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• Maritime Labour Certificate ,Declaration of Maritime Labour Compliance required as per regulation 5.1.3 and standard A5.1.3 of MLC 2006 is not applicable for MODU (Mobile offshore drilling units and MOUS).

• Ship owners or operators may voluntarily certify their units through Recognized organization.

• The requirements of the MLC with respect to the living conditions onboard, including the requirements of financial security for repatriation (Regulation 2.5- Abandonment) and financial security relating to ship owner’s liability (Regulation 4.2) will be applicable if the seafarer or personnel employed are covered by STCW.

• Panama administration has established , personnel that  shall not be considered as seafarers taking into consideration the following factors as per  ILO resolution VII (regarding information on occupational groups):

a. the duration of stay onboard,

b. the frequency of periods of work spent on board,

c. the location of the person’s place of work, and

d. the purpose of the person’s work onboard.

• As per Panama national regulation the persons or the category of persons not considered as seafarers are defined in Merchant Marine Circular MMC-265 (enclosed).

• PSC and FSI will verify the requirement mentioned in Para 3.

• The platforms or MODU(Mobile offshore drilling units) are subject to safety annual inspections(ASI) ,which shall be performed by the Flag surveyors.

• Ship owners/ operators and masters are advised to be guided by above.

Enclosure:

1. MMC 251
2. MMC 265

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