Because of the COVID-19 pandemic, there are unfortunately many laid-up ships. From time to time, the Norwegian Maritime Authority (NMA) receives accident reports from companies with laid-up vessels, or vessels that are at berth for long periods of time. Often, these reports are about fires on board or broken moorings. We also get reports on operational problems when, or just after, a vessel is recommissioned after a significant lay-up or berth period. 

Accidents and incidents with no crew on board often lead to bigger challenges than if the ship had been in normal operation. The weather varies, machinery is not in normal operation and the power comes from ashore. The NMA therefore recommends that the company and crew make sure that the vessel is securely moored and protected against various conditions before the regular crew is reduced. 

With an approved security management system or ISM, there are also tasks that must be carried out even if the vessel is not in regular operation. The functions this applies to varies between vessel types and sizes. However, it is important to make sure that the maintenance work that can be carried out is carried out so that there are no surprises when the vessel is recommissioned. 

Risk assessment is key 

We also recommend that a risk assessment of the lay-up is carried out based on the location and duration of the lay-up, and necessary measures that must be in place. To many this is new, and not something that they considered a couple of months ago. 

Any work operations carried out on board during lay-up must be risk assessed the same way they would have been during normal operation. Crew remaining on board and working there are still subject to most of the requirements for sailing ships. 

General requirements  

The company and master must consult local authorities, classification societies and insurance companies in order to clarify any special requirements related to lay-up and lay-up location. The company and the master are responsible for the safe operation of the ship. The NMA will therefore not stipulate a minimum safe manning for the lay-up period. The size of the crew will depend on several factors, e.g. lay-up location, level of security, hot or cold lay-up and local requirements. 

Operational safety and security (ISPS) 

The following equipment and systems must be operable and be maintained: 

  • Life-saving equipment and distress signals appropriate for lay-up location and the number of persons on board 
  • Fire-fighting equipment for relevant areas on board including the emergency generator, emergency fire pumps, emergency batteries and other required equipment that maintains the fire safety 
  • Relevant alarm systems 

Operational requirements in MARPOL shall be complied with 

With regard to the security of laid-up ships, it is a precondition that the ship has been satisfactorily secured against unauthorised access. This means that the ship shall have a watchkeeping arrangement that ensures that unauthorised persons cannot gain access on board, and that any visitors are logged with time and duration of visit. Consequences for ISSC: 

  • Lay-up period of up to 3 months: No consequences apart from the requirement to do a thorough search of the ship prior to departure in order to uncover any irregular conditions on board. The ship may then sail with its original ISSC. 
  • Lay-up period from 3 to 6 months: In addition to the action mentioned in point 1, a physical verification audit shall be carried out on board the ship, either by the NMA or an RSO (Recognized Security Organization). The purpose of the verification is to confirm that any changes made on board during the lay-up period are not in conflict with the ship's security plan, and that technical equipment included in safety measures are found on board and are in working order. 
  • Lay-up period of more than 6 months: The ship must be subjected to a new certification pursuant to the current regulations unless exceptional circumstances indicate that an exemption should be granted. Exemptions may be granted following a written application to the NMA. 

Insurance 

Hull and Machinery and P & I insurance shall be maintained in accordance with the insurance companies' requirements. 

“Certificate of Insurance or other Financial Security in Respect of Civil Liability for Bunker Oil Pollution Damage” shall be valid. 

Recommissioned vessels

Lately, we have seen vessels being recommissioned. This could be an indicator that the need for maritime transport is rising. Regrettably, there have been some incidents where recommissioned vessels have run into problems and needed towing to avoid breakdown.

To ensure that the vessels are operative, it is important to keep all systems on board well maintained and fit for the safe operation of the vessel after lay-up. Depending on the duration of the lay-up, there are different requirements that must be met when a vessel is recommissioned.

For vessels not flying the Norwegian flag, it is important to act in accordance with the guidelines issued by the flag State and/or class. Any port State requirements must also be met.