Updates Regarding the Coronavirus Disease (COVID-19)
Dominica Maritime Administration's Status
During these challenging times, the Dominica Maritime Registry, Inc, Administration remains fully operational and accessible to our clients. The Dominica Maritime Registry, Inc. provides the administrative and technical support for the Commonwealth of Dominica Maritime Administration (DMA). DMA remains fully operational and accessible to our clients across the globe. During these uncertain and evolving times as a result of COVID-19, DMA is doing all it can to provide solutions and service, including the registering of ships and licensing of mariners to continue the trade the keeps our various economies moving.
This page serves as a hub of information for owners, operators and mariners regarding the COVID-19 situation. This page will continue to be updated based on the rapidly changing situation.
The Dominica Maritime Administration is committed to responsibly facilitating the business operations of our clients around the globe. Our 20 worldwide offices are monitoring guidance from their local authorities and the World Health Organization (WHO). Although some of our offices and team members are now working remotely, DMA has maintained full capability to assist clients throughout the world using normal email and phone channels without interruption.
Below you will find important information and documents pertaining to the following topics:
- 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 Dominica Maritime Administration 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 Administration.
In the most extreme cases, where neither a physical attendance nor a remote survey can be organized, 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 Administration 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.
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. If you have an immediate question or concern regarding vessel inspections or boardings, please contact your regional office or directly send an email by clicking on the button below.
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.
The WHO provides updates on “affected areas” and the latest status updates.
Seafarers’ Documentation Update/Status
At present, we are not shipping seafarer documents to India, Italy, Myanmar, the Philippines, or Spain. If your receiving address is located in one of these countries, please contact us to supply an alternative delivery address for your documents.
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, please send an email by clicking on the button below.
The Administration has the ability to extend the SEAs. The Administration 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 DMA-flagged ships may exceed the service period as entered in their seafarer employment agreements (SEA).
The Administration allows for extended SEAs as provided in CD-MSC 11-20 Maximum Period of Shipboard Service for Seafarers Under the Maritime Labour Convention, 2006 (MLC, 2006). 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 Administration 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 send an email by clicking on the button below.
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 Administration 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 Dominica Maritime Administration 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 Administration fully endorses.
Implementation of IMO 2020 (0.50% fuel oil sulphur content limit)
Only a handful of cases were 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 Administration 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.
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 DMA fleet, with roughly an 80% response rate. Broad enforcement of the carriage prohibition is expected by PSC. The Administration has noted instances of PSC action against ships found with non-compliant fuel oil onboard. Under some circumstances, the Administration 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.
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 Administration 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:
- signed agreement with the shipyard and EGCS supplier;
- written confirmation from the shipyard and/or makers that issues caused by the COVID-19 pandemic are the reason for the enforced delay;
- 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
- 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 CD-MSC 05-20 Modifications to Instrument Recordation and CD-MSC 06-20 Guidelines on Modifications to Instrument Recordation in Response to COVID-19 Pandemic.
If further guidance is required, please send an email by clicking on the button below.
It is important to state that the DMA 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.
- Brazil Ordinance No. 47 (English translation on second page)
- The Brazilian Health Regulatory Agency: COVID-19 – Guidelines for Embarkation and Disembarkation of Crew
- Centers for Disease Control and Prevention
- Centre for Health Protection, Hong Kong Department of Health, Updated Summary Table of Medical Arrangement for Visiting Vessels
- COVID-19 Restrictions – Online Tracker from the International Group of P&I Clubs
- DGS Order No. 12 of 2020 (22 April 2020), Standard Operating Procedures / Protocols (SOP) for Controlled Crew Change – Reg.
- EU & EC: COVID-19 Articles Related to Transport
- European Commission: Guidelines Concerning the Exercise of the Free Movement of Workers During COVID-19 Outbreak
- European Commission: Guidelines on Protection of Health, Repatriation, and Travel Arrangements for Seafarers, Passengers, and Other Persons On Board Ships
- France Prefectoral Decree No. 037/2020, Regulating Shipping and Maritime Activities in the Internal and Territorial Waters of the French Mediterranean Sea to Address the Coronavirus 2019 (COVID-19) Epidemic
- IATA and ICS: Governments Must Facilitate Ship Crew Changes
- ICS: Coronavirus (COVID-19) Guidance for Ship Operators for the Protection of the Health of Seafarers
- ICS China Liaison Office: Notice on Extension of Duration of Related Certificates of Chinese Flagged Ships and Chinese Seafarers Engaged in International Voyages
- ICS China Liaison Office: Notice on Further Strengthening the Personal Protection of Frontline Workers at the Port during the Outbreak of COVID-19
- ITF E-Circular No. 087
- IMO’s press page
- IMO Circular Letter No. 4204, Novel Coronavirus (2019-nCoV)
- IMO Circular Letter No. 4204/Add.1, COVID-19 – Implementation and Enforcement of Relevant IMO Instruments
- IMO Circular Letter No. 4204/Add.2, Joint Statement IMO-WHO on the Response to the COVID-19 Outbreak
- IMO Circular Letter No. 4204/Add.3, Operational Considerations for Management COVID-19 Cases/Outbreak On Board Ships
- IMO Circular Letter No. 4204/Add.4, ICS Coronavirus (COVID-19) Guidance for Ship Operators for the Protection of the Health of Seafarers
- IMO Circular Letter No. 4204/Add.5, Coronavirus (COVID-19) – Guidance Relating to the Certification of Seafarers
- IMO Circular Letter No. 4204/Add.5/Rev.1, Coronavirus (COVID-19) – Guidance Relating to the Certification of Seafarers and Fishing Vessel Personnel
- IMO Circular Letter No. 4204/Add.6, Coronavirus (COVID-19) – Preliminary List of Recommendations for Governments and Relevant National Authorities on the Facilitation of Maritime Trade During the COVID-19 Pandemic
- IMO Circular Letter No. 4204/Add.7, Coronavirus (COVID-19) – Guidance Concerning Unforeseen Delays in the Delivery of Ships
- IMO Circular Letter No. 4204/Add.8, Coronavirus (COVID-19) – Video Meeting with Port State Control (PSC) Regimes
- IMO Circular Letter No. 4204/Add.9, Joint Statement IMO-WCO on the Integrity of the Global Supply Chain During the COVID-19 Pandemic
- IMO Circular Letter No. 4204/Add.10, Joint Statement IMO-WHO-ILO on Medical Certificates of Seafarers, Ship Sanitation Certificates, and Medical Care of Seafarers in the Context of the COVID-19 Pandemic
- IMO Circular Letter No. 4204/Add.13, Coronavirus (COVID-19) – Recommendations for Governments and Relevant National Authorities on Facilitating the Movement of Offshore Energy Sector Personnel during the COVID-19 Pandemic
- IMO Circular Letter No.4204/Add.15, Coronavirus (COVID-19) – Personal Protective Equipment
- IMO Circular Letter No.4204/Add.16, Coronavirus (COVID-19) – COVID-19 Related Guidelines for Ensuring a Safe Shipboard Interface between Ship and Shore-Based Personnel
- IMO Circular Letter No.4204/Add.18, Joint Statement IMO-ICAO-ILO on Designation of Seafarers, Marine Personnel, Fishing Vessel Personnel, Offshore Energy Sector Personnel, Aviation Personnel, Air Cargo Supply Chain Personnel and Service Provider Personnel at Airports and Ports as Key Workers, and on Facilitation of Crew Changes in Ports and Airports in the Context of the COVID-19 Pandemic
- IMO Circular Letter No. 4204/Add.19, Coronavirus (COVID-19) – Guidance for Flag States regarding Surveys and Renewals of Certificates during the COVID-19 Pandemic
- IMO Circular Letter No. 4204/Add.22, Coronavirus (COVID-19) – Singapore Crew Change Guidebook
- IMO Circular Letter No.4204/Add.28, Coronavirus (COVID-19) – WHO Guidance to Promote Public Health Measures on Cargo Ships and Fishing Vessels
- IMO Circular Letter No. 4221, Communication from the Government of the People’s Republic of China
- IMO Circular Letter No. 4224, Communication from the Secretary-General
- IMO Circular MEPC.1/Circ.881, Guidance for port State control on contingency measures for addressing non-compliant fuel oil
- International Road Transport Union: Impact on Freight and Passenger Transport of the Global Coronavirus (COVID-19) Outbreak
- Joint Circular No. 01, Guidelines for the Establishment of the Philippine Green Lane to Facilitate the Speedy and Safe Travel of Seafarers, Including their Safe and Swift Disembarkation, and Crew Change During the COVID-19 Pandemic
- Joint JNG-ITF Statement: Crew Changes and Contractual Rights & Obligations
- MARINA Advisory 2020-23, Further Extension of Validity of STCW Certificates of Filipino Seafarers Currently Serving Onboard Seagoing Ships Amid Challenges caused by COVID-19
- MEPC 75/3, Draft amendments to MARPOL Annex VI
- CD-MSC 06-20, Guidelines on Modifications to Instrument Recordation in Response to COVID-19
- CD-MSC 07-20, Temporary Alternative Inspection Protocols During COVID-19
- CD-MSC 08-20, Handling the Validity of Ship Certificates Due to COVID-19
- CD-MSC 09-20, Handling ISM, ISPS, and MLC, 2006 Due to the Exceptional Circumstance of COVID-19
- CD-MSC 10-20, Coronavirus Disease Updates
- MSIB 09-20 Vessel Inspections, Exams, and Documentation
- MSIB: Extensions to Ballast Water Management related to COVID-19
- Paris Memorandum of Understanding Guidance Regarding the Impact of COVID-19
- Promare Newsletter – COVID-19: Updates in the North and Northeast ports and Crew Change proceedings in Brazil
- Ship Operations Cooperative Program: US Mariner Crew Change Facilitation Guidance for COVID-19
- WHO COVID-19 Interim Guidance, Rational use of personal protective equipment for coronavirus disease (COVID-19) and considerations during severe shortages