**Executive Summary**
MS Notice No. 01 of 2016, issued by the Directorate General of Shipping, revises procedures for In-Water Surveys (IWS) in lieu of dry-docking for Indian flag cargo vessels. It removes age restrictions previously in place, allowing IWS for vessels of any age under certain conditions. This notice supersedes MS Notice No. 24 of 2009 and takes effect from the date of issuance.
**Key Points / Main Content**
* **General Provisions:**
* Allows IWS in lieu of dry-docking for Indian flag cargo vessels of any age, provided certain conditions are met.
* This change is made to provide a level playing field for Indian vessels and to promote the growth of Indian shipping.
* **Vessels Covered Under Enhanced Survey Program (ESP):**
* For ESP vessels less than 15 years old, alternate bottom inspections can be conducted via IWS.
* For ESP vessels 15 years and older, bottom inspections during intermediate and renewal surveys must be done in dry-dock.
* **Vessels Not Covered Under Enhanced Survey Program (ESP):**
* Bottom inspections during renewal surveys must be carried out in dry-dock.
* Alternate bottom inspections (not during renewal surveys) may be carried out via IWS.
* IWS requires a valid notation from the RO, a suitable hull coating, and completion of thickness measurements and internal examinations.
* No hull repairs or conditions of class requiring dry-docking are permitted.
* **In-Water Survey (IWS) Requirements:**
* Vessel owners must request IWS from the office and the RO, including date and location.
* A signed statement confirming no hull damage is required.
* The IWS must be conducted per specific requirements. These include the vessel Master or owner’s representative declaration of the hull damages and paint scheme, protected site with good visibility, clean hull, CCTV inspection, and surveyor examination above the waterline.
* Defects or deterioration detected during or after the IWS may require internal structure examination and/or dry-docking.
* **Endorsement and Reporting:**
* Upon satisfactory completion of IWS, statutory certificates can be endorsed.
* The RO must forward a detailed report, survey findings, and IWS recommendation to the office for ex-post-facto approval.
**Impact Analysis**
**Vessel Owners**
* **Impact:** Increased flexibility in scheduling surveys, potential cost savings by avoiding dry-docking.
* **Action Required:** Submit a request for IWS to the office and RO, ensure the vessel meets all IWS requirements, provide necessary declarations and documentation, and facilitate the survey.
**Recognized Organizations (ROs)**
* **Impact:** Responsibility for ensuring vessels comply with IWS requirements and the rules, procedures, and guidelines of the respective ROs.
* **Action Required:** Implement procedures for evaluating and approving IWS requests, conduct surveys, provide notations for vessels, and report findings to the Directorate General of Shipping.
**Directorate General of Shipping**
* **Impact:** Authority for overseeing and approving IWS procedures.
* **Action Required:** Review and approve IWS requests and RO reports, ensure compliance with regulations, and maintain oversight of the IWS process.
Key Entities Referenced
In-Water Survey (IWS): A survey conducted on a vessel while it is afloat, often as an alternative to dry-docking, to assess the underwater portion of the hull and fittings.
Directorate General of Shipping: The primary regulatory body for shipping in India, responsible for issuing the MS Notice and approving IWS procedures.
Recognised Organizations (ROs): Organizations authorized by the Directorate General of Shipping to conduct surveys and certifications of vessels, including In-Water Surveys.
SOLAS 74/88 Regulation I/10(a)(v): Refers to a specific regulation within the International Convention for the Safety of Life at Sea, as amended, which likely provides a framework or authorization for alternative survey methods like IWS.
Enhanced Survey Program (ESP): A structured inspection program for bulk carriers and oil tankers, relevant because the procedures outlined in the MS Notice differentiate between ESP vessels based on age.
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on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and
Oil Tankers, 2011 (ESP Code), as amended’, and the provisions/guidelines
applicable as per the rules of the respective RO.
2.1.2. For ESP vessels of 15 years of age and over, inspection of the outside of the
vessel's bottom during intermediate surveys and renewal surveys shall be carried
out with the vessel in dry-dock.
2.2. Vessels other than those covered under Paragraph 2.1:
2.2.1. The inspection of the outside of the vessel's bottom during renewal surveys shall
be carried out with the vessel in dry-dock.
2.2.2. Alternate inspections of the vessel’s bottom, not conducted in conjunction with the
renewal survey, may be carried out by an IWS with the vessel afloat.
2.2.3. Based on a request from the vessel owner(s), the RO concerned may carryout the
IWS in accordance with the applicable rules/procedures/ guidelines of the
respective ROs, subject to the following conditions :
2.2.3.1. The vessel has an appropriate and valid notation from the respective RO
for carrying out an IWS in lieu of an out of water docking.
2.2.3.2. The underwater portion of the hull structure is protected by a suitable
coating of adequate thickness, valid till the dry-docking during renewal
survey.
2.2.3.3. The thickness measurement of the underwater hull structure, and the
internal examination and close-up survey of all tanks and spaces, as per
the respective class requirements for an intermediate survey, should be
preferably completed before an IWS. In case an IWS is held before the
completion of the abovementioned activities, an endorsement towards
intermediate docking survey shall be done only after these activites are
completed with satisfactory results, within the due date for docking survey.
2.2.3.4. No repair or renewal work for the hull structure or fittings, and, no
condition of class (CoC) on the hull structure or fittings, either of which
necessitate the bottom survey in a dry-dock, exists.
2.2.3.5. If a vessel does not have notation as prescribed hereinabove, such a
notation may be obtained from the RO concerned at the time of dry-
docking, to avail the benefit of an IWS during the intermediate surveys.
However, as a one-time measure, a vessel may undergo an IWS in lieu of
an intermediate dry-docking, provided the RO concerned ensures that the
vessel complies with all the class requirements for an IWS and this MS
Notice, and in all such cases, the vessel shall obtain the appropriate
notation at the next dry-dock survey.
2.3. In-Water Survey (IWS) Requirements:
2.3.1. Prior to each IWS, a request should be made by the vessel owner(s) to this office
and the RO concerned, indicating information such as date and location of the
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IWS, general information on the diving company and a schedule for undertaking
the IWS, coupled with a signed statement confirming that the vessel has not
suffered any damage to the underwater hull and fittings due to grounding or
contact or any other reason.
2.3.2. The IWS should be conducted in accordance with the following requirements;
2.3.2.1. At the time of an IWS, the vessel Master or owner's representative
should provide a declaration to the RO concerned, of all suspected or
actual damage to the hull that has occurred since the previous
drydocking, as well as a declaration that the underwater portion of the
hull structure is protected by a suitable paint scheme of an adequate
thickness, valid till the dry-docking during renewal survey.
2.3.2.2. The proposed survey site should be in a protected location, with calm
clear water providing good underwater visibility. Sufficient visibility shall
be available to enable the Surveyor to ascertain if the hull requires
repairs/renewals that necessitate the bottom survey in a dry-dock.
Special attention should also be given to the effects of current and tides.
2.3.2.3. The hull should be clean for an external survey and the RO Surveyor
should be satisfied that the method and quality of pictorial presentation
is satisfactory and that the information obtained enables a reliable
assessment to be made of the condition of the hull and fittings to decide
whether dry-docking is needed or not. The survey should be
discontinued if the conditions or equipments deteriorate to the extent
that the transmitted pictures and/or communications are no longer
acceptable.
2.3.2.4. An examination of the entire vessel below the waterline should be
carried out by an approved diving company acceptable to the RO, using
closed circuit television with a two-way communication capable of being
monitored by the Surveyor as required.
2.3.2.5. Where practicable, the IWS should be carried out while the vessel is in a
light operating condition to facilitate the survey.
2.3.2.6. An examination of the outside of the shell plating above the waterline
and exposed portions of appendages should be carried out by the
Surveyor. Means should be provided to enable the Surveyor to
accomplish this visual examination. The extent of underwater inspection
by RO Surveyor should be sufficient to include all items which would
normally be examined if the vessel was in dry-dock.
2.3.2.7. When a defect or deterioration or damage is detected or suspected as a
result of an IWS, or subsequent to an internal examination of spaces, or
thickness measurement, or from the Master's statement, the internal
structure should be examined as considered necessary to clarify or
confirm the findings. In such cases, the Surveyor may require that the
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