Isle of Man: Note on the IOMSR General Inspection schemes

The Isle of Man Ship Registry on 19 May 2023 issued a shipping note on the IOMSR General Inspection schemes.

Introduction

This notice only applies to Merchant Ships and does not apply to commercial yachts, pleasure yachts, or fishing vessels.

Isle of Man Ship Registry (IOMSR) surveyors are periodically required to undertake flag state General Inspections (GIs) on board Manx ships to ensure satisfactory standards are being maintained by the vessels flying the IOM flag.

There are two GI schemes: the Annual GI Scheme (AGI) and the ‘2 in 5’ Scheme.

The AGI Scheme makes use of remote inspection technology to inspect Manx ships more frequently (annually instead of twice in 5 years) while the ‘2 in 5’ Scheme encompasses only physical inspections undertaken in the traditional manner.

The differences between remote and physical inspections are explained in section 2 below.

The AGI scheme was introduced in 2022 with the intention of establishing more regular contact with the vessels on the Manx flag and offering IOMSR and clients greater flexibility in how and where inspections took place.

Although the scheme has been generally successful, feedback from the first year of the scheme has identified that there have been some issues in establishing a reliable and clear data link to the vessels.

We have found that there are also a number of areas of the vessels where it has been very difficult to inspect with the remote technology such as machinery spaces, accommodation, and deck areas. Accordingly, we are making some changes to the scheme in response to feedback.

These changes are outlined below.

Shipowners and operators who wish for their ships to be placed or remain on the AGI scheme will have to apply to the Ship Registry by completing and submitting form S084 to Marine.Survey@gov.im.

For new ships, this must be done prior to registration, and for existing ships, this must be done prior to 1 July 2023.

As part of this process, shipowners and operators will have to demonstrate to the satisfaction of the Ship Registry that their ships have the required internet connectivity, bandwidth, and cyber security protocols to conduct AGIs.

If the application is unsuccessful, then ships will be placed on the ‘2 in 5’ Scheme, together with any ship which has not applied to go onto the AGI scheme.

The Ship Registry retains the right to refuse an application to the AGI Scheme based on ship, owner/operator PSC, Class, external closed source, and open-source data.

Types of General Inspection

2.1 Physical Inspection

All ships will require a physical inspection at some point during the GI cycle.

For ships on the AGI Scheme, this will be once every 5 years. For ships on the '2 in 5' scheme, this will be twice every 5 years.

In general, a physical GI will take around 12 hours to complete.

The inspection will be similar in format to an expanded PSC inspection and should be prepared for in the same way. An opening meeting will take place with all available crew for introductions and planning of the inspection. A full inspection of the vessel will then take place.

The surveyor will arrange to work around the crew's schedule in order to not affect their working pattern or interfere with their minimum hours of rest.

There will be a closing meeting with available crew to discuss the results of the inspection findings, any deficiencies raised, and the proposed timeframes/corrective actions for closing them out.

An inspection report will be provided following completion of the inspection.

2.2 Remote General Inspections

In order for a Remote GI to take place, it is necessary for the ship to have a reasonable level of connectivity, sufficient for the transmission of high-quality video, and the Company to have completed the declaration in Form S084 (See Section 1).

Remote GIs will take place only for ships on the AGI Scheme. In a 5-year cycle, they will take place annually, with the exception of the 5th year in which the physical GI takes place.

Although remote GIs are more frequent, they are reduced in scope compared to a physical GI and will only target specific areas.

The targeted areas will be identified by an analysis of our data to identify areas where the inspection can provide the most value.

Such analysis will consider factors such as items which are high risk of PSC detention, current PSC campaigns/trends, and class deficiencies.

Remote inspections will be approximately 4 hours and will target a different area each year.

An inspection report will be provided following completion of the inspection.

Survey Schemes

The below is provided as a general overview of the operation of each scheme, however, in some cases, it may be necessary to vary the application of the rules of either scheme for operational reasons. Should this be the case, IOMSR Survey Department will contact you to discuss.

3.1 Annual General Inspection Scheme

The Annual GI scheme works on a cycle of up to 5 years, with one physical GI and four annual remote GIs required within a 5-year period.

In general, this will consist of a remote GI for the first 4 years of the cycle, to take place 3 months either side of the anniversary of the start date. In the fifth year, a physical GI will take place before the 5th anniversary and may be completed up to six months prior.

After the physical GI takes place at the end of the 5-year cycle, a new GI cycle will commence, with the start date of the new cycle being the date of the physical GI that has just taken place.

This is to ensure that there will never be more than 5 years between physical GIs and will mean that the GI 'window' will differ slightly between each 5-year cycle.

This is shown below:

3.2 '2 in 5' Scheme

The '2 in 5' Scheme consists of two physical inspections within a 5-year period with a maximum of 3 years between inspections.

The 5-year window begins from the start date and cannot run past the fifth anniversary of the start date.

3.3 Exemptions

Where strict compliance with the above survey windows is not possible, the Ship Registry may issue an Exemption relating to one or more of the above GIs.

It should be noted that if an Exemption is issued, it will apply only to the GIs stated on it and will not extend the due date of any subsequent GIs unless stated.

Costs

Fees for the inspections referred to in 3.1 and 3.2 are covered within a vessel's consolidated annual fee, regardless of where and how the GI is undertaken.

To keep IOMSR fees and GHG emissions low, IOMSR will work with the vessel's operator to ensure the GI takes place at a mutually convenient port where travel time is kept to a minimum.

Pre-registration Surveys and additional inspections outside of normal requirements are not included within annual fees and are billed separately. For more information, refer to IOMSR fees page.

Pre-Registration Inspections

All new vessels are attended for a pre-registration survey, however, this may be carried out by either a surveyor from the Isle of Man Ship Registry or by Class depending on the following criteria:

5.1 New Build

A new build ship will not normally require a pre-registration survey by an IOMSR surveyor if similar ships from that yard have shown to be of an acceptable standard.

They will, however, have to be attended by the vessel's RO for a pre-registration survey in all cases.

This will take the form of normal Class surveys carried out as part of the survey process to allow certification to be issued.

In determining whether a pre-registration survey is carried out by an IOMSR surveyor required we will also consider the following factors:

Is the vessel type new to the yard?
The technical manager's inspection procedure and/or survey report and whether the manager is known to IOMSR
Technical manager's fleet PSC history
Relevant information from the ship's RO.

5.2 Existing Ships Less Than 10 Years Old

Again, existing ships less than 10 years old that are transferring onto the Isle of Man flag will not normally require a pre-registration survey from an IOMSR surveyor unless there are sufficient adverse indicators. Such indicators may be derived from:

Previous flag's Paris MOU status
PSC history for the Ship or Technical Manager
Information from the ship's RO records. If not attended by an Isle of Man Ship Registry surveyor, then the vessel's RO will have to attend for a pre-registration survey.

5.3 Existing Ships More Than 10 Years Old but Less Than 20 Years Old

These ships will always require a survey carried out by an IOMSR surveyor, however, this can be either before registration or deferred for up to six months from the date of registration. This determination will be made on the same criteria as those listed above.

If an IOMSR surveyor does not attend prior to registration, the vessel will require a pre-registration survey from the RO.

5.4 Existing Ships More Than 20 Years Old

These ships require special permission to register and require a pre-registration survey by an IOMSR surveyor that cannot be deferred. The GI cycle will begin from the date of registration.

Frequently Asked Questions

How do I arrange an Inspection?

Contact IOMSR at marine.survey@gov.im around one month before you wish the inspection to take place.

Can I switch from one GI scheme to another?

This will only be permitted in certain circumstances since switching between the schemes creates various administrative difficulties due to the different rules associated with each scheme.

How do I know which scheme my ship is on?

If you are unsure, contact IOMSR at marine.survey@gov.im.

How do I know when my GI is due, and will I receive a reminder that it is due?

It is the Master's responsibility to request the attendance of a surveyor to conduct GIs when due. Although you may be contacted by the Ship Registry on occasion when ships are due for inspection, you should not rely on this.

Can remote GIs be done at Sea?

Yes, in most cases, provided you have a reliable internet connection, router coverage extenders (and suitable Ex rated equipment if you are a tanker).