Alterations concerning vessel inspections for CoE

From August 1st 2019 on there will be two major alterations concerning the application process for the CoE which vessel operators/owners should prepare themselves for.

The German Authorities BG Verkehr just informed that from that date onward following changes come into effect:

1. Inspections will only take place on the German coast. Having a vessel inspected outside of Germany won’t be possible any more.

2. Only one vessel per day will be inspected by the BG Verkehr inspectors. No combined inspections of more than one vessel will be possible any longer.

Aggravation in application for German Certificate of Equivalence

Due to a high amount of new applicants and some amendments BG Verkehr has made for foreign vessels applying for a German CoE, the requirements to receive a CoE have become stricter and higher.

Especially for vessels that have just been Coded under MCA Workboat (or Brown Code) and have not been further classed by a classification society the German Authorities tightened the requirements and are

interpreting the regulations stricter than before which might even lead to major structural modifications.

Whereas formerly only certificates have to be handed in completely prior to an inspection, currently these documents are to be scrutinized and approved by BG Verkehr before an inspection date can basically be organized and is granted. This results in high lead times for on board inspections. BG Verkehr officially states partly up to 6 weeks. Furthermore, BG Verkehr reserves their right to also check construction and system drawings prior to an inspection.

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German Certificate of Equivalence: Ballast Water Tank Exemption document

We recently had some cases where during their on board inspections, the German Authority inspectors of BG Verkehr asked for ballast water tank exemption documents.

Since according to the Ballast Water Management Convention vessels with 400GT and more need to have a Ballast Water Management Certificate along with a Ballast Water Management Plan and Record Book. Vessels being exempted are issued with a respective exemption certificate. However, small vessels generally don't have such.

Following the regulations of the German Authorities, small vessels (under 400GT) that don't carry ballast water tanks nevertheless are required to present a Ballast Water Tank Exemption document.

This document can be issued either by the classification society, certifying authority or Flag State where the vessel has been coded or classed. It is no certificate as such, rather a formal document of any of the aforementioned organisations stating that the coded/classed vessel does not include the capability to carry water ballast and isn't therefore likely to conduct an operation subject to the Water Ballast Management Convention. Hence, the vessel will not require to hold a Ballast Water Management Plan, or a Ballast Water Record Book.

IMPORTANT NOTICE: German Certificate of Equivalence

The German Authorities (BG Verkehr) recently has changed their practice with the German Certificate of Equivalence (CoE) that leads to new situations and requirements vessel operators have to face. A CoE is not issued without a prior on board inspection by a surveyor of BG Verkehr. Inspection dates will be allocated by BG Verkehr in general within a period of 1-2 weeks time.
 

„According to § 9, § 5 and Annex 1 letter D of the SchSV, vessels with less than 500 GRT have to provide evidence of equivalency with regard to safety and environmental protection according to German law. This is documented by a Certificate of Equivalence (CoE).

Following regulation is currently in force:

1. Any vessel applying for a German Certificate of Equivalance for the first time has to provide evidence of the required certificates (for vessel and crew) and is furthermore subject to an on board inspection carried out by a surveyor of BG Verkehr.

2. The following years vessels younger than 5 years can apply for an extension of the CoE without being subject to an inspection, just by giving evidence of the annual endorsements of the certificates.

3. Vessels older than 5 years can only apply for a yearly extension of the CoE by giving evidence of the annual endorsements of the certificates and after an inspection of a surveyor of BG Verkehr. This procedure is to be followed for all subsequent years.“

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