Overview

As the COVID-19 pandemic continues, some ships are experiencing operational challenges, such as shipyards or dry docks closing down. In addition, surveys and audits can in some cases not be conducted because surveyors are unable to attend the ships due to travel restrictions or quarantines.

BIMCO has collected available guidance from a number of flag states, port states and recognised organisations/classification societies (RO) and produced a regulatory analysis concerning COVID-19 and its possible implications on statutory ship certificates, surveys, inspections or audits under relevant International Maritime Organization (IMO) and International Labour Organization (ILO) instruments when due dates cannot be met.

The IMO has issued Circular Letter No. 4204/Add.1, addressed to all its member states. In this circular, the IMO Secretary-General addresses COVID-19’s impact on the shipping industry, including implementation and enforcement of mandatory IMO requirements. The circular encourages flexibility. The IMO can only encourage co-operation and a pragmatic approach between flag and port states. It cannot issue a general exemption from the mandatory provisions of the relevant statutory conventions, nor delay implementation of mandatory regulations coming into force – not even in the current uncertain situation caused by the COVID-19 pandemic.

In addition to the IMO circular, BIMCO has gathered a range of information from other organisations and analysed the consequences. The information and analysis are accessible from the BIMCO website here.