From: Stephen Keenan

Cc: BMA Director; Alessandro Lo Piccolo; Arie Durbazevs; Atsushi Magaino; BMA Inspections & Surveys; Capt. Dwain
Hutchinson; Capt. Jahangir Hussain; Capt. Lester Pink; Capt. Steve Bomgardner; Christos Chrysovitsanos; Christos
Papastathopoulos; Dimitri Tsiftsis; Giovanni Ciniglio; Jerry Mooney; Kenneth Carey; Marie Caillerie; Nick Dowden; Oli Olsen;
Paras Thukral; Tom Jenkins
Subject: COVID19 - ISM/ISPS/MLC audits/inspections
Date: 13 March 2020 16:20:22
Attachments: SigLogo_8c9b19d3-ec9d-4b13-a65b-5da9421b8f21.png
Importance: High

To Bahamas Recognised Organisations

Dear all

Thank you for your continuous support and assistance.

As outlined in BMA Technical Alert 20-03, the ongoing COVID-19 pandemic is resulting in various restrictions and
limitations which are having a serious effect on the continuity of maritime operations on a global scale.

The BMA shares the concerns expressed by the numerous Bahamas Recognised Organisations, shipwowners,
inspectors and other stakeholders with regards to timely completion of surveys and verifications due to
restrictions on travel. Timely completion of ISM Internal Audits and ISM/ISPS/MLC renewal verifications are
amongst the most frequently reported difficulties.
 
The BMA therefore temporarily authorises Bahamas Recognised Organisations to allow, where requested by the
Company, extensions to annual ISM internal audits for up to 3 months, as per para 5.6 of BMA Information
Bulletin 23 and para 12.1 of the ISM Code in cases where audits cannot be carried out due to travel restrictions
imposed due to COVID19. With regards to SMC and ISSC Renewal Audits, and noting the provisions of ISM
Code 13.14 and ISPS Code A-19.3.5, the BMA authorises its Recognised Organisations to issue 3 month
extensions, where requested by the Company, to existing SMC and ISSC Certificates.
 
MLC 2006 does not provide for the issue of extensions to existing MLC Certificates without inspection. However,
in this exceptional situation, the BMA authorises its Recognised Organisations to administratively issue a
Maritime Labour Certificate for 3 months in cases where the renewal inspection cannot be conducted due to
COVID19 restrictions. The Recognised Organisation shall state that the certificate has been issued to allow the
ship to continue on its intended voyage and complete the renewal inspection at the first port where inspectors are
available. When the renewal inspection has been completed a full term Maritime Labour Certificate may be
issued with its expiry date not later than 5 years from the expiry date of the original full-term Maritime Labour
Certificate.
 
The Recognised Organisation shall inform the BMA of each occasion where the above has been carried out, to
tech@bahamasmaritime.com
 
These temporary measures shall remain in place for a period of 3 months starting from 16 March 2020 and are
subject to review as the situation develops.

Kind regards,

Stephen Keenan IEng, IMarEng, MIMarEST, MRINA

Deputy Director
Inspections & Surveys Department

120 Old Broad Street

London | EC2N 1AR | United Kingdom

T: +44 (0) 20 7562 1300 (main)

T: +44 (0) 20 7562 1346 (direct)
E: skeenan@bahamasmaritime.com
E: tech@bahamasmaritime.com
bahamasmaritime.com

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