Flag and Port State Control requirements

The latest Flag and Port State Control requirements, as reported by Lloyd's Register.

Safety alert: Expired Hammar hydrostatic release units

Class News No. 04/2015 | 20th February 2015

Applicability: All shipbuilders, owners and operators.

Further to Class News No. 05/2009, which warned of counterfeit hydrostatic release units (HRUs), the UK Maritime & Coastguard Agency (MCA) has advised that expired CM Hammar H20 HRUs have been refurbished and re-sold, and found on board ships for use with liferafts.

Photograph of superyacht on the water from the bow

These expired units pose a serious safety risk; they are not guaranteed to operate in an emergency, meaning that liferafts or EPIRBs may not be released. If discovered on board, they should be withdrawn from service immediately.

The HRUs highlighted to the MCA had their genuine labels removed and replaced with substandard labels. These labels were observed to wear away a short time after the HRUs were installed.

To help identify genuine H20 HRUs, the manufacturer CM Hammar AB has released a news bulletin, available here.

The MCA and Australian Maritime Safety Authority (AMSA) have also released a safety bulletin and marine notice respectively.

CM Hammar recommends that H20 HRUs are procured from authorised distributors or liferaft service agents to ensure they are genuine. The Hammar H20 HRU is designed and approved to release a liferaft or an EPIRB in the event of a ship sinking, and has a service life of two years. At the end of the two years, it should be disposed of.

For more information, visit Lloyd's Register.

Statutory alert: New inspection requirement for ships trading in the Paris MOU area

Class News No. 41/2014 | 2nd October 2014

Applicability: Owners, managers and operators of vessels flagged with St. Vincent and the Grenadines.

The St. Vincent and The Grenadines Maritime Administration has issued Circular No. PSC 033, which requires additional inspections (termed ‘occasional surveys’) to be carried out for all vessels whose next port of call is within a Paris MOU member country. The circular only applies to vessels if they have been detained by port state control authorities within the last three years.

View of St. Thomas Yacht Haven Grande at night

The Administration has stated that a vessel will be deleted from its Registry if:

  • An occasional survey is not carried out when required
  • A vessel is detained twice by a maritime authority member of the Paris MOU within a six month period.

What to do now:

To determine if your vessel requires an occasional survey prior to departure for a Paris MOU member country, please take a look at this flow chart.

For more information, visit Lloyd's Register.

Statutory alert: Marshall Islands requirements for rescue boat on-load release mechanisms

Class News No. 16/2015 | 20th August 2015

Applicability: Owners and managers of Marshall Islands-registered vessels with dedicated rescue boats.

The Republic of the Marshall Islands (RMI) Maritime Administrator has introduced a new requirement that all on-load release mechanisms used to launch dedicated rescue boats must comply with paragraph of the Life-Saving Appliances (LSA) Code, and evaluated in accordance with IMO circular MSC.1/Circ.1392.

This is over and above the normal SOLAS requirements, which do not stipulate that boats used solely for rescue purposes fitted with on-load release mechanisms be re-evaluated against the latest LSA Code.

Safety equipment, life jacket and ring on board boat

What do I need to do?

All rescue boat on-load release mechanisms not complying with LSA Code paragraphs to must either be replaced with compliant equipment or modified to comply.

In cases where a suitable replacement or modified on-load release mechanism is not available for a rescue boat which is launched from a single fall and hook arrangement, the mechanism might be replaced with a suitable off-load release mechanism, as permitted by LSA Code paragraph

The SOLAS timeframe for evaluating and replacing mechanisms on lifeboats is the first scheduled dry-docking after 1st July 2014, but not later than 1st July 2019. For vessels that have already completed their dry-docking and are now required to evaluate their rescue boat on-load release mechanisms, the RMI Maritime Administrator will, on a case-by-case basis, allow extra time to complete the replacement.

Full details of the requirement are available in Technical Circular 20, issued by the RMI Maritime Administrator.

For more information, visit Lloyd’s Register

Statutory alert: Joint concentrated inspection campaign on crew familiarisation with enclosed space entry

Class News No. 15/2015 | 3rd August 2015

Applicability: All shipowners and managers

The Paris and Tokyo MOUs on Port State Control have announced they will launch a joint concentrated inspection campaign (CIC) on crew familiarisation with enclosed space entry. The CIC will run from 1st September to 30th November 2015.

The purpose of the campaign is to ensure ships have effective procedures and measures in place to safeguard seafarers when entering and working in enclosed spaces on board ships, and to check compliance with the applicable SOLAS Convention requirements.

Lit superyacht moored alongside in marina at dusk

During port state inspections, officers will check in detail the enclosed space entry procedures and measures that are in place. Port state control officers will use a questionnaire to establish that crew members are familiar with the relevant equipment and have received training to identify and understand the hazards associated with enclosed space entry.

If a deficiency is found, actions by the port state may vary from recording a deficiency and instructing the master to rectify it within a certain period, to detaining the ship until the deficiency has been rectified. Any detention will be published in the Paris and Tokyo MOU monthly detention lists.

It is expected that approximately 10,000 inspections will be carried out during the CIC.

The results of the campaign will be analysed and the findings will be presented to the governing bodies of both MOUs for submission to the IMO.

For more information, visit Lloyd’s Register

Statutory alert: US Coast Guard ballast water management discharge standards – applications for extension of the implementation schedule

Class News No. 14/2015 | 13th July 2015

Applicability: Vessels equipped with ballast water tanks and operating in US waters, unless exempt from the US Coast Guard ballast water management regulations

The US Coast Guard (USCG) has advised that vessels with less than 12 months to comply with the USCG ballast water management discharge standards can now request an extension to the implementation schedule. Effectively, this means an extension to the date, by which the vessel must install a treatment system.

Small boats, yachts and superyacht in Mediterranean port

This change is not currently stated in existing USCG regulations. Vessels may apply for an extension request at any time within the 12-month period, but it is recommended that applications be submitted as soon as possible.

Lloyd’s Register can help clients to prepare requests for an extension of the implementation schedule.

Please contact marine-environment@lr.org for more information, or visit Lloyd’s Register

Statutory alert: Ratification of the AFS Convention by India

Class News 11/2015 | 23rd June 2015

Applicability: All owners and managers of vessels registered within the Indian Maritime Administration.

The International Convention on the Control of Harmful Antifouling Systems on Ships (the AFS Convention) enters into force for India on 24th July 2015.

The Directorate General of Shipping, India, has issued Engineering Circular No.04 of 2015, advising that existing Statements of Compliance (SOCs), issued in respect of the AFS Convention for Indian flagged vessels, are to be replaced. Convention certificates are to be issued to vessels on or after 24th July 2015, but not later than 24th July 2016.

Large luxury yachts moored in blue water harbour

The AFS Convention applies to all vessels of 400GT and above, excluding fixed or floating platforms, floating storage units (FSUs), and floating production storage and offshore loading units (FPSOs) engaged in international voyages.

For more information, visit Lloyd’s Register

Statutory alert: Hong Kong – new regulation requiring use of low-sulphur fuel while at berth

Class News 09/2015 | 21st May 2015

Applicability: All shipowners, operators and managers.

The Hong Kong Marine Department is implementing a new low-sulphur regulation for ocean-going vessels (OGVs) moored or anchored at a berth in Hong Kong waters from 1st July 2015.

The ‘Air Pollution Control Regulation' requires OGVs to use ‘compliant’ fuels while at berth in Hong Kong, when operating main engines (except when used for the propulsion of the vessel), auxiliary engines, boilers or generators. The requirement does not apply during the first hour after arrival and the last hour before departure.

Superyacht at anchor

Under the regulation, compliant fuel means low-sulphur fuel with a sulphur content not exceeding 0.5% by weight; liquefied natural gas (LNG); or any other fuel approved by the Hong Kong authority.

Masters are required to record the date and time of fuel switching and keep the records for three years. If an OGV uses technology that can achieve the same or less SO2 emissions as can be achieved with compliant fuel, the OGV may be exempt from fuel switching.

After the Regulation enters into force on 1st July 2015, masters and owners of any OGVs using non-compliant fuel while at berth in Hong Kong may be liable to a maximum fine of $200,000 and imprisonment for six months. Masters and owners who fail to keep the required records may also be liable to a maximum fine of $50,000 and imprisonment for three months.

Read the full text of the regulation, here.

For more information, visit Lloyd's Register

Statutory alert: European Union approves CO2 monitoring, reporting and verification regulation

Class News No. 08/2015 | 18th May 2015

Applicability: All vessels over 5,00GT trading in EU ports (excluding: fishing vessels, warships, naval auxiliaries, wooden ships of primitive build, ships not propelled by mechanical means, and government ships used for non-commercial purposes).

On 28 April 2015, the European Council approved a new shipping regulation on the monitoring, reporting and verification of CO2 emissions as part of its overall strategy to reduce greenhouse gas emissions by 2050.

The following requirements will apply: From 31 August 2017, all vessels over 5,000GT trading to, from and between ports in the jurisdiction of EU-member states will be required to carry on board a CO2 monitoring plan that has been reviewed by a third party verifier.

Man writing on official paperwork

This plan must contain:

  • Vessel and company details
  • Details of emission sources
  • Procedures for plan updates
  • Procedures for monitoring voyage times and distances
  • Procedures for monitoring time spent in port/at anchor
  • Procedures for monitoring fuel consumption, including: the monitoring method used; details of measuring instruments and data management; and the density calculation method
  • The emissions factors used for each type of fuel
  • Procedures for monitoring and recording cargo and passenger levels for each voyage.
  • Monitoring will be on a per-voyage basis, and data will be aggregated into an annual emissions report. The first reporting period requiring monitoring will be 1 January 2018 to 31 December 2018.

Monitoring will be on a per-voyage basis, and data will be aggregated into an annual emissions report. The first reporting period requiring monitoring will be 1st January 2018 to 31st December 2018.


Once monitoring is completed, data collected in accordance with the monitoring plan will require verification by an approved third party. Then, once the verification process is successfully completed, the vessel will be issued a Document of Compliance, which will need to be kept on board for inspection.

The penalties for failing to carry a Document of Compliance include vessel detention and the issue of an Expulsion Order that prohibits entry into EU ports.


From 2019, verified annual reports must be submitted to the EU Commission and the flag authority for each vessel by 30th April each year. These reports will consist of:

  • Vessel and company details
  • EEDI or EIV** information (as applicable)
  • The monitoring methods used
  • The results of the annual monitoring

The Commission will make this information publicly available by 30 June each year.

**EEDI is the Energy Efficiency Design Index. EIV is the Estimated Index Value for ships for which the EEDI is not mandatory.

For more information, visit Lloyd's Register

Statutory alert: Amendment to inflatable liferaft servicing requirements

Class News No. 05/2015 | 23rd February 2015

Applicability: liferaft servicing suppliers, shipowners and managers.

SOLAS regulation III/20.8 requires inflatable liferafts to be serviced at intervals not exceeding 12 months. It also requires the servicing to be carried out at an approved servicing station, which is competent to service them, maintains proper servicing facilities and uses only properly trained personnel.

IMO guidance on servicing stations is contained in resolution A.761(18) – Recommendation on Conditions for the Approval of Servicing Stations for Inflatable Liferafts.

Life rafts with paddles, safety helmets and lifejackets

The IMO has recently issued an amendment to resolution A.761(18), published as resolution MSC.388(94), which introduces the following new requirement for inflatable liferaft servicing procedures: “All items of equipment should be checked to ensure that they are in good condition and that dated items are replaced at the time of servicing in cases where the expiry date falls before the next service date of the liferaft".

Lloyd’s Register’s Procedures for Approval of Service Suppliers have been updated to include this requirement.

For more information, visit Lloyd's Register

Statutory alert: Port state control detentions

Class News No. 03/2015 | 17th February 2015

Applicability: All shipowners and operators.

Further to Class News No. 35/2013, the United States Coast Guard (USCG) has now detained over 40 foreign flag vessels for water mist system deficiencies discovered during Port State control (PSC) inspections.

In a number of cases, the water supply valve was found in the closed position during the PSC inspection, making the water mist system “not readily available for immediate use”, or the water mist system was found to be in “manual” rather than “automatic” mode.

Aerial view of a port at dusk

Inspection and verification of water mist systems:

It is important that all water mist systems are fully checked and verified as being in satisfactory working order at all times.

It is highly advisable to make frequent rounds and inspections of the water mist system, paying close attention to valve alignment, as well as ensuring that there is adequate labelling so that existing and new crew members will know that critical fixed firefighting equipment must be made available for immediate use.

The vessel’s senior management team, designated persons ashore (DPAs) and vessel superintendents are advised to ensure procedures are in place to confirm the water mist system is fully operational and in “automatic” mode, with the power supply turned “on”. This is particularly important after maintenance is carried out on the water mist system. Procedures should be included in the vessel’s Safety Management System.

Attention is drawn to SOLAS regulation II-2/14 covering operational readiness and maintenance. Paragraph 2.1.2 states that “Fire-fighting systems and appliances shall be kept in good order and readily available for immediate use”.

For more information, visit Lloyd's Register