**Executive Summary**
DGS Order 17 of 2020, dated June 29, 2020, addresses the extension of validity for Seafarer's Certificates and Ship's Statutory Certificates due to the COVID-19 pandemic. This order revises the procedure for granting extensions on statutory certificates expiring after June 30, 2020, but on or prior to August 31, 2020, and is valid until August 31, 2020. DGS Order 13 of 2020, dated 21st May 2020 remains applicable for ships with statutory certificates expiring on/prior 30 June 2020
**Key Points / Main Content**
* **Extension Applicability:**
* This order revises procedures for ships with statutory surveys expiring after June 30, 2020, but on/prior to August 31, 2020.
* DGS Order 13 of 2020 remains applicable for ships with statutory certificates expiring on/prior 30 June 2020.
* **General Conditions for Extension**
* Extensions are generally not granted unless the Recognized Organization (RO) confirms in writing that a surveyor cannot attend the vessel due to lockdown.
* Extensions are considered on a case-by-case basis, following a satisfactory risk assessment, solely to allow the ship to reach a port with an available RO surveyor.
* Risk assessments are based on past survey/inspection history, satisfactory condition continuation, and declarations from the Master, Chief Engineer, and DPA/Owner/Manager.
* Extension beyond the IMO Convention provisions requires company to obtain permission from relevant Maritime Authorities.
* **Annual/Periodical Statutory Surveys & Audits**
* Owners should make all efforts to offer ships to ROs for surveys within the conventional time range of 3-12 months.
* Convention provisions provide time ranging between 3-12 months to the ship owners to complete these surveys/inspections/audits.
* **Intermediate Surveys**
* Extensions are limited to 3 months after the due date or 42 months since last dry-dock (or availability of dry-dock plus 15 days), whichever is earlier.
* Extension granted only with dry-dock availability evidence.
* Surveys for certificates not requiring dry-dock must be completed before extension or at the first port where the RO surveyor can board.
* Surveys for certificates requiring dry-dock are extended based on RO recommendations after examinations and measurements.
* Specific surveys are required before or after extension, where the RO Surveyor can board the vessel.
* Extension granted only after a Risk Assessment without these surveys.
* **Renewal Surveys**
* For extensions of 3 months from expiry or 36 months since last dry-dock, standard procedures apply.
* Extensions beyond 6 months after the due date or 42 months since last dry-dock (or dry-dock availability plus 15 days) are not granted.
* Extension granted only with dry-dock availability evidence.
* Surveys related to Statutory Certificates not requiring dry-dock shall be completed to the extent possible either prior extension or at first port.
* Surveys of Statutory Certificates requiring dry-dock to be progressed as far as practicable.
* **Service Suppliers**
* Inability of Service supplier to conduct 5-yearly load test of life-boat/rescue boat is allowed to be replaced with service suppliers approved by Directorate and in presence of RO Surveyor.
* **Exemptions & Waivers**
* Dispensation from safe manning requires a risk assessment.
* The waiver of applicable extension fees as applicable for surveys falling due on/before 30 June 2020 shall also be applicable to ships to which this Order applies.
* **Port State Control**
* Port State Control Officers are advised to adopt a pragmatic approach when inspecting foreign ships visiting India.
**Impact Analysis**
**Ship Owners/Managers**
*Impact:*
* Affected by revised procedures for extending Ship's Statutory Certificates.
* Must comply with enhanced monitoring requirements during extension periods.
*Action Required:*
* Assess the expiry dates of certificates and plan surveys.
* Provide necessary declarations and documentation for risk assessments.
* Offer ships for survey to ROs as early as possible.
**Seafarers**
*Impact:*
* Potentially affected by the extension of Seafarer Certificates.
*Action Required:*
* None specifically mentioned, but seafarers should ensure their certificates remain valid.
**Recognized Organizations (ROs)**
*Impact:*
* Responsible for conducting risk assessments and surveys.
* Required to provide written confirmation when surveyors cannot attend vessels.
*Action Required:*
* Carry out surveys and provide written confirmation of non-attendance.
* Perform risk assessments based on specified criteria.
**Port State Control Officers**
*Impact:*
* Required to adopt a pragmatic approach to foreign ship inspections.
*Action Required:*
* Consider the order’s provisions regarding certificate extensions when inspecting foreign ships.
Key Entities Referenced
Directorate General of Shipping (DGS): The primary regulatory body issuing the order regarding the extension of validity of seafarer's and ship's statutory certificates.
DGS Order 6 of 2020: The preceding order that initially allowed the extension of Ship's Statutory Certificates due to COVID-19, referenced and amended by this order.
COVID-19 Pandemic: The event causing the disruption to shipping operations and necessitating the extension of certificates.
Recognized Organization (RO): An organization authorized to conduct surveys and inspections on ships, plays a role in risk assessment and granting extensions.
Ship's Statutory Certificates: Certificates related to the ship's compliance with safety and environmental regulations, the validity of which is being extended.
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DGS Order 17 of 2020
File No. ENG/MrSC -29(73)t09 | oate.:yoeZOn
Subject: Extension to validity o
Periodical Surveys & Audits in view of covlD-l9 pandemic
l. Noting that there have been difficulties faced by shipowners to meet the statutory
requirements in maintaining the validity of ship and seafarer certificates, due to force
majeure situation posed by COVID-19 resulting lock-down of many countries around the
world including India, the Directorate vide DGS Order 6 of 2020 dated23,d March 2020,
allowed extension of Ship's Statutory Certificates on a case to case basis by three months
and extension of one month to the validity of Seafarer Certificate of
Competency/Profi ciency/Recognition of Equivalence.
2. Noting further that the continued lock-down has resulted in non-availability of
Recognized organization Surveyors, service suppliers and dry-docks, the Directorate
vide Addendum No.2 to DGS order 6 of 2020 dated 2l't April2020, allowed extension
of ship statutory certificates expiring on/before 3l't May 2020, beyond what is permitted
by various International Conventions, subject to a Risk assessment carried out by
Recognized Organization, and imposition of certain specific conditions such as enhanced
monitoring of ships from shore by ship managers/owners during this period of extension.
J. Even though the lock-down started easing out with effect from end May 2020,yet many
ship-owners faced problems in docking their vessels, either due to continued closure of
the dry-docks or inability of the ship-owners to attend his ship at dry-dock due-to non-
availability of flights to foreign destinations, the Directorate vide DGS Order 13 of 2020,
allowed extension of ship statutory certificates expiring on/before 30tr June 2020 under
revised conditions such as ensuring attendance of the vessel by Recogni zed, organization,
wherever possible, for progressing of the surveys as far as practicable.
4. Now, the Indian National Ship owner Association has requested extension of Statutory
certificates expiring on/prior to 31't August 2020 citingthe prevailing waiting period at
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+' Ar>L ^-s...;A*- --l n' \ \ \various dry-docks around world, which are operating at full capacity to clear pending
ships requiring dry-dock.
5. Recognizing the changing situation world-wide and also noting that Recognized
Organizations have started carrying out surveys at an increasing number of ports world-
wide' the Directorate now reviews its procedure for grant of extension of statutory
certificates to ships whose statutory surveys are expiring after 30s June 2020 but on/prior
to 31't August 2020 and, the revised procedure as laid down in the following paragraphs
will apply.
6'
The DGS Order 13 of 2020 dated,2l't May 2020 remains applicable for ships with
statutory certificates expiring on/prior 30 June 2020 and thereafter this order will replace
and will be in force till 3l't August 2020.
7 ' The Risk assessment by RO, where-ever mentioned in this order, is to be based on 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
8'
The revised procedure for extension of Annual/Periodical Statutory Surveys or
InterimllnitialllntermediaterRenewal
Audits/Inspections
:
a) It is to be noted that, the Convention provisions provide sufficient time ranging
between 3-12 months to the ship owners to complete these surveys/inspections/audits.
Therefore, all efforts should be made by all owners to offer their ships to the RO for
suryeys, in case these are within the range period.
b) In general, no extension shall be granted/considered unless the Recognized
Otganization provides in writing that the Surveyor cannot attend the vessel due to
lock-down at any port visited by the ship, after the issue of this order.
c) Even if an extension is to be considered on a case to case basis, same will be after a
satisfactory Risk assessment, and same shall only be granted for the period to enable
the ship to reach a port where Recognized organization Surveyor can attend the
vessel.
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The procedure for extension of Intermediate surveys shall be:
a) No extension shall 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 availabilitv of
dry-dock plus 15 days, which-ever is earlier.
b) This extension shall be granted only upon submission of a firm evidence of date of
dry-dock availability from the selected dry_dock.
c)
The Surveys related to Statutory Certificates not requiring dry-dock (such
as
Safety Equipment/Radio/IOPP/IAPP etc.) shall be completed either prior extension
or at the first port, where RO Surveyor can board the vessel during the period of
extension.
d) The extension of Surveys of Statutory Certificates requiring dry-dock(Such as
load-line/Safety Construction etc.) shall 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 Caniers and a CCTV examination of the
underwater portion of the hull, appendages, propeller and rudder.
e)
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 vessel. 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.
l0' Extension of Renewal surveys beyond three months from expiry date:
a) 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 shall apply.
b) No extension shall 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-
c)
This extension shall be granted only upon submission of a firm evidence of date of
dry-dock availability from the selected drv_dock.
Page 3 of 5d) The Surveys related to Statutory Certificates not requiring dry-dock shall be
completed to-the extent possible either prior extension or at first port, where RO
Surveyor can board the vessel 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 recommended for
extension with the Risk assessment.
D The Surveys of Statutory Certificates requiring dry-dock to be progressed as far
as practicable. The extension shall be based on RO recommendation after a
satisfactory general examination of hull, machinery, fitting (structural and non-
structural), 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 Caniers and a CCTV examination of the
underwater portion of the hull, appendages, propeller and rudder.
e) These Surveys are to be carried out either prior extension or at first port after
extension, where RO Surveyor can board the vessel. 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.
0 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 and the testing to be conducted in presence of RO Surveyor.
11. Exemptions from Safe Manning Document:Any dispensation from safe manning shall
be on case to case basis where-in a seafarer is signed-off in an emergency and a risk
assessment is submitted.
12. The waiver of applicable extension fees as applicable for surveys falling due on/before 30
June 2020 shall also be applicable to ships to which this order applies.
13' The extension of surveys beyond the IMO Convention provisions will be under the
following conditions.
Page 4 of 5a) 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.
b) The Company should ensure increased monitoring of ship for safety of ship and
seafarer by shore staff during this period of extension. Procedure for such monitoring
to be developed and approved by DPA (for ISM/DDOC vessels) and records to be
maintained for verification at next audit/FSl.
14' All Port State Control officer are hereby advised to take a pragmatic approach while
inspecting foreign ships visiting India till further orders. Foreign ships with statutory
Certificates, having similar extension of Annual/Periodical/ Surveys by 3-months from
expiry date and Interim/Initial/tntermediate/Renewal Audit/Inspection by
3-months
beyond expiry date, 42-month period since last dry-docking and renewal surveys
extension by 6-months beyond expiry date may be accepted. No ship shall be detained for
any other period of extension unless approved by concerned principal officer based on
present condition of ship.
Director General of Shipping
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