ItoS - National Legislation - Manning

Legend / Explanation of abbreviations:

• CoP: Certificate of Proficiency

• DGLM: Directorate-General for Civil Aviation and Maritime Affairs (Directorate for Maritime Affairs)

• IGC Code: International Code of the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk

• IMO: International Maritime Organization

• IGF code: International Code of Safety for Ships using Gases or other Low-flashpoint Fuels

• LNG: Liquefied Natural Gas

• MSC: Maritime Safety Committee

• NSI: Netherlands Shipping Inspectorate

• STCW code: The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978

• HTW: Human Element Training and Watch keeping

1 Manning of the ship in port

With regard to article 4.5 to 4.10 of the Netherlands Seafarers Act, the NSI:

1. does not require all members of the crew as mentioned in the ship's minimum safe manning document to be onboard at all times while the ship is in port;

2. allows for the master of the ship to decide if and when members of the crew may (dis-)embark from the ship or be granted shore leave when the ship is moored in a port.

Attention is drawn to the fact that local authorities may impose requirements regarding the number of persons present on board. If in doubt about local requirements, the local authorities should be consulted.

2 Declaration of communication

With regard to article 122 and article 123 of the Netherlands Seafarers Decree, the NSI:

1. requires the Declaration of Communication to be drawn up in the form given by NSI or in a format containing at least the same; and

2. does not require the Declaration of Communication to be approved or authenticated by the NSI. When the ship is inspected, compliance can still be verified. The purpose of maintaining the period of validity is to ensure that at regular intervals the ship manager verifies that all measures with regards to communication on board still corresponds to what is stated in the declaration.

3 The IGF-code in relation to manning requirements

3.1 Alternative IGF experience

Article 39a paragraph 3 of the Seafarers Decree requires that Masters, engineers, maritime officers and any other seafarer who has a direct responsibility in using fuel systems on board of ships with a fuel with a low flashpoint are to be in possession of an 'advanced IGF CoP'.

This requirement can be challenging for shipowners due to the fact that in order to apply for a CoP, the person in question needs to fulfill the requirements of Regulation V/3 paragraph 7 of the STCW-code, which include 1 month of seagoing experience on ships to which the IGF Code applies. In order to obtain this experience there already needs to be a sufficient number of IGF Code certified crew on board.

Due to the practical difficulties of obtaining this experience the underneath temporary solution may be applied. This means (alternative) experience listed below may also qualify:

• Experience gained during the construction of an IGF Code ship; this concerns the commissioning and test running of the installation;

• Experience gained on ships on which the IGF Code does not apply, but do use fuels with a low flash point (these are ships that were built before 1-1-2017). Because these ships are not subject to the IGF Code, the V/3 qualifications are also not mandatory on board;

• Experience gained on gas tankers to which the IGC Code applies;

• Experience gained with a shore installation that uses fuels with a low flash point;

• Experience gained on board inland ships that uses fuels with a low flash point;

• Experience gained at bunker terminals that load and unload IGF Code fuels or other fuels with a low flash point.

The information mentioned above is a temporary work instruction. It is the result of close cooperation between all interested parties including DGLM, NSI, Kiwa Register BV, employer and employee representation. It will remain in force until the 31th of December 2026 after which the above will be reviewed.

3.2 Other alternatives in relation to new fuel technologies

3.2.1 Background

Originally the IGF Code was developed for LNG. The IGF Code covers in its current version does not cover trainings for seafarers for individual new fuel technologies.

The IMO has developed and is currently developing guidelines on training for seafarers on ships using alternative fuels and new technologies. The IMO Sub-Committee on HTW:

• has finalized generic interim guidelines on training for seafarers on ships using alternative fuels and new technologies with the view of approval at MSC (111); and

• has commenced the development of the interim guidelines on training for seafarers on ships using methyl/ethyl alcohol as fuel; and

• has established a Correspondence Group to further develop the interim guidelines on training for seafarers on ships using methyl/ethyl alcohol as fuel, as well as individual sets of interim guidelines on training for seafarers on ships using other alternative fuels.

The above mentioned guidelines use as basis the IGF Code structure and additionally address different competencies as necessary for the fuel in question.

Reference is made to paragraph 16.6 of MSC.1/Circ.1621. The master, officers, ratings and other personnel on ships using methyl/ethyl alcohol fuels should be trained and qualified in accordance with regulation V/3 of the STCW Convention and section A-V/3 of the STCW Code, taking into account the specific hazards of the methyl/ethyl alcohol used as fuel; were the STCW Convention does not preclude specific (competency and training) requirements regarding alternative fuels with a low flash point, other than LNG. At the same time the IGF code in its current version does not cover competency and training for seafarers for individual alternative fuels and new technologies. Therefore, the below procedure is concluded.

3.2.2 Sailing on methanol as alternative fuel

In certain circumstances the work instruction related to 'alternative IGF experience' might still not be feasible to obtain sufficient onboard experience. Besides, the IGF advanced training is not considered relevant to this specific fuel (Methanol).

Shipowners shall have a clear plan how to safely operate a ship with the crew being in possession of a valid IGF-CoP for IGF Basic and in addition well trained and qualified (by declaration of participation) for the fuel-specific training. This training course shall be based on the principle of IGF advanced training, however amended for the fuel-specific risks and operational handling of the relevant fuel and shall be provided by a recognized training institute. This training institute is preferably recognized by NSI. The training institute is required to submit this training course/program to the NSI ([e-mail]) for pre-acceptance.

Requirements to sail under that condition include, but is not limited to:

1. In principle, the structure of the approach of the IGF basic and advanced training of the seafarer in question taking into account the interim guidelines as developed during HTW (11);

2. As the IGF basic training is used as the basis, additional specific training for advanced level for alternative fuels should be added taken into account the interim guideline developed at HTW (11), for which proof of a training or course of this respective type of fuel is available (declaration of participation);1

3. In case of bunkering operations, sufficient persons shall be on board, with proof of three bunker operations carried out, two of which may be part of the training mentioned under point 1 and/or 2;2

4. Declaration by the shipowner that:

   1. there is a sufficient amount of trained seafarers, as meant under paragraph 16.6 of MSC.1/Circ.1621, on board (who are in possession of the IGF basic CoP) and alternative training course as mentioned under point two; and

   2. the personnel has received sufficient instruction regarding the use of an alternative fuel (e.g. methanol) and is aware of the ship-specific risks resulting from the risk analysis prescribed in IACS recommendation 146; and

   3. reference is made to this ItoS.

3.2.3 Future amendments

If further agreements, regarding the training and certification of seafarers serving on ships propelled by alternative fuels, are reached at the international level (IMO / HTW), these will be adhered to in principle.

4 Dual-fuel ships not sailing on low-flashpoint fuels

For dual fuel ships, not sailing on low-flashpoint fuel for propulsion matters, there are 2 options:

1. No low-flashpoint fuel on board at all; or

2. Low-flashpoint fuel on board, only in bunkertanks.

4.1 No low-flashpoint fuel on board at all

On ships, equipped with dual-fuel systems, which are clearly defined as 'not low-flashpoint fueled ship' consequently no specific IGF STCW requirements are in place, and the crew can sail with the 'regular certificates'. If no low-flaspoint fuel is on board a ship at all, the STCW IGF-requirements are not applicable even when the ship has a formal Class Notation as a low-flashpoint fuel ship.

4.2 Low-flashpoint fuel on board, only in bunkertanks

The competency for seafarers on ships using IGF-fuel or an alternative fuel (such as methanol) becomes relevant when such fuel is used operationally.

Since there is ambiguity (internationally) compared to training requirements when a low-flashpoint fuel is carried as a product in the bunker tanks (under the relevant safety standards) but not used operationally, the position of the NSI is that, with reference to STCW Code I/14 and ISM Code Part A, any additional (training) requirements / competencies for seafarers when sailing in such a configuration is the responsibility of the ship owner; and should be laid down in the ISM / safety procedures for the respective ship, which covers at least:

• Competency in the safety requirements relevant to the fuel;

• Competency in case of emergencies / incidents.

• Informatietype: Informatie voor uitvoering
• Documentsoort: Nieuwsbrief
• Toegangsrechten: Extern
• Identificatie: PUC_789775_14
• Versie: 2
• Datum beschikbaarheid: 05-06-2025
• Geldigheid van: 06-06-2025
• Wijzigingsdatum: 05-06-2025
• Titel: ItoS - National Legislation - Manning
• Organisatie: Inspectie Leefomgeving en Transport
• Taal: Engels
• Thema: National legislation - Decisions and Interpretations