Refers to: Ship Owners / Managers/ Operators of Panamanian flagged vessels, PHRS Representatives/Surveyors

Action Date: January 8th, 2019

Kindly note that Merchant Marine Circular 269 issued by the Panama Maritime Authority, regarding the certification process for Maritime Labor Convention has been revised.
 
This revision includes the modification of paragraph 22 stating that from January 8th 2019, the ROs listed in the Circular MMC 255 may extend the validity of the Maritime Labor Certificate for a period not exceeding five months after the expiry date of the existing certificate, provided that the renewal inspection has been carried out according to standard of the MLC (A5.1.3.4). The format to be followed by the RO´s will be the same as that found in the Appendix A5–II of the Convention and will be added to the maritime labor certificate and be available to the competent authorities.
 
Also, paragraph 25 has been added to the circular, stating that in case of change of ship-owner or operator address, an additional inspection is not required; the RO shall re-issue administratively the full or interim maritime labor certificate with same expiry date of the previous certificate, considering that this change does not affect the operation of the ship or the Company procedures. Therefore, an authorization shall be requested to mlc@segumar.com , copy of the valid maritime labor certificate and the certificate of registry (patent) updated if applicable.
 
Click here for the full MMC – 269 Maritime Labor Convention 2006 (MLC 2006), Certification Process.

Do not hesitate to contact us for any clarifications you may need on the above.

February 6th, 2019 - PHRS Head Office

Ships are increasingly using systems that rely on digitization, digitalization, integration, and automation. Cyber technologies have become essential to the operation and management of numerous systems critical to the safety and security of shipping and protection of the marine environment. 

As technology continues to develop, information technology and operational technology on board ships are being networked together and more frequently connected to the internet. Therefore the ships’ systems and networks maybe vulnerable to risks may also occur from personnel accessing systems on board, for example by introducing malware via removable media. The vulnerabilities created by accessing, interconnecting or networking these systems can lead to cyber risks which should be addressed.

Vulnerable systems could include, but are not limited to:

.1 Bridge systems;

.2 Cargo handling and management systems;

.3 Propulsion and machinery management and power control systems;

.4 Access control systems;

.5 Passenger servicing and management systems;

.6 Passenger facing public networks;

.7 Administrative and crew welfare systems; and

.8 Communication systems

To mitigate the potential safety, environmental and commercial consequences of a cyber incident, the IMO and other international shipping organizations have participated in the development of guidelines designed to assist shipping companies in formulating their own approaches to cyber risk management on board ships:

• IMO resolution MSC.1/Circ.1526 [ INTERIM GUIDELINES ON MARITIME CYBER RISK MANAGEMENT ] (which can be found here)
• IMO Resolution MSC.428 (98) [ MARITIME CYBER RISK MANAGEMENT IN SAFETY MANAGEMENT SYSTEMS ] (which can be found here)
• IMO MSC-FAL.1/Circ.3 [ GUIDELINES ON MARITIME CYBER RISK MANAGEMENT ] (which can be found here)
• ISO/IEC 27001:2013 [Information technology -- Security techniques -- Information security management systems – Requirements ]
• The Guidelines on Maritime Cyber Risk Management [Produced by BIMCO, CLIA, ICS, INTERCARGO, INTERMANAGER, INTERTANKO, IUMI, OCIMF and WORLD SHIPPING COUNCIL ] (which can be found here) 

According to IMO Resolution MSC. 428 (98) on Maritime Cyber Risk Management, the objectives of the International Safety Management (ISM) Code include the provision of safe practices in ship operation and a safe working environment, the assessment of all identified risks to ships, personnel and the environment. In this scope, the Safety Management System (SMS) of the shipping companies should take into account cyber risk management in accordance with the objectives and functional requirements of the ISM Code aiming to safeguard shipping from current and emerging cyber threats and vulnerabilities. Therefore, cyber risks should be appropriately addressed in the SMS no later than the first annual verification of the company’s Document of Compliance that occurs after 1 January 2021.

For that scope, the Interim Guidelines on Maritime Cyber Risk Management [ IMO resolution MSC.1/Circ.1526 ] provides recommendations that can be incorporated into existing risk management processes. The Guidelines also include functional elements that support effective cyber risk management.

The Guidelines on Cyber Security on board Ships (please click here), reflect a deeper experience with risk assessments of operational technology, such as navigational systems and engine controls, and provides more guidance for dealing with the cyber risks to the ship arising from parties in the supply chain. For detailed guidance on cyber risk management.

Flag Administrations will soon publish their own guidelines & requirements for encouraging ship-owners and operators to take the necessary steps to safeguard shipping from current and emerging threats and vulnerabilities related to digitization, integration and automation of processes and systems in shipping. Shipping companies should carefully develop plans and procedures for cyber risk management which should be seen as complementary to existing security and safety risk management requirements contained in the International Safety Management Code (ISM) Code and the International Ship and Port Facility Security (ISPS) Code.

December 21st , 2018 - PHRS Head Office

Υπογραφή Διαπιστωτικής Πράξης από το ΥΝΑΝΠ

ΔΕΛΤΙΟ ΤΥΠΟΥ

Στις 30/01/2019, υπεγράφη η Διαπιστωτική Πράξη Συμμόρφωσης του Οργανισμού με τα κριτήρια του άρθρου 109 του νόμου 4504/2017, από το Υπουργείο Ναυτιλίας και Νησιωτικής Πολιτικής. Η υπογραφή της Διαπιστωτικής Πράξης στο σύνολο της, πιστοποιεί και την συμμόρφωση του Οργανισμού με τα κριτήρια του Κώδικα περί Αναγνωρισμένων Οργανισμών (Recognized Organizations Code) του Διεθνούς Ναυτιλιακού Οργανισμού (IMO) αναλογικά με το βαθμό εξουσιοδότησης του Οργανισμού από την Ελληνική σημαία.

NL 205/19|IMO Guidance on preparing Ship Implementation Plan for 2020 Sulfur Cap Compliance

At its latest Marine Environment Protection Committee (MEPC 73), IMO approved, among others, the guidance on the development of a ship implementation plan outlining how the ship may prepare in order to comply with the required sulfur content limit of 0.50% by 1 January 2020 (IMO 2020 sulfur cap) under MARPOL Annex VI.

IMO's 2020 Sulfur cap, which will take effect from 1 January 2020, requires that ships must run on fuel containing no more than 0.5% m/m of sulfur, unless having scrubbers installed.
Namely, the options available for ship-operators to achieve compliance are:

• The use of low-sulfur fuel

• Installation of scrubbers

• The use of LNG

• The use of other new developed fuels 

In this context, MEPC 73 in October 2018 agreed that Administrations should encourage ships flying their flag to develop implementation plans, outlining how the ship may prepare, in order to comply with the regulation.
The plan could be complemented with a record of actions taken by the ship in order to be compliant by the applicable date.

Administrations and Port State control authorities may take into account the implementation plan when verifying compliance with the 0.50% sulfur limit requirement. A ship implementation plan is not a mandatory requirement. A lack of a ship implementation plan or an incomplete ship implementation plan should not be considered as "clear grounds" for a more detailed PSC inspection.

It is advised that ship operators schedule for each of their managed vessels a compliance plan in order to achieve compliance prior of 31st of December 2019 in respect of % content in emissions.

Under the new guidance, the ship implementation plan for 2020 could cover various items relevant for the specific ship, including, as appropriate, but not limited to:

• Risk assessment and mitigation plan (impact of new fuels)

• Fuel oil system modifications and tank cleaning (if needed)

• Fuel oil capacity and segregation capability

• Procurement of compliant fuel

• Fuel oil changeover plan (conventional residual fuel oils to 0.50% sulfur compliant fuel oil)

• Documentation and Reporting 

 Issues relating to use of sulfur compliant fuel oil

All fuel oil supplied to a ship shall comply with regulation 18.3 of MARPOL Annex VI and chapter II/2 of SOLAS. Meanwhile, operators could consider ordering fuel oil specified in accordance with the ISO 8217 marine fuel standard.
The following potential fuel-related issues may need to be assessed and addressed by ships in preparation for and implementation of the 0.50% sulfur limit requirement:

• Technical capability of ships to handle different types of fuel (e.g. suitability of fuel pumps to handle both higher and lower viscosity fuels, restrictions on fuels suitable for use in a ship's boilers, particularly the use of distillate fuels in large marine boilers)

• Compatibility of different types of fuels e.g. when paraffin and aromatic fuels containing asphaltenes are commingled in bunkering or fuel oil changeover

• Handling sulfur non-compliant fuels in the event of non-availability of sulfur compliant fuels

• Crew preparedness including possible training with changeover procedures during fuel switching from residual fuel oil to 0.50% compliant fuel oils. 

Additionally, the ship implementation plan could be used as the appropriate tool to identify any specific safety risks related to sulfur compliant fuel oil, as may be relevant to the ship, and to develop an appropriate action plan for the organization to address and mitigate the concerns identified.
Examples should include: 

• Procedures to segregate different types of fuel and fuels from different sources

• Detailed procedures for compatibility testing and segregating fuels from different sources until compatibility can be confirmed

• Procedures to changeover from one type of fuel to another or a fuel oil that is known to be incompatible with another fuel oil

• Plans to address any mechanical constraints with respect to handling specific fuels, including ensuring that minimum/maximum characteristics of fuel oil as identified in ISO 8217 can be safely handled on board the ship

• Procedures to verify machinery performance on fuel oil with characteristics with which the ship does not have prior experience.

​Click here for the relevant IMO guidance MEPC.1/ Circ.878 (Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulfur limit under MARPOL Annex VI).

February 5^th, 2019 - PHRS Head Office