CERTIFYING AUTHORITY (CA) NEWS OCTOBER 2018
Published: 19 October 18
A review of a recent case of a vessel carrying certificates for two operational area categories has indicated that there may have been some confusion about survey regimes to support the issue and maintenance of more than one certificate.
Apologies for probably telling you something you’re already fully familiar with as it has been discussed regularly over the years during British Committee (BC)s and CA British Certification Committee (BCC)s, but ultimately it was worth sending out a reminder on the subject.
The purpose is to request Certifying Authorities to remind, as necessary, their surveyors of the general principles of certifying a vessel for more than one operational area category. Surveyors will be familiar with, for example, Section 188.8.131.52 in MGN 280 that sets out the survey regime for Area Category and Type of Service of the vessel in question. Further, as per the overarching requirements of Sections 3 and 27 of MGN 280, before being certificated a vessel must be surveyed and reviewed to ensure it complies with the requirements of the area category being sought and for the purpose to which the vessel will be used.
For a vessel that has more than one categorisation and certificated as such, the underlying principles of the Survey and Certification Regulations, which will apply to a Code vessel in that the Codes are an equivalence to the Load Line Regulations, are that the vessel should comply with the requirements of the more onerous area category.
It also follows that if a vessel is certificated to more than one category concurrently, then the more onerous survey regime in support of the higher category would apply. If the higher category certificate is suspended or lapses, then to reinstate the certificate the required surveys for that category must be carried out. It would not be permissible to reinstate the higher category certificate based on a lesser survey regime of a lower category.
SAN 93 may also be relevant when considering a lapsed, suspended or withdrawn certificate due to overdue surveys, specifically paragraph 2.2 referring to action required when an examination (survey) is requested more than one month after the required specified period.