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
• 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 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 05-21. 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 22-22.

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.

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

Visit the IMO’s press page which highlights the work of the IMO and information 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.

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.