Circulars
  • Date: 6/30/2015
  • Series: RSR
  • Number: RSR 7 - 2015
  • Case number: 2015/9688-29

Regulation concerning amendment to the Regulations on a safety management system for Norwegian ships - requirement for DOC for fishing vessel companies

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The Norwegian Maritime Authority (NMA) has laid down a Regulation concerning an amendment to Regulations of 5 September 2014 No. 1191 on a safety management system for Norwegian ships and mobile offshore units. These amendments enter into force on 1 July 2015. For fishing vessels, the rules apply from 1 July 2016.

The proposed amendment was circulated for review from 18 March to 12 July 2015. The NMA received answers from 19 consultative bodies, whereof 2 had comments to the proposal.

The background for the amendments

The NMA wants fishing vessel companies to be issued with a separate Document of Compliance (DOC). The main reason for the amendment is to make the company's responsibilities and duties related to safety management clearer. It will become clearer whether a non-conformity is linked to a vessel or the company organization. This will increase the possibility of improvements in the ISM system for the company.

Today, there is a requirement for the safety management system for the company organizations of fishing vessels, cf. section 4 of the Regulations. According to existing rules, the audit that provides the basis for the issuance of a DOC must be conducted. This amendment therefore only lays down a requirement for the issue of the DOC..

It is also important to clarify that fishing vessel companies which do not have a shore-based organization are not required to establish such organization. After this amendment, it is still possible to have a company organization on board the vessel.

A DOC issued to the company organizations will also harmonize the requirement that apply to such companies with other parts of the industry. The safety management system and the certification will be the same, regardless of whether you are on board a fishing vessel or other types of vessels.

The requirement for the company organization to be issued with a DOC will also mean that the certification of fishing vessels complies with the requirements of the ISM Code.

Economic and administrative consequences

For companies that only have one vessel, there are only marginal adjustments in fees and time spent on audits. For companies that have several vessels, the audits will potentially be shorter on each vessel and will thus result in smaller fees and less time spent.

The new requirement will not result in any additional audits or new systems. Only completion of information on the certificate and any additional information from the company is required in connection with the issuance of a DOC. According to our estimates, this will result in a few hours of extra work. The benefit is that the company will get a better overview of where any non-conformities belong.

The ISM requirement for fishing vessels has already been introduced, and there will therefore be no further need for establishing competence or training in order to meet the requirement.

The NMA will conduct all audits and be responsible for the issuance of both the SMC and DOC.

Regulation concerning amendment to the Regulations on a safety management system for Norwegian ships and mobile offshore units

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