general examination of hull, machinery, fittings (structural and non-structural) and equipment, satisfactory thickness measurement, as applicable, examination of fore-peak ballast tank, aft-peak ballast tank and other representative water-ballast tanks, examination of fore-most and aft cargo holds and one other cargo hold in case of Single-Hull Bulk Carriers and a CCTV examination of the underwater portion of the hull, appendages, propeller and rudder.
The above Survey for extension is to be carried out either prior extension or at first port after extension, where RO Surveyor can board the ship. Extension without the stated surveys, even till the next port where a RO Surveyor can attend the ship shall be granted only after a Risk Assessment.
Extension of Renewal surveys beyond three months from expiry date:
For extension of renewal surveys by 3-months from expiry date or 36 months since last dry-dock, which-ever is earlier, the usual procedure for extension will apply.
No extension will be granted for a period more than 6-months after the due date of renewal survey or 42 months since last dry-dock or date of availability of dry-dock plus l5 days, which-ever is earlier.
The extension will be granted only upon submission of a firm evidence of date of dry-dock availability from the selected dry-dock.
The Surveys related to Statutory Certificates not requiring dry-dock are to be completed to-the extent possible either prior extension or at first port, where RO
Surveyor can board the ship during the period of extension. A risk assessment to be conducted for items outstanding to be completed at dry-dock such as 5-yearly load testing of life-boat/rescue boat and launching appliances and to be recommended for extension with the Risk assessment.
The Surveys of Statutory Certificates requiring dry-dock to be progressed as far as practicable. The extension will be based on RO recommendation after a satisfactory general examination of hull, machinery, fitting (structural and nonstructural), equipment's, satisfactory thickness measurement, as applicable, examination of fore-peak ballast tank, aft-peak ballast tank and other representative water-ballast tanks, examination of fore-most and aft cargo holds and one other cargo hold in case of Single-Hull Bulk Carriers and a CCTV examination of the underwater portion of the hull, appendages, propeller and rudder.
These Surveys are to be carried out either prior extension or at first port after extension, where RO Surveyor can board the ship. Extension without the stated surveys even till the next port where a RO Surveyor can attend the ship shall be granted only after a Risk Assessment.
In case Service supplier for 5-yearly load test of life-boat/rescue boat and launching appliances is unable to attend due to any reason, Owner can appoint any other local Service supplier who is approved by Directorate but may not be approved by Manufacturer. In such cases, the testing is to be conducted in presence of RO Surveyor.
Exemptions from Safe Manning Document:
Any dispensation from safe manning will be considered by the Administration on case to case basis where-in a seafarer is signed-off in an emergency and a risk assessment is submitted.
The extension of surveys beyond the IMO Convention provisions will be under the following conditions:
If the extension is granted beyond the IMO Convention provisions, the Company, prior entering any foreign load/discharge port, will take permission from relevant Maritime Authorities for acceptance of statutory certificates.
The Company to ensure increased monitoring of ship for safety of ship and seafarer by shore staff during the period of extension. Procedure for such monitoring is to be developed and approved by DPA (for ISM/DDOC ships) and records to be maintained for verification at next audit/FSI.
The waiver of applicable extension fees as applicable for surveys falling due on/before 30 June 2020 will also be applicable to ships to which the DGS Order No.17 of 2020 applies.
Ship owners/ operators and managers of Indian flagged ships contemplating delay in carrying out mandatory periodical surveys, audits and inspections due to the COVlD-19 situation are advised to be guided by above and act accordingly.
Enclosure:
Disclaimer:
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.