Onderwerp: Bezoek-historie

ItoS - National Legislation - Manning
Geldigheid:04-11-2025 t/m 28-06-2026Versie:vergelijk Status: Was geldig

Dit onderwerp bevat de volgende rubrieken.

Legend / Explanation of abbreviations:

  • CoC: Certificate of Competency, as defined by Regulation I/1.30 of the Annex to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers

  • CoP: Certificate of Proficiency, as defined by Regulation I/1.31 of the Annex to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers

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

  • EEZ: Exclusive Economic Zone

  • HTW: Human Element Training and Watch keeping

  • 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

  • MSMD: Minimum Safe Manning Document

  • NSI: Netherlands Shipping Inspectorate

  • OOW: Officer in charge of a navigational watch

  • PSCRB: Proficiency in Survival Craft and Rescue Boats (other than fast rescue boats)

  • SMBW: 'Schipper machinist beperkt werkgebied'

  • STCW: The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended including the Annex and the Code

1 Manning of the ship in port

With regard to article 4 and article 9 of the Netherlands Seagoing vessels crew 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 Manning of the ship on inland waters

It shall be noted that the minimum crew composition on inland waters and within port limits is subject to specific legislation applicable on inland waters. The minimum amount of crew can differ from that mentioned on this MSMD. It is the responsibility of the owner to ensure that the ship also fulfills the requirements of this specific legislation.

3 Documentation relevant to manning

3.1 Declaration of communication

With regard to article 2.4.6 and article 2.4.7 of the Netherlands Seagoing vessels crew Decree, the NSI:

  1. requires the Declaration of Communication to be drawn up in the form provided by the 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.

3.2 Seaman's book

Every seafarer holding a CoC and working on a ship flying the flag of the Netherlands must be in possession of a valid Seaman's book (in Dutch: 'monsterboekje').

For every other seafarer an alternative document which must be signed by the Master is sufficient. The alternative document shall comply with article 2.3.3 (especially sub 4) of the Seagoing vessels crew Regulation.

With reference to article 22 of the Netherlands Seagoing vessels crew Act, seafarers who do not have the Dutch nationality can use their foreign seaman's book subject to the condition that it is written in (at least) the English language or, when in another language, a copy is also available in English.

For more information regarding the application process, please refer to the website of Kiwa Register, which issues Dutch seaman's books on behalf of the Dutch Minister of Infrastructure and Water management.

3.3 Amendments to Basic Training (Section A-VI/1)

In line with Res.MSC.560(108) training institutions are required to make adjustments to Table A-VI/1-4 of the Basic Training course. These Adjustments are related to training provisions to prevent and respond to bullying and harassment in the maritime sector, including sexual assault and sexual harassment.

Effective the 1st of January 2026, all Basic Training courses must incorporate these new provisions as part of the curriculum, both for the initial issuance of a CoP and for refresher (renewal) training.

The NSI would like to confirm that the Basic Training CoP's issued prior to the 1st of January 2026 remain valid and only seafarers who will follow the Basic Training course on- or after the 1st of January 2026 will be required to meet the new criteria as specified in Res.MSC.560(108).

Nevertheless, the NSI strongly encourages shipowners to ensure that all crew members are familiar with the new requirements and related guidance on preventing and responding to bullying and harassment at sea.

3.4 Limitations on Dutch CoC's in regards to the 'international coast'

3.4.1 Near Coastal CoC

As of the 1st of July 2025 the Netherlands no longer issues II/3 and III/3 CoC's with a 'International Coast' (SMBW) limitation.

Between the 1st of May 2014 and the 30th of June 2025 the Netherlands has issued CoC's with an 'International Coast' limitation. In practice this limitation was sometimes perceived as providing the right to conduct international voyages. However section A-I/3 paragraph 2 of the STCW code explicitly prohibits this. Therefore as of the 1st of July 2025 the highest possible limitation on a 'Near Coastal' CoC will be the Dutch EEZ.

This means that any seafarer, who wishes to extend the validity of his or her CoC, or applies for subject CoC for the first time, will receive a maximum limitation of the Dutch EEZ.

3.4.2 Implication for sailing in foreign waters

It is important to note that this change does not necessarily mean that a CoC with an EEZ limitation cannot be used in foreign waters. The Netherlands has set agreements, under STCW Regulation I/3, allowing Dutch CoCs with an EEZ limitation to be used in Belgian and German waters that are classified by those countries as 'Near Coastal Voyages'. In all other cases we urge ship managers to verify with the local authorities if the COC's in question can be used in the waters of the respective party.

3.5 CoP PSCRB or CoP Safety Training Sailing Vessels less than 500 GT

As of the 1st of July 2026, every officer on board of sailing vessels <500 GT will be required to hold a valid CoP for PSCRB or a CoP Safety Training Sailing Vessels less than 500 GT The latter course, for sailing vessels <500 GT, is an equivalent to the regular PSCRB CoP and is better suited for the specific conditions and equipment on sailing vessels <500GT.

As a result of consultations with the branch, until the 1st of December 2025, sailing vessels <500 GT are exempted from having a seafarer on board in possession of a valid CoP PSCRB or valid CoP Safety Training Sailing Vessels less than 500 GT.

From the 1st of December 2025 onwards there must be at least one seafarer on board who is in possession of one of the aforementioned CoPs.

From the 1st of July 2026 every officer will have to be in possession of one of the aforementioned valid CoPs in order to serve on Dutch flagged sailing vessels <500 GT. From this moment onwards the CoP PSCRB or CoP Safety Training Sailing Vessels less than 500 GT will also be mandatory in order to obtain a CoC as an officer on sailing vessels <500 GT.

3.6 'OOW sailing vessels' function in regards to the Dutch MSMD's for sailing vessels below 500 GT

In accordance with the Dutch Shipping legislation (Seagoing vessels crew Act and the respective Decree and Regulation), a seafarer in possession of the COC 'Officer in charge of a navigational watch on sailing vessels <500 GT in unlimited trading area' (NL code 174), may fulfill the function of 'Chief mate on sailing vessels of less than 500 GT in unlimited trading area'.

The above is meant to overcome a difference in terminology in regards to the CoC's and MSMD's.

4 The IGF-code in relation to manning requirements

4.1 Alternative IGF experience

Article 3.3.4 paragraph 4 of the Netherlands Seagoing vessels crew 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.

4.2 Other alternatives in relation to new fuel technologies

4.2.1 Background

Originally the IGF Code was developed for LNG. The IGF Code 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; where 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 has been concluded.

4.2.2 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 (nsi-stcw@ilent.nl) 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);3

  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;4

  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.

4.2.3 Advanced level training

Regarding who should be trained, and in line with Article 3.3.4, paragraph 3 of the Seagoing Vessels Crew Decree, the Master, Engineer Officers, Maritime Officers, and any person with immediate responsibility for the care and use of fuels or fuel systems are required to complete advanced-level training (for Methanol: the additional specific training).

The NSI would like to clarify that the following functions are considered to fall under the definition of 'immediate responsibility for the care and use of fuels or fuel systems':

  • Operating or monitoring the fuel systems (e.g. bunkering, transfer, storage, or consumption of gas fuels such as LNG or Methanol);

  • Maintaining or repairing fuel system components; and

  • Supervising other personnel engaged in work involving fuel systems.

However, since the above list should not be considered exhaustive, sufficient knowledge among the crew, and ensuring that the crew is well trained (e.g. for competency in the safety requirements relevant to the fuel and in case of emergencies / incidents) are the responsibility of the ship owner.

4.2.4 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.

5 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.

5.1 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.

5.2 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.

6 Regulation regarding experimentation in the case of (demonstrable) technological innovation

The new Seagoing vessels crew Act provides a scope for conducting experiments linked to a specific seagoing ship in cases where demonstrable technological innovation is involved. The conditions that such an experiment must meet are set out in Article 3 of the Seagoing vessels crew Act. These conditions are defined in consultation with the relevant organizations representing ship managers, seafarers, and other stakeholders involved in the experiment.

This includes considerations such as the specific purpose, usefulness, and necessity of the experiment, with an assessment of whether technological innovation is indeed present. The maximum duration of the experiment is set at three years, which is deemed sufficient for the execution of the experiment in question. This period can, be extended for a further three years under certain circumstances.

This approach is meant to experiment with:

  • The crew composition of a specific ship; and

  • The qualifications of seafarers working on board of a specific ship.

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