Practical implementation: convention ships

Practical implementation of the inspection policy for convention ships

a. General 

Surveys and audits must be requested by mail at Ship.BelFlag@mobilit.fgov.be. In any case, the ship and crew must be available in port or at the yard for a sufficient period of time in order to enable the Flag State to conduct good quality inspections. 

The recognised organisations are authorised to conduct statutory surveys and certification of all ships flying the Belgian flag and not being passenger ships, in accordance with the Working Agreement where delegations are defined in the associated Work Matrix. 

Recognised organisations are those classification societies that have signed a working agreement with the Directorate-General Shipping and are thereby authorised to conduct statutory tasks on board Belgian ships.

b. Existing convention cargo ships already in service

Statutory surveys and certification are all checks related to the issue, maintenance and renewal of the following statutory certificates. These certificates are issued only by the Flag State. 

• Cargo Ship Safety Equipment Certificate (+ Form E)
• Cargo Ship Safety Radio Certificate (+ Form R)
• International Oil Pollution Prevention Certificate (+ Supplement)
• International Certificate for the Carriage of Liquefied Gases in Bulk (IGC) (if applicable)
• Certificate of Seaworthiness (COS)
• Minimum Safe Manning Certificate
• Safety Management Certificate (SMC)
• International Ship Security Certificate (ISSC)
• Maritime Labour Certificate (MAC) (+DMLC Part II)
• Continuous Synopsis Record (CSR)
• Exemption Certificates

The recognised organisations are authorised to endorse applicable certificates when a statutory survey or audit is conducted and concluded with a positive outcome by the recognised organisation concerned. In case the Flag State conducted the statutory survey or audit, the certificates concerned are endorsed by the Flag State. 

In order to monitor the recognised organisations on the one hand and check the quality of the fleet on the other, an inspection policy applies to every existing convention ship flying the Belgian flag. The inspection policy consists of a basic package supplemented by additional control measures as required.

Basic package 

In the five-year validity cycle of the Cargo Ship Safety Construction Certificate, each ship must be subjected to one statutory survey and one audit conducted by the Flag State. As a basic principle, the survey and/or audit by the Flag State is combined with a survey conducted by the recognised organisation. Therefore, the survey and/or audit must be conducted when respectively statutory certificates and/or ISM/ISPS/MLC certificates are in window of an intermediate or renewal inspection. 

The shipowner has the right to determine where and when the Flag State conducts the statutory survey and/or audit, taking into account the location and availability of the ship. The surveys and/or audits must be related to intermediate visits or renewal of certificates. In addition, if the inspection windows allow, a statutory survey can be combined with an ISM/ISPS/MLC audit. 
If the shipping company has the intermediate survey or audit conducted by the recognised organisation, then the shipping company must invite the Flag State for the renewal survey or audit.

The reissue of the Certificate of Seaworthiness is dependent on the statutory surveys and audits having been done by the Flag State in the previous five-year cycle and within the time windows legally imposed. Deviation from this condition is accepted only exceptionally.

The scope of each statutory survey is in line with international, European and Belgian provisions.

Control measures

If a risk is identified regarding a shipping company or a ship (e.g. as a result of a detention of a ship), additional control measures may be imposed. 

Control measures are additional or more extensive inspections and/or audits, on top of the basic package referred to above. Control measures are not fixed and are determined in consultation with the shipowner concerned. The principle here is to impose reasonable but effective control measures. Additional or more extensive inspections and/or audits are conducted exclusively by the Flag State and are not subject to delegation to a recognised organisation. 

c. Existing passenger ships already in service

Existing passenger ships are subject to an annual dry-dock survey to renew the Passenger Ship Safety Certificate (valid for 1 year). In view of the complexity and risks associated with passenger ships, this survey is partly conducted by the Flag State, in the presence of the recognised organisation. As for cargo ships, the aim is to monitor the recognised organisation concerned.

In addition, passenger ships are also subject to control measures if risks are identified, as mentioned above.

d. Flagging in

Any ship brought under the Belgian flag must be subjected to a survey conducted by the Flag State prior to registration of the ship. 

The following Flag State surveys are the basic package for each flagging in:

• Pre-registry survey (if applicable, see below)
• Survey for obtaining the Belgian flag (characteristics of the flag on board) 
• Interim Safety Management Certificate
• Interim International Ship Security Certificate
• Interim Maritime Labour Certificate
• Certificate of Seaworthiness

For ships older than 15 years (counted from the delivery date to the date of registration), a comprehensive examination of the structure is required beforehand. The scope of this 'pre-registry survey' is not fixed and depends on a documentary check, but includes at least a comprehensive examination of the structure in dry dock. The pre-registry survey is conducted solely by the Flag State; however, ad hoc assistance by a recognised organisation may be called in. 

In any case, the ship and crew must be available in the port or at the yard for a sufficient period of time in order to enable the Flag State to conduct good quality inspections. 

e. Newbuild and conversion projects

For each newbuild project and each conversion, a specific procedure applies, which also defines the extent of delegation to the recognised organisation. 
Delegations for newbuilds and conversions are not included in the Working Agreement. 

As a basic principle, all acceptance tests, statutory surveys and the issue of statutory certificates are delegated to the recognised organisation.

As a basic package, the following tasks are carried out by the Flag State:

• Sea trials (only the first ship of a series of sister ships)
• Flagging in inspection (see item (d)) 

As part of the monitoring of the recognised organisations, the sea trials are conducted by the recognised organisation but attended by the Flag State.

f. Document of Compliance

The DOC has a maximum validity of 5 years and is subject to annual verifications (audits). Given the importance and scope of the DOC, the required audits for the issue, maintenance and renewal of the DOC are conducted exclusively by the Flag State. 

The DOC audits also allow for an annual consultation with the shipowner and timely detection of developments, changes and trends which may impact safety, security or the environment. Moreover, there is an exchange of feedback, which is important for the quality of the Flag State's services. 

CONTACT

Preferably by email: Ship.Belflag@mobilit.fgov.be
By phone: + 32 (0)2 277 42 50 (secretarial office Flag State)