Technical Circular No: 102/2020
Download PDF1. The Marshall Islands Administration vide Marine Safety Advisory No. 25-20 has provided information on alternative arrangements where an auditor or inspector cannot attend due to restrictions imposed as a result of the COVID-19 pandemic.
2. Except as otherwise stated within the Safety Advisory, Recognized Organization (RO) or Recognized Security Organization (RSO) are required to inform and obtain concurrence from the Republic of the Marshall Islands (RMI) Maritime Administrator when utilizing these alternatives.
a. International Safety Management (ISM) Code:
i. Internal Annual ISM Verification: The Administrator will allow for a three-month extension to the 12-month interval for shore side and shipboard internal audits. Also for audits to be carried out during the extension period, the Administrator will accept a remote audit in lieu of a physical audit if it meets the requirements of the ISM Code.No further authorization to carry out a remote internal audit is required from the Administrator. This may also be applied to internal audits which are required to be completed prior to the external verification.
ii. External Initial ISM Verification: The Administrator will authorize an extension of the Interim Safety Management Certificate (SMC) in accordance with ISM Code §14.3. The validity will be for the minimum period required to complete the initial verification.
iii. Intermediate ISM Verification: The Administrator will authorize the issuance of a short-term SMC that is valid for a period of no longer than three months. Supporting documentation from the RO must show that the Company’s original request for the verification was made prior to the SMC’s third anniversary date.
iv. External Renewal ISM Verification: The Administrator will authorize an extension of the SMC for no longer than three months in accordance with ISM Code §13.14.
v. Document of Compliance Verification: Where a Company cannot complete the required Document of Compliance (DOC) verifications in accordance with ISM Code, the Administrator will authorize the issuance of a short-term DOC. This will be handled on a case-by-case basis upon a recommendation from the RO.
b. International Ship and Port Facility Security (ISPS) Code:
i. Internal Annual ISPS Verification: The Administrator will allow for a three-month extension to the 12-month interval for shore side and shipboard internal audits. Also for audits to be carried out during the extension period, the Administrator will accept a remote audit in lieu of a physical audit if it meets the requirements of the ISPS Code. No further authorization to carry out a remote internal audit is required from the Administrator. This may also be applied to internal audits which are required to be completed prior to the external verification.
ii. Initial ISPS Verification: The Administrator will authorize a consecutive Interim International Ship Security Certificate (ISSC) in accordance with ISPS Code A-19.4.5. The validity will be for the minimum period required to complete the initial verification.
iii. Intermediate ISPS Verification: The Administrator will authorize the issuance of a short-term ISSC that is valid for a period of no longer than three months. Supporting documentation from the RSO must show that the Company’s original request for the verification was made prior to the ISSC’s third anniversary date.
iv. Renewal ISPS Verification: The Administrator will authorize an extension of the ISSC for no longer than three months in accordance with ISPS Code A-19.3.5.
c. Maritime Labour Convention, 2006 (MLC, 2006):
MLC, 2006 does not provide for the extension of initial, intermediate, or renewal inspections. However, where there is adequate justification and supporting documentation that an inspector is unable to attend, a short-term certificate may be issued. The validitywill be for the minimum period required to complete the required inspection.
d. Remote External Verifications:
Remote external verifications are audits conducted using Information and Communication Technology (ICT) where physical attendance to the site being audited is not possible.
3. Ship owners/ operators and masters of Marshall Islands flagged ships are advised to be guided by above.
4. This Technical Circular supersedes and revokes earlier Technical Circular No. 019/2020, dated 24 March 2020.
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.