After Brexit changes for UK flagged vessels operating in German waters

Vessels flying a non-EU flag (except Norway) generally require a Cabotage Approval when operating in German waters.

After the Brexit this regulation also applies to UK flagged vessels operating in German waters.

Cabotage is the fee-based carriage of passengers or goods with a foreign-flagged vessel from one place to another within German territory using German coastal waters (12 nautical mile area).

Shipping companies do not require a Cabotage Approval if their ships

• carry goods or passengers to places outside coastal waters (12 nautical mile zone) – for example to offshore wind farms in an Exclusive Economic Area or

• do not carry goods or passengers for a fee, as for example is the case with assistance tugs in a port.

Vessels flying an EU flag are not required a Cabotage Approval.

The Cabotage Approval is often understood to be the same as the Certificate of Equivalence (CoE). However, they are actually two different documents with different purposes. Cabotage is about counteracting disadvantages for the freedom of economic activity of German shipping while the Certificate of Equivalence ensures a comparable degree of safety of all vessels operating in German maritime waters.

The Cabotage Approval is being issued by the German Authorties.

German BG Verkehr updates for Certificates of Equivalence

Within the CORONA crisis, German Maritime Authority BG Verkehr has announced measures with respect to the containment of COVID19.

Since for the time being BG Verkehr has stopped on board inspection several facilitations for vessel operators and owners have come into effect:

- Short term certificates with a validity of 3 months (until 30.06) can be issued as desk-top approval without the requirement of an inspection.

- Valid certificates will keep their validity if a required inspection isn't possible.

- Valid certificates can be extended by 3 months.

- Common annual or any other regular inspections or related services can be delayed or suspended for 3 months (until 30.06.) or at the most 3 months after the scheduled time frame.

Alterations concerning vessel inspections for CoE

From August 1st 2019 on there will be two major alterations concerning the application process for the CoE which vessel operators/owners should prepare themselves for.

The German Authorities BG Verkehr just informed that from that date onward following changes come into effect:

1. Inspections will only take place on the German coast. Having a vessel inspected outside of Germany won’t be possible any more.

2. Only one vessel per day will be inspected by the BG Verkehr inspectors. No combined inspections of more than one vessel will be possible any longer.

Aggravation in application for German Certificate of Equivalence

Due to a high amount of new applicants and some amendments BG Verkehr has made for foreign vessels applying for a German CoE, the requirements to receive a CoE have become stricter and higher.

Especially for vessels that have just been Coded under MCA Workboat (or Brown Code) and have not been further classed by a classification society the German Authorities tightened the requirements and are

interpreting the regulations stricter than before which might even lead to major structural modifications.

Whereas formerly only certificates have to be handed in completely prior to an inspection, currently these documents are to be scrutinized and approved by BG Verkehr before an inspection date can basically be organized and is granted. This results in high lead times for on board inspections. BG Verkehr officially states partly up to 6 weeks. Furthermore, BG Verkehr reserves their right to also check construction and system drawings prior to an inspection.

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Certifying Authorities - An alternative to Classification Societies

When it comes to Small Vessel Coding (for vessels below 24m Load Line Length) going with Certifying Authorities instead of Classification Societies gives you the same service and result with much less costs.

See below article from our partner MECAL:

https://www.linkedin.com/feed/update/urn:li:activity:6512411985890549760/

New MCA Workboat Code: Advice on changing and remaining regulations

WB2 was driven by the industry & was deliberately set at being a strong code partly due to criticism (particularly from outside the UK) of the weakness of MGN280 for workboats, which made it very difficult for some fleet operators to work abroad (particularly windfarm vessels).

The working group also decided that the use of 5 year safe history of vessel or model as a means of acceptance of structure was one of those weaknesses, hence it’s removal.

But the consequences to sectors of industry such as aquaculture & to the builders/suppliers of small workboats, where small production vessels of standard design are renewed on a regular basis, wasn’t foreseen. 

These small vessels may not have had independent approval of structure & may have been accepted via the safe history route.

• New workboats starting build on or after 31/12/18 –  Must comply with WB2

• Existing WB’s under Brown Code – continue as is -see Appendix 16

• Existing WB’s under MGN280 – continue as is but with recommendation from Mecal to change to Brown Code – see Appendix 16 (check with other CAs)

• Existing workboats under IWGTS (2014) – must phase into WB2 within a time frame – see Appendix 16

• New or existing coded vessels that are predominantly for leisure charter but want occasional light workboat duty – apply MGN280 with Mecal issuing a Light Workboat Certificate under Section 25.10 of the new code. Note that MGN280 will eventually be replaced by a new leisure commercial code which is currently in draft

• Existing workboats that have lapsed certification within the last 5 years – can continue under the same code following a periodical or renewal survey, according to the lapsed time

• Existing non-coded workboats with no code or structural approval history – must comply in full including a retrospective structural design approval, as advised by Mecal (not an easy route) 

• Existing non coded workboats with structural approval (eg originally built to class) – apply WB2, with scantling check if deemed necessary  

• New production workboats which are identical to existing vessels that have been coded under the previous codes – will have to comply with WB2 but Mecal may be able to carry out a simplified scantling check or examine & verify technical documents to satisfy the structural requirements of the new code

• In addition, there are aspects of WB2 which must also be applied to existing workboats coded under MGN280 & Brown Code. These relate to safety standards that have been revised over the years as a result of changing national or international regulations or as a result of MAIB Investigations. A Technical Working Group met in Nov 2018 to identify the applicable sections of WB2 & to determine the phase-in arrangements for these updates. The process will also include public consultation & impact assessment & it is hoped that this will be completed before the end of this year.

Freelance Surveyor needed

We are looking for a freelance Master,  Engineer or surveyor with experience in large CTV, OSV, AHTS, JackUp, survey and Accomodation vessels. Must be travelling and working on short notice (less than 12hours). Only north European, living close to an airport and CMID accredited preferred. Questions please in the comments.

Applications to info@brager.solutions. This is not a full time employment! Only freelance work and you need to be able to issue official invoices!

Major additions and changes in IMCA Audits

Due to recent changes and amendments by IMCA with regard to IMCA Audits, we would like to draw attention to a newly added section concerning data protection and cyber security.

With respect to this section in the IMCA Report and the requested standards vessels have to fulfill further requirements.

We assume that vessel owners/operators should expect more findings and also more time for audits and follow-up which we also have to take into account as surveyors for inspections, office work and follow-up.

German Certificate of Equivalence: Ballast Water Tank Exemption document

We recently had some cases where during their on board inspections, the German Authority inspectors of BG Verkehr asked for ballast water tank exemption documents.

Since according to the Ballast Water Management Convention vessels with 400GT and more need to have a Ballast Water Management Certificate along with a Ballast Water Management Plan and Record Book. Vessels being exempted are issued with a respective exemption certificate. However, small vessels generally don't have such.

Following the regulations of the German Authorities, small vessels (under 400GT) that don't carry ballast water tanks nevertheless are required to present a Ballast Water Tank Exemption document.

This document can be issued either by the classification society, certifying authority or Flag State where the vessel has been coded or classed. It is no certificate as such, rather a formal document of any of the aforementioned organisations stating that the coded/classed vessel does not include the capability to carry water ballast and isn't therefore likely to conduct an operation subject to the Water Ballast Management Convention. Hence, the vessel will not require to hold a Ballast Water Management Plan, or a Ballast Water Record Book.

Additional fees for IMCA CMID and MISW Audits

According to an announcement of IMCA they will be charging 100 GBP for an IMCA Report being uploaded by us IMCA inspectors to the IMCA database from June 18 on.

According to IMCA this service fee is demanded to manage the increase in use and enable future enhancements to the eCMID website and software. The fee however, will be passed on to us AVIs  who shall recoup the arising costs by including them in their inspection costs.

Now offering ROV Audits

BRAGER solutions is pleased to announce that we have expanded our services and are now providing special Audits for remotely operated vehicles (ROVs).

As official IMCA Accredited Vessel Inspector, we are qualified to carry out special ROV Audits which we offer our clients in addition to IMCA CMID and MISW Audits. A survey report is a verification tool for clients prior to charter an ROV that states its condition and operational readiness.

The Audits focus on all aspects of equipment, personnel and operations related to remotely operated systems that are used to support marine activities.

T-1Five merges with BRAGER solutions

In the course of a further development of our services our company T-1Five merged with BRAGER solutions. T-1Five focuses on the provision of patrol boats providing a continously updated portfolio of both used patrol boats for sale and new built products for which the company collaborates with selected shipyards worldwide.

IMPORTANT NOTICE: German Certificate of Equivalence

The German Authorities (BG Verkehr) recently has changed their practice with the German Certificate of Equivalence (CoE) that leads to new situations and requirements vessel operators have to face. A CoE is not issued without a prior on board inspection by a surveyor of BG Verkehr. Inspection dates will be allocated by BG Verkehr in general within a period of 1-2 weeks time.
 

„According to § 9, § 5 and Annex 1 letter D of the SchSV, vessels with less than 500 GRT have to provide evidence of equivalency with regard to safety and environmental protection according to German law. This is documented by a Certificate of Equivalence (CoE).

Following regulation is currently in force:

1. Any vessel applying for a German Certificate of Equivalance for the first time has to provide evidence of the required certificates (for vessel and crew) and is furthermore subject to an on board inspection carried out by a surveyor of BG Verkehr.

2. The following years vessels younger than 5 years can apply for an extension of the CoE without being subject to an inspection, just by giving evidence of the annual endorsements of the certificates.

3. Vessels older than 5 years can only apply for a yearly extension of the CoE by giving evidence of the annual endorsements of the certificates and after an inspection of a surveyor of BG Verkehr. This procedure is to be followed for all subsequent years.“

Read more about our service for GoC

New tailored service for IMCA clients

BRAGER solutions has recently established a new service tailored especially for vessel operators to deal with IMCA Audits request. A new fixed rate system for IMCA Audit services allows our clients requesting an IMCA CMID/MISW Audit to act faster and to safe time and act independently. No need to send us your request for a quotation. Just select the required service (CMID or MISW) and location of the vessel from a list and give us some further basic information on the vessel and your company and we can directly respond by confirming or offering another date proposal. Sign the email with the confirmed survey date, send it back to us and we are on it.

We are always keen to adapt to the needs of the industry and to offer high flexibility, short-term service and transparency and hope with this new service we are again one step further.

The service is accessible through our company website on a client restricted area.

 

IMCA surveys in Sassnitz

With meanwhile around 20 vessels is Sassnitz on of the busy offshore ports in Germany. Current windfarm operator demands valid IMCA audits for vessels operating in the field. For most CTV is the shortened MISW applicable. For vessels above 24m or with more 500grt the large CMID survey is required. As accredited surveyors we can assist with IMCA surveys on short notice.

Recent changes for IMCA CMID and MISW Audits

Being recently approached by a couple of vessel owners and operators who had problems with the acceptance of IMCA reports by their clients.

So far there were no restrictions for surveyors to carry out IMCA CMID and MISW surveys for vessels. However, due to a change of policy at IMCA meanwhile only IMCA accredited vessels inspectors do have access to the new and current IMCA survey templates (version 10) that are not only more comprehensive but also differ in certain aspects with regards to content.

Beside IMCA will soon be switching to online based IMCA reports and the electronic version of IMCA reports (eCMID) will only be accessible by accredited surveyors. IMCA is also working on a digital database where all IMCA vessels beloning or being managed by a company will be listed.

We recommend you to check if the surveyor who will be carrying out the next IMCA on one of your vessels is accredited by IMCA and does have access to the latest version of IMCA survey reports.   

As IMCA CMID Accredited Vessel Inspectors (AVI) we are carrying out CMID and MISW Audits all along the German Baltic and North Sea coast (Rostock, Sassnitz, Wilhelmshaven, etc.), we are regularly in port of Sassnitz but also in Denmark, Sweden and Norway.

Superyacht Refit Contractor

We expanded our services and portfolio in order to provide a turnkey solution for superyacht refits. We are able to deliver all different works and services out of one hand and to provide the client with one point of contact only in order to facilitate communication and make work-flow and decision processes more efficient. Specialized and experienced teams provide yacht painting and composite works as well as teak decking, interior, machinery and electrical systems. Along with an inhouse-engineering department and together with selected partners we are able to transfer Northern European craftmanship and deploy skilled teams in any location in the world. Whether be it remote locations or shipyards with lacking skills or personal, we are able to set up and manage a complete superyacht refit center anywhere in the world.

Our experience in yachting dates back to 1993 and includes numerous yachts we had been involved with globally for new building or refit. Over the years we have established tight relations with our partners partners who we teamed-up with in order to meet current and future business. We are pretty excited and looking forward to be in the business as a competitive, professional and reliable turnkey Superyacht Refit Service provider and to deliver our services to the largest shipyards and most discerning customers around the world.

Marine surveyor needed!

Marine Surveyor familiar with oil & gas fields assessment prior seismic exploration is needed for a survey in Libya ( 20 to 30 days maximum), he should be familiar with the geological aspects for oil and gas he would need to know main marine characteristics, water depth/dredging requirements, other shipping activity, as well as availability of land, site development requirements, proximity to load centres, proximity to gas infrastructure, local environmental and regulatory standards, etc. Interesting candidates please send your cv to info@brager.solutions