Updates Regarding the Coronavirus Disease (COVID-19)

International Registries, Inc. and its affiliates (IRI), which provide administrative and technical support to the Republic of the Marshall Islands (RMI) Maritime and Corporate Administrators, is always committed to quality client service. During these rapidly changing and challenging times, the RMI Registry remains fully operational and accessible to our clients. In addition to the normal activities of protecting life, the environment, and resources, the COVID-19 virus means the RMI Registry must now, more than ever, focus on ensuring that RMI registered ships continue trading to keep the global supply chain moving.

The RMI Registry encourages all government agencies and industry stakeholders to recognize this is a force majeure situation that will necessitate flexibility. This page will continue to be updated based on the rapidly changing COVID-19 situation.

RMI Registry Status

The RMI Registry is committed to responsibly facilitating the business operations of our clients around the globe. Our 28 worldwide offices are monitoring guidance from their local authorities and the World Health Organization (WHO). IRI’s network of worldwide experts including client services managers, and technical and marine safety personnel are available to provide service locally which is essential during these challenging times. While some of our offices remain open, many of our offices and team members are now working remotely and we maintain our full capability to assist clients throughout the world using normal email and phone channels without interruption.

The RMI Registry’s operations teams including Corporate, Technical, Marine Safety, Seafarers’ Documentation, Radio Station Licensing, Vessel Registration, and Vessel Documentation, remain fully manned and capable of answering questions from ship operators, shipowners, Classification Societies (Class) / Recognized Organizations (ROs), filing agents, banks, law firms and other industry stakeholders. To ensure a timely response please use the email address for the appropriate department.

As this challenging situation continues to escalate there have been many questions posed to the RMI Maritime Administrator (the “Administrator”). Please take a moment to review the following important information:

• Ship Surveys and Statutory Certificates
• Ship Inspections
• Seafarers’ Documentation Update/Status
• Crew Contracts
• International Maritime Organization (IMO) Update
• Implementation of IMO 2020 (0.50% fuel oil sulphur content limit)
• Prohibition on Carriage of Non-Compliant Fuel
• Exhaust Gas Cleaning System (EGCS) Installations
• Recordation of Mortgages and Other Instruments; Acknowledgements
• Useful Links

Ship Surveys and Statutory Certificates

As statutory certificates become due for periodic or renewal surveys, ship operators are requested to make all efforts to ensure certificates are valid. However, it is recognized that there may be issues securing dry-docks and repair facilities, receiving essential equipment, and organizing servicing technicians. In some cases, it may be difficult to arrange attendance from Class / ROs. It is imperative that the ship operator and Class work together to keep certificates valid using physical and remote survey techniques where possible. The Administrator has authorized International Association of Classification Society members to act on its behalf to evaluate each situation and recommend a course of action to the Administrator.

In the most extreme cases, where neither a physical attendance nor a remote survey can be organized, then the RO may recommend a period of grace of up to three months. The RO should record and track the status of any extensions and provide ships with evidence that certificates have been extended along with an explanation. While the Administrator cannot guarantee that every port State control (PSC) will accept extended certificates, this evidence may be shown to PSC. It is recommended that such evidence is also sent with any advanced notice of arrival that may be required by some coastal States.

MSA 24-20 – Handing the Validity of Ship Certificates Due to COVID-19

MSA 25-20 – Handling ISM, ISPS, and MLC, 2006 Due to the Exceptional Circumstance of COVID-19 (Updated 26 March 2020)

Technical Circular 13 – Guidelines for Extending the Period of Validity of a Certificate provides additional guidance

Ship Inspections

Alternative arrangements for vessel inspections are available to address and reduce risk. When the traditional in-person inspection is not possible, temporary arrangements will be considered in accordance with MSA 17-20. If you have an immediate question or concern regarding vessel inspections or boardings, please contact your regional office or directly send an email to the respective inspection office as noted below.

Inspections-HK@register-iri.com for those vessels needing to schedule an inspection in China, the Far East, Southeast Asia, Australia, or New Zealand.

Inspections-Busan@register-iri.com for those vessels needing to schedule an inspection in Korea and the Pacific coast of Russia.

Inspections-Dubai@register-iri.com for those vessels needing to schedule an inspection in the Middle East including Red Sea area and Gulf of Aden, India, or Pakistan.

Inspections-Roosendaal@register-iri.com for those vessels needing to schedule an inspection in Northern and Eastern Europe; Western Russia; West, Central, and Southern Africa; or Madagascar.

Inspections-Piraeus@register-iri.com for those vessels needing to schedule an inspection in the Mediterranean, Black Sea, or North Africa.

Inspections-Baltimore@register-iri.com for those vessels needing to schedule an inspection in North, Central, and South America; the Caribbean; Greenland; Guam; or the Hawaiian Islands.

Close cooperation with the regional office coordinating your inspection is greatly appreciated as we work together to reduce the risk and minimize the global impact of COVID-19 in the maritime arena.

WHO provides updates on “affected areas” and the latest status updates.

Updated guidance on vessel calls in affected ports, vessel inspections, and crew contracts may be found in MSA 38-20.

Seafarers’ Documentation Regional Office Status

Our Seafarers’ Documentation teams are operational with some personnel working from home. There are restrictions on office hours and/or visitors for some offices. Please email your Seafarers’ Documentation full-service processing office if you have questions about hours, closures, or visitors.

Filing agents who submit applications online may continue to do so via remote desktop or virtual desktop infrastructure, if submitting from a remote location. If you do not have remote desktop capability and are unable to submit paper applications by courier, please contact seafarers@register-iri.com for guidance.

Crew Contracts

The Administrator is aware that stringent border control measures to reduce the spread of COVID-19 has resulted in operators having difficulty in arranging crew changes and repatriating seafarers when their employment agreements expire. As a result, some seafarers employed to work on RMI-flagged ships may exceed the service period as entered in their seafarer employment agreements (SEA).

The Administrator allows for extended SEAs as provided in RMI Marine Notice (MN) 7-052-2. It also recognizes in contrast to this position that some port States hold a rigid interpretation that a SEA may not be extended beyond 11 months or its original contract date, if less than that period. See MSA 26-20 on the Administrator’s expectations for the repatriation of seafarers due to COVID-19.

The Administrator is closely monitoring the problems arising with the restriction of crew changes worldwide and will engage, if necessary, in an active dialogue with all relevant industry stakeholders to ensure the safety and security of the Registry’s seafarers and vessels.

If further guidance is required, please contact regulatoryaffairs@register-iri.com.

International Maritime Organization (IMO) Update

With many meetings of the IMO now postponed, including the Legal Committee (LEG) 107, the Marine Environment Protection Committee (MEPC) 75 and the Maritime Safety Committee (MSC) 102, the Administrator has noted there will be consequential effects with regard to work program timelines and entry into force dates for treaty amendments. Noteworthy are the expected adoption of amendments to the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI relative to testing/verification protocols (MEPC 75/3) and approval of the revised EGCS guidelines. In this regard, the IMO secretariat will develop a revised timetable once the final number of postponed meetings are known, taking into account modalities for these re-scheduled meetings (including submission of documents, effect on amendment procedures, etc.) to ensure the work of the IMO is adequately resumed. Until then, there is no opportunity for further official discussions on the response to COVID-19 on the maritime stage at an international level in relation to implementation and enforcement of relevant IMO instruments. However, the RMI Maritime Administrator is prepared to work with the international community as required to address implementation difficulties when encountered.

Visit the IMO’s press page which highlights the work of the IMO and circular letters issued to date.

A communication from the IMO Secretary General urging a practical and pragmatic approach, in response to issues like crew changeovers, resupply, repairs, survey and certification, and licensing of seafarers can also be found here, which the Administrator fully endorses.

Implementation of IMO 2020 (0.50% fuel oil sulphur content limit)

High levels of compliance were noted with only a handful of cases reported where difficulties were encountered due to fuel oil non-availability. Ship operators are urged to remain vigilant regarding potential fuel oil quality and availability issues worldwide in the event of unforeseen supply disruptions arising from COVID-19 measures. The Administrator will continue to assess Fuel Oil Non-Availability Reports (FONAR) on a case-by-case basis and utilize discretion when evaluating what actions to take, including taking no control actions, where, despite all best efforts, the ship was unable to source compliant fuel oil.

Further guidance may be found in MN 2-013-8 and form MI-112 should be used when notifying the Administrator of a fuel oil non-availability situation.

Prohibition on Carriage of Non-Compliant Fuel

Results from an informal survey in advance of the entry into force of amendments to MARPOL Annex VI prohibiting carriage of non-compliant fuel oil on 1 March 2020 indicated a high level of readiness throughout the RMI fleet, with roughly an 80% response rate.  Broad enforcement of the carriage prohibition is expected by PSC. The Administrator has noted instances of PSC action against ships found with non-compliant fuel oil onboard. Under some circumstances, the Administrator may permit a ship to carry non-compliant fuel oil, with concurrent approval by the competent authorities for the port of destination and port of departure, as relevant, if party to MARPOL Annex VI. Such a situation may be to allow for a single, one-way, direct voyage to bunker compliant fuel oil for the ship, in accordance with Regulation 18.2.4, when compliant fuel oil is not available. IMO Circular MEPC.1/Circ.881, Guidance for port State control on contingency measures for addressing non-compliant fuel oil, is to be referenced when considering options to deal with remaining non-compliant fuel oil onboard.

EGCS Installations

COVID-19 restrictions are impacting some scrubber installations planned in China, which may also be difficult in other ports should restrictions become more widespread. In several instances, due to delays in drydocking/installation, ships have requested to retain non-compliant fuel onboard past the 1 March 2020 deadline for use during installation surveys. The Administrator will continue to evaluate such requests on a case-by-case basis, but generally will support requests to retain non-compliant fuel being onboard after 1 March 2020 subject to specific conditions, evidence of which must be submitted as follows:

1. signed agreement with the shipyard and EGCS supplier;
2. written confirmation from the shipyard and/or makers that issues caused by the COVID-19 pandemic are the reason for the enforced delay;
3. RO verifies the isolation and security of the non-compliant fuel and issues an occasional survey report to that effect. Validity not to exceed three months beyond 1 March 2020; and
4. records of soundings maintained in order to confirm no consumption of non-compliant fuel.

The Administrator also recommends that destination port States are notified as relevant in line with MEPC.1/Circ.881.

Recordation of Mortgages and Other Instruments; Acknowledgements

All transactions that require the recordation of a mortgage or other instrument as well as all transactions requiring notarization or acknowledgment, where such notarization or acknowledgment cannot be done in person due to the COVID-19 pandemic and associated restrictions, may be subject to modified requirements pursuant to MN 1-004-3 and MG 1-04-1.

If further guidance is required, please contact: registrations@register-iri.com or legal@register-iri.com.

It is important to restate that the RMI Registry encourages all government agencies and industry stakeholders to recognize this is a force majeure situation, which will necessitate flexibility. This page will continue to be updated based on the rapidly changing COVID-19 situation.