Statutory Surveys by Marine Surveyors Cayman
The following article on Statutory Surveys, by Captain Michael Pickthorne, was first published in Lloyd’s List on 12 January 1999.
As an Independent Marine Surveyor, Captain Michael Pickthorne has been helping clients navigate this sea of interminable commercial vessel paperwork since 1999 and prior to that as a Flag state / Port state surveyor.
Statutory Surveys conducted with years of experience and knowledge, along with the attitude of “working together for compliance and safety”, can help insure safe and profitable voyages while minimizing any risks from authorities having jurisdiction.
In addition to experience as a Master Mariner and in Port State Control Authority on three continents, Captain Michael Pickthorne and company possess the resources of several maritime organizations as well as the resources of the Lloyd’s Agency and affiliates to minimize and effectively conduct your required statutory surveys.
for a consultation regarding your commercial maritime requirements for statutory surveys and how we can help you with your “Certificates Galore”.
By Captain Michael Pickthorne
There was a time when all that an owner needed to sail a ship was a captain, a crew, a compass, and a fair wind. A cargo was also a big incentive, of course, but there would have been little or no requirement for certificates except perhaps (depending upon the date) a Certificate of Registry.
Today the story is very different and there is a plethora of regulatory documentation required before a merchant ship of almost any size or description may legally sail from or enter a port or anchorage.
In the more recent past as a serving shipmaster, I remember the agent’s envelope containing the documents needed to report or clear the ship. It contained the Certificate of Registry, the De-Rat (or De-Rat Exemption) certificate and four International Safety Convention certificates as follows:
1. Load-Line Certificate
2. Safety Equipment Certificate
3. Safety Construction Certificate
4. Safety Radio Certificate
As is well known, the Load-Line Certificate is a result of the introduction of Samuel Plimsoll’s line whereas the last three certificates are requirements of the SOLAS Convention that came into being following the sinking of the “Titanic” in 1912. A passengers ship is slightly different in this respect as the three SOLAS certificates are usually combined into one called the Passenger Safety Certificate.
Earlier this year, I was involved with the registration of a small chemical tanker of less than one thousand tons gross. Apart from the Certificate of Registry, no less than eight certificates were required. Further to the list above we can now add the following:
5. International Tonnage Certificate (ITC 69)
6. Safe Manning Certificate
7. International Oil Pollution Prevention Certificate
8. Certificate of Fitness (for the carriage of bulk chemical cargoes)
No. 5 of the above replaces the previous national tonnage certificates that caused so much headache prior to the introduction of the International Tonnage Convention. Also, No. 8 only applies to chemical tankers although there is a similar one for gas tankers and soon one may be a requirement for bulk carriers. However, since then we have seen the introduction of the ISM Code and so we must now add the following:
9. Safety Management Certificate
10: Copy of Document of Compliance
Now one would think that a total of ten mandatory certificates of one sort or another, and mainly to do with the safety of the vessel, would be more than enough and probably about nine too many. After all, doesn’t an aircraft only need one? But wait! What do we see looming on the regulatory horizon, but more and more certificates? Moreover, the pace of their introduction is accelerating. They are advancing upon the unsuspecting ship owner and the bewildered shipmaster one after the other and sometimes two at a time. They would appear to be as unstoppable as was the Titanic on that fateful night to remember.
The days of the third engineer “blowing tubes” without a thought in the world other than (not) spoiling the freshly painted poop house or deck are numbered. It won’t be long now before such actions will/should be a thing of the past according to the new Annex VI to MARPOL. New ships constructed on or after the next Millennium Day will need to comply with this and they will need to carry an International Air Pollution Prevention Certificate to show that they do.
Traditionally, the master is responsible for maintaining the household standards of the ship and watching over the welfare of the crew. In British ships and those of many other nations, there was the ritual of Captain’s weekly inspection that generally took place on a Sunday morning at sea. This however, is now thought to be insufficient. The implementation of the ILO Convention 178 will herald the inspection of seafarers Working and Living Conditions by a flag state surveyor or authorized representative. An appropriate certificate will be issued on successful completion of this inspection. This will doubtless become known as the ILO Certificate.
Recently, on board a modern bulk carrier, I found two certificates not mentioned above. Namely a “Garbage Pollution Prevention Certificate” and an “International Sewage Pollution Prevention Certificate”.
Apparently some countries insist that their vessels carry these documents as proof that certain relevant standards have been met. Of course most of us are aware that ships are no required to carry a garbage management plan as required by Annex V of MARPOL, but it was understandably overshadowed by the implementation of the first stage of the ISM Code on the same day (July 1st).
As for sewage, most new ships are fitted with proper treatment systems. The need for “discharge boards” which had to be strategically deployed over the side of the ship in port by the crews to deflect the offending effluent from the toilet outlet pipes away for the quayside and into the dock must be long gone except perhaps for some small older vessels. Roving port officials must now look for other reasons to inflict on-the-spot-fines.
Whilst inspecting ballast tanks on a handy-size bulk carrier recently, I was not impressed by the large amount of mud in the tanks and this brought to mind the necessity for a good ballast water management on this category of vessel. All sorts of marine plants and small organisms have been exported to places where they are not wanted, as this sort of transmigration can create havoc with the environment. It is anticipated that a new Annex to MARPOL will be introduced incorporating the requirements of ballast water management. Some countries with sensitive coastlines, such as Australia with the Great Barrier Reef, have already implemented certain requirements to such vessels entering their waters.
Thus, in a few short years, more certificates will be required as follows:
11. International Air Pollution Prevention Certificate
12. ILO Certificate
13. Garbage Pollution Prevention Certificate
14. International Sewage Pollution Prevention Certificate
15. Ballast Water Management Certificate
This brings the total to no less than fifteen International Convention Certificates of one sort or the other. There are, of course, other certificates that ships may be required to have such as the De-Rat (or De-Rat Exemption) Certificate and the Insurance (CLC) Certificate. Also omitted are such items as the Intact Stability Booklet, Oil Record Book, Cargo Record Book (NLS), and the Garbage Record Book (Annex V).
I find the thought of fifteen or more mandatory certificates quite incredible. Do we really need as many as this to show that the various conventions are complied with? No, of course not. The whole business of certificate issue needs rationalizing or we risk maritime administrations becoming little else but “Certificate Factories”. Each and every one costs money whether issued from a remote sandy atoll, or the more sophisticated certificate production line of one of the larger of the representative organizations.
So how can we reduce this proliferation of paper? Let us see what a little amalgamation will do. Five of these certificates are in fact concerned with environmental protection of one sort or the other and could easily be combined . Carrying this exercise to a logical conclusion, I feel that no more than four certificates need be required which could be made up as follows:
1. Ship Certificate
Incorporating Certificate of Registry
Tonnage (ITC 69)
2. Safety Certificate
Consisting of Load-Line
Safety Construction (SOLAS)
Safety Equipment (SOLAS)
Safety Radio (SOLAS)
Certificate of Fitness (Chemical or Gas Tanker etc.)
3. Management Certificate
Incorporating ISM Certificate
Safe Manning Certificate
4. Environmental Protection Certificate
Consisting of IOPP Certificate (Oil)
ISPP Certificate (Sewage)
GPP Certificate (Garbage)
IAPP Certificate (Air Pollution)
IBPP Certificate (Ballast Water)
Some countries now re-issue a valid Certificate of Registry every five years and as this document is basically a description of the vessel it would make sense for this to be the primary part of the Ship Certificate.
We do not need to stop here of course as the above may be considered a first step. All could be brought together into one document, which perhaps could be styled the Certificate of Navigation. This should not be a cumbersome document as only a few parts require extensive information such as that in the Tonnage, Load Line, and Safe Manning Certificates. Check boxes would do for many. There should be a way of incorporating extensions into the system.
However, let us not forget the supplements to certificates, which are a recent introduction. These are the Safety Equipment Form E, Safety Radio Form R, MARPOL Supplement(s) and any approved cargo lists. These should comprise a separate document that could act as a guide to surveyors when carrying out their inspections. It would remain onboard the ship and be updated as required.
Although not perhaps back where we started, we would at least have only one document to worry about as in pre-convention days.
First published in Lloyd’s List on 12 January 1999 under the title “Merging mandatory certificates may curb paperwork gloom”.
Note: As of this publication November 1, 2014, the following Statutory Surveys
11. International Air Pollution Prevention Certificate (In force)
12. ILO Certificate (In force and known as the “MLC” certificate)
13. Garbage Pollution Prevention Certificate (in force)
14. International Sewage Pollutant Prevention Certificate (in force)
15. Ballast Water Management Certificate (in force Australia & USA California)
16. International Safety Management Certificate (introduce after events of 9/11)