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The new "State of medical knowledge" includes, besides an equipment list, practical information on the storage of drugs and medical products on board. The changes in comparison to the previous state of medical knowledge are given in an information leaflet . Both the "State of medical knowledge" and the accompanying leaflet are currently being translated.

Shipowners only have to implement the changes of the medical equipment by the next annual inspection. 

For our and your benefit, please note: During inspections on board, it has been noticed that a lot of the time only the last attestation by the pharmacy was kept on board. However, sec. 109 para. 3 of the Maritime Labour Act requires the last 5 attestations be kept on board. Please make sure that the last five attestation are available on board in the future.

More information on this topic can be found in our section on "Maritime Medicine".

For the protection of the environment: Starting from 1^st Febuary 2025, a new form of the International Ballast Water Record Book is applicable. 

The IMO Resolution MEPC.369(80) has been made mandatory under national law with the 4^th Ordinance on Amendments of International Conventions for Climate and Environmental Protection on Seagoing Traffic (Vierte Verordnung zur Änderung Internationaler Übereinkommen zum Klima- und Umweltschutz im Seeverkehr) of 14.01.2025.

We ask all shipping companies to use the new form for their Ballast Water Record Books.

The previously applicable form of the International Ballast Water Record Book will no longer be valid as of the end of January.

Read latest PSC Awareness Newsletter: PSC Awareness 03/2024

On 30 November 2024, the "Ersten Verordnung zur Änderung schiffssicherheitsrechtlicher Vorschriften" (first ordinance on amending ship safety instruments) has entered into force. It contains extensive changes, mostly of the "Schiffssicherheitsverordnung" (ship safety ordinance) the Federal Ministry of Digital and Transport (BMDV). You can find the consolidated version of the "Schiffssicherheitsverordnung" on the website gesetze-im-internet.de. The BMDV has also changed the "Seesportbootverordnung (SeeSpbootV)" (recreational craft ordinance) regarding commercially used recreational craft. Its consolidated version is also available on the website gesetze-im-internet.de.

The most important changes and regulations are:

1. Safety requirements for commercially used small craft (e.g. water taxis) have increased.
2. Small craft that are not used commercially but for non-material purposes do not require a ship safety certificate.
3. Neither does the "Schiffssicherheitsverordnung" apply to recreational craft that are only used for sport and recreational purposes.
4. The previously required certificate of equivalence for small ships flying a foreign flag navigating in German coastal waters is no longer necessary.
5. Operation of small passenger ships navigating the Tidal Flats or as ferry to and from Helgoland is simplified.
6. Magnetic compass adjustments for ships are not limited to state-recognized compass adjusters anymore.
7. Authorities can use their own survey regime for their authority vessels.
8. There are longer transitional periods in place for ships of traditional build.

Regarding the individual regulations:

1. Increased safety requirements for commercially used small craft

The main focus of the current ordinance amendments is the increased safety requirements for commercially-used small craft. The intention of the Federal Ministry of Digital and Transport (BMDV) is to reduce the hazard potential of these small craft.

According to the "Schiffssicherheitsverordnung", publicly and relatively regularly offering an undefined group of persons the carriage of persons or cargo or providing services for a fee – regardless of the fiscal assessment – constitutes commercial usage. The intent of profit realization is not necessary. Relative regularity exists if the usage occurs only on very isolated occasions and in rare exceptional cases for a very low fee.

The recently amended "Schiffssicherheitsverordnung" defines small craft as cargo ships with a length of less than 24 m. This includes among others:

• Craft of less than 8 m for which manning requirements had been in place before but no mandatory safety standards acc. to the "Schiffssicherheitsverordnung",
• water taxis and other craft that commercially transport up to 12 passengers,
• other craft used commercially,
• recreational training craft from 8 m in length used for training in order to attain the recreational craft drivers licence,
• berth charter boats,
• craft provided with a crew hired to people for a fee for sport and recreational purposes.

According to the latest amendments of the "Schiffssicherheitsverordnung" and "Seesportbootverordnung", the following provision, among others, apply for commercially used small craft:

• They require a ship safety certificate by the BG Verkehr and will be subjected to surveys by BG Verkehr on a regular basis.
• Categorically, they have to be built in accordance with the provisions of a classification society or the EU Directive 2013/53/EU on recreational craft and personal watercraft and are subject to the regulations of "Schiffssicherheitsverordnung", Annex 1a, Part 6, Chapter 3.
• They may navigate a trading area that is dependent on a boat's type and design category (individual approval for berth charter, hiring a commercially used "recreational craft" with crew, and recreational training craft).

If small craft carry passengers commercially (like for example in the case of water taxis), additional requirements apply:

• Only not open craft of design category "B" are permissible.
• The craft have to be provided with a class A automatic identification system (AIS).
• Before the voyage begins, a safety instruction for all passengers is mandatory.
• Restrictions due to the weather apply.
• A maximum of 12 passengers may be carried.

It is commercial carriage of passengers if the carriage of persons for a fee is publicly and relatively regularly offered to an undefined group of persons. The intent of profit realization is not necessary.

For small craft already in service and commercially used recreational craft, both of which had previously already been issued a safety certificate by BG Verkehr, different transitional due dates apply:

• For craft with a length of less than 8 m that had already been in service up to 29.11.2024 and used for commercial passenger carriage, ship safety certificates for small craft acc. to the "Schiffssicherheitsverordnung" are required from 01.06.2025.
• For craft with a length of less than 8 m that had already been in service up to 29.11.2024 and used for another kind of commercial usage, ship safety certificates for small craft acc. to the "Schiffssicherheitsverordnung" are required from 01.06.2026.
• For craft that had already been issued a safety certificate for commercially used recreational craft prior to 30.11.2024 and will continue to be used for this kind of purpose only, certificates may only be renewed until the end of 2033.

The following craft may be issued a safety certificate acc. to the "Schiffssicherheitsverordnung" and the "Seesportbootverordnung":

• Craft used for hiring out sleeping berths or cabins for a fee for sport and recreational purposes (berth charter boat),
• Craft used for hiring out for sport and recreational purposes with skipper or crew for a fee,
• Recreational training craft (from 8 m in length)
  
  

2. The "Schiffssicherheitsverordnung" does not apply to craft used non-commercially and for non-material purposes

Small craft operated non-commercially and for non-material purposes are not subject to the regulations of the "Schiffssicherheitsverordnung". This includes among others craft belonging to associations/clubs with less than 24 m in length by SAR organizations carrying out privately organized search and rescue missions e.g. in the Mediterranean Sea and that are not categorized as merchant vessels due to a charter contract. Also excluded are small craft operated for other non-commercial and non-material purposes (e.g. environment protection, scientific marine observation).

3. The "Schiffssicherheitsverordnung" does not apply to recreational craft privately and intended for sport and recreational purposes

As before, the "Schiffssicherheitsverordnung" does not apply to recreational craft used privately and intended for sport and recreational purposes. Acc. to the "Schiffssicherheitsverordnung", the term "sport and recreational purposes" comprises the private operation of a craft for water sport activities, for locomotion, for regeneration or pleasure. This includes sport and recreational activities such as sailing, motor boating, angling or diving – if they are not done commercially.

The meaning of "non-material purposes" is not included in the term "sport and recreational purposes" (compare No. 2 above), yet it is not necessary to hold a safety certificate in case of non-commercial operation.

4. Certificates of equivalence no longer necessary

So far, commercially operated sea-going ships under foreign flag (incl. EU flags) operated on German maritime waterways as well as within German coastal waters (12 nm area), and without international certificates acc. to the SOLAS Convention, required a certificate of equivalence by the BG Verkehr. In practice, this was mostly the case for offshore transfer vessels.

This requirement for a certificate of equivalence is lifted as of now, with the changes of the "Schiffssicherheitsverordnung" being in force. In this way, the BMDV deregulates coastal shipping in line with the EU freedom of service and the expansion of offshore wind energy. While, the previous verification of equivalence was not only applicable to ships under EU flag, the legislator found a special monitoring system that only applies to non-EU-flagged ships as too complex.

5. Easier operation of small passenger ships for Tidal Flats navigation and for the Helgoland port ferry

The existing special regulations for ships navigating the Tidal Flats remain applicable but trade restriction for new ships are added. During a violent storm of 12 bf. ships built after 30 November 2024 may not commence a voyage; this is common practice nowadays.

For the port ferry traveling between Helgoland's mainland and the dune a dedicated safety standard has been developed. Moreover, the sea area between Helgoland's mainland and the dune is categorized as port area and the navigational chart changed accordingly.

6. Restrictions for magnetic compass adjusters abolished

So far, the adjustment of magnetic compasses on German-flagged ships was limited to people who had been approved by either BSH or an IMO member state. This requirement has now been canceled with the amendment of the "Schiffssicherheitsverordnung". This brings the German regulation on a par with international procedures. Another aspect had been that BSH- or IMO-approved adjusters where rarely available abroad.

7. Own survey regime for authority vessels possible

Due to an exceptional rule in the "Schiffssicherheitsverordnung", authorities now have the choice either to apply for safety certificates by the BG Verkehr (as was common practice before) or to monitor the safety of their ships with a survey regime internal to the authority.

8. Extension of transitional due dates for ships of traditional build

With the latest ordinance amendments, the BMDV has extended transitional due dates for the new safety requirements for ships of traditional build introduced in 2018. Operators of ships of traditional build who apply for a renewal up until the end of 2024, receive an extra three years to fulfil the requirements for equipment, operational safety systems and the structural provisions that entered into force in 2018. With this step, the BMDV takes into consideration that ships of traditional build had not been able to be put into service as often during and after the COVID-19 pandemic as well as that the implementation of the new safety standards in the shipyards or with expert input had been impeded.

The detailed changes can been found in the text of the "Ersten Verordnung zur Änderung schiffssicherheitsrechtlicher Vorschriften". On the website gesetze-im-internet.de the "Schiffssicherheitsverordnung" and the "See-Sportbootverordnung" are consolidated with the recent changes that have entered into force.

So far, shipping companies needed an approval by the Generaldirektion Wasserstraßen und Schifffahrt (GDWS) for cabotage voyages of their ships that do not fly an EU flag (Norway excluded). Cabotage means the fee-based carriage of persons or goods with ships under foreign flag from one place to another in coastal waters within German territory (12 nm area).

The requirement for cabotage approvals has been void since the "Bürokratieentlastungsverordnung" has entered into force on 14 December 2024. This legal instrument repeals the previous "Verordnung über die Küstenschifffahrt (KüSchV)" which formed the basis for cabotage approvals.

There are many excellent ways to get support as a seafarer – but you have to know of them. And in times of crisis, you need to have the contact data at hand, low-threshold and on board. For this purpose, the BG Verkehr has compiled concise info material:

• A poster shows you at one glance the most important 24/7 means of contact for both the German Seamen's Mission and ISWAN the "International Seafarers's Welfare and Assistance Network".
  
  The Flyer is available in either German or English, in a handy A4 format and perfect for the notice board.
  
  
• An accompanying flyer expands on the infos of the poster. In addition, it lists the most common symptoms of psychological crises. An these are not just the ones a psychological layperson might think of.
  
  The flyer is bilingual – German and English.

You can already download and print out the poster and flyer. The printed editions are currently being printed and will be available to shipping companies with German-flagged ships.

Please do not hesitate to make use of the support on offer. It is never "too early".

The International Maritime Organization (IMO) has declared climate neutral maritime shipping by 2050 as its goal. With an extensive action plan, the strategy for reducing greenhouse gases is intended to work on all levels and to be feasible for everyone involved. To promote this plan, the IMO, together with the government of the Republic of Korea, has launched the ‘Future Fuels and Technology for Low- and Zero-Carbon Shipping Project (FFT Project)’.

This project supports the work of the Marine Environment Protection Committee (MEPC) of IMO on three levels:

1. technical analysis of developed solutions and implemented measures,
2. pilot projects facilitate cooperation between developed and developing countries and the industry,
3. and now new: the online platform "Future Fuels and Technology" offers an overview of all the different types of fuels – existing and developing infrastructure, availability and usage, prices, existing fleet and construction contracts.

At the very latest since the mandatory international requirements regarding greenhouse gas reduction and energy efficiency of their ships have entered into force, many shipping companies are faced with the question: Which technology and which fuel is the right one? There are many options to choose from and at first glance the costs involved are convoluted and daunting – this is where the IMO's new online platform "Future Fuels and Technology" comes in. It assists a well-founded decision-making process with diagrams and statistics that give an overview of the various options and their pros and cons.

Among other things, the website serves to get an overview which fuel is most commonly used in which type of ship. For example, of the available alternative fuels, LNG is currently utilized on container ships, but building contracts of ships fuelled by methanol indicate that this type of alternative fuel is on the rise in this sector. In contrast – as shown by the overview – batteries are often used in ferries, ro-ro passenger ships and ships deployed close to the coast, and have taken root in these sectors.

Moreover, the online portal presents the stages of development of the different fuels and offers links to leading research projects offering more specialized information on the individual topics, which facilitates a comprehensive and in-depth insight.

However, the choice of the most suitable fuel strongly depends on the availability in the trading area as well. For current and future planning, the website does not only shed light on existing capacities, but also on infrastructure projects that are being developed.

The predicted price development of alternative fuels is particularly interesting. At this point in time, heavy fuel oil in combination with a scrubber is the most cost-effective solution. Most alternative fuels have to be stored on board and burned in larger quantities to achieve the same performance as carbon-based fuels. This requires space and currently costs significantly more. The introduction of a carbon price might even out the price-performance ratio, which would make alternative fuels a real alternative. Such at least is the prognosis displayed in the diagrams published on the website.

There is much to think about and many things to consider when investing in the future. IMO's platform "Future Fuels and Technology" may assist in the decision-making process.

Please note Marine Notice 2024/03 by the Australian Maritime Safety Authority AMSA, which focuses on testing and inspection of 15 ppm bilge separators during port state control inspections in Australia. An oily water separator that does not function properly or is damaged constitutes a detainable deficiency.

We would like to draw your attention to our new ISM Circular 01/2024. It contains a "Lessons Learned" by the Federal Bureau of Maritime Casualty Investigation (BSU), which points out a safety risk of launching devices for life-saving appliances that bears significance beyond the individual case.

Therefore, the circular and the attached "Lessons Learned" are of interest for shipowners and operators, classification societies, masters and crews, manufacturers of launching appliances as well as service companies tasked with the manufacture and maintenance of launching appliances and their fittings.

Please take note of ISM Circular 01/2024 and the attached "Lessons Learned" and check if these risks pertain to you or if there are any interfaces to this safety risk in your work activities.

The Marine Environment Protection Committee (MEPC) of the Internationale Maritime Organization IMO recently approved "Interim guidance on the use of biofuels under regulations 26, 27 and 28 of MARPOL Annex VI" (MEPC.1/Circ.905). This Interim Guidance assists with the calculation for DSC reporting and the Carbon Intensity Indicator (CII) in cases where biofuels are used on board seagoing vessels.

The Interim Guidance enters into force on 1^st October 2023. It applies until more comprehensive guidelines for well-to-wake GHG emissions have been developed and entered into force.

The Circular MEPC.1/Circ.905applies immediately for seagoing ships flying the German Flag and can already be applied for the 2023 monitoring period.

Further questions can be directed to the Ship Safety Division in Hamburg via phone +49 40 36 137 217 or e-mail to maschine@bg-verkehr.de.