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The German Flag has stepped up significantly in the ranking of the Flag States in comparison to last year. It is now No. 21 on the White List of the Paris Memorandum of Understanding on Port State Control (Paris MoU), which goes to shows that the German Flag continues to be a flag of high quality.

Deutsche Flagge 400 x 600 Christian BubenzerLast year the German Flag placed 34 in the Flag State Ranking of the Paris Memorandum of Understanding on Port State Control (Paris MoU), now it managed a jump to 21. This is based on the recently published White-Grey-Black List of the Paris MoU, which is valid from 1st July.

The reason for the improvement of the German Flag in the ranking is less detentions of German-flagged ships at port state control inspections throughout the last year. This puts the German Flag in this year's ranking ahead of the flags that are most chosen by German shipowners: Portugal (this year: 22, last year: 26), Liberia (this year: 30, last year: 25) and Antigua/Barbuda (this year: 35, last year: 31).

As in the previous year, Denmark came first in the Paris MoU ranking. The Netherlands came second (last year: 4) and Norway third (last year: 5). The world's largest flag, Panama, is on place 55 (last year: 46) and therefore in the Grey List of the Paris MoU. Just like the previous year, of all the flag states covered Cameroon comes last in the ranking on place 71.

The White-Grey-Black List of Paris MoU is based on the total number of inspections and detentions of flags with at least 30 inspections during a three-year period. The ranking is published every year and among other things, it determines how often ships will get inspected in port state controls.

With its latest service offer "Checks on Board", the German Flag supports shipping companies in preparing their ships for port state control inspections abroad. The goal is a better performance during unannounced surveys by offering these checklists that are in step with actual practice.

Checks on Board aufgefächert 600x400The Ship Safety Division of the BG Verkehr offers shipping companies with German-flagged sea-going ships a practical preparation for PSC inspections abroad with its new service "Checks on Board". These checklists are aimed at improving the performance of individual ships and their respective company-fleet as well as preventing the detection of deficiencies during PSC inspections.

"Checks on Board" is a new service of the German Flag and comes without any obligations; the internal results of the checklists remain with the shipping company. The checklists are meant for both the management on board as well as onshore company-inspectors since ship-side and land-side operations should be closely integrated with each other according to the core idea of the ISM Code.

The different editions of "Checks on Board" are always structured in the same way: The first part contains a checklist about the respective topic, the second part contains explanations and legal bases. In terms of content, the "Checks on Board" cover every part of a ship's operations from ship safety over marine environment protection to working and living conditions of seafarers.

Currently the following editions of "Checks on Board" are available at https://www.deutsche-flagge.de/en/german-flag/support-for-shipowners:

More "Checks on Board" will follow.

Information for ships calling at Australian ports

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.

Safety risk of launching appliances

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.

MARPOL Regulation V/10.3 applies as of May 2024 for ships from 100 GT

Ships of a certain size navigating within the jurisdiction of MARPOL parties have to maintain a garbage record book. So far this obligation began from 400 GT. This is about to change: As of 1st May 2024, the garbage record book is mandatory from a ship size of 100 GT.

According to MARPOL Regulation V/10.3, the garbage record book is still mandatory for all ships on international voyages approved for 15 or more persons (passengers and crew) irrespective of their ship size. And it is also mandatory for fixed or floating platforms (FFPOs).

Information on the contents required in the garbage record book can be found in ISM Circular 02/2018 – "New Form of garbage record books from 01 March 2018".

Garbage record books as paper hard copies are available in all known shops selling ship's logbooks and record books. Here on the website, you can also find a list of approved electronic (garbage) record books approved by the German Flag.

As of now, shipping companies can calculate what the fees are to enter a sea-going ship into a German shipping register with our new tool Fees Calculator Ship Registration. Meanwhile, the trend towards a centralized German shipping register continues. The Federal State Rheinland-Pfalz has transferred their two shipping registers to Hamburg by interstate agreement.

Faehre_Kirk Williams.jpgSea-going ships from a hull length of 15 m and more belonging to German owners have to be entered in a German shipping register for sea-going ships – irrespective of the flag the ships are flying. This is regulated under §1 of the German “Flaggenrechtsgesetz” (flag act) in conjunction with §10 para. 1 of the "Schiffsregisterordnung" (shipping register ordinance).

The charged fees for the registration in a German shipping register for sea-going ships depend on the value of the ship. In most cases, the value of the ship is given in the sales contract.

With our new Fees Calculator Ship Registration, ship operators can now calculate how high the fees for initial registration would be. Simply enter the value of the sea-going ship into the dedicated field and click once – just like that, the registration fee is displayed.

Scheibenwischer_Christian Bubenzer.jpgUsually, there are no fees when changing to the German Flag, because ship's of German owners that had previously been flying a foreign flag and were therefore flagged-out are already registered in a German shipping register for sea-going ships. For fees regarding changing to the German Flag and newbuildings under German Flag, please use our separate Fees Calculator German Flag.

In the meantime, the centralization trend of the previously 17 German shipping registers for sea-going ships is continuing. In 2021, the Federal States Berlin and Brandenburg transferred their shipping registers to the shipping register of Hamburg by interstate agreement. This was followed by Bavaria, Baden-Württemberg and parts of Hessen in 2023. As of 1st February Rheinland-Pfalz has transferred about 200 sea-going and 650 inland ships of the shipping registers Mainz and St. Goar to Hamburg. The shipping register of Hamburg with over 8,000 sea-going and inland ships has been working digitally since 2020.

Guideline electro-technical rating aspirants

On 15th February 2024, the new guideline for approved practical training and sea-going service for electro-technical rating aspirants (ESA) entered into force. According to the guideline, sea-going service as ESA has to be served in compliance with it and recognized as practical time at sea.

In Article III the ESA guideline requires  that every ESA has to maintain a traning record book. This record book is published by the Federal Maritime and Hydrographic Agency (BSH) and is available commercially with the ISBN: 978-3-96490-214-6.

Read more on training record books.

It is not yet possible to receive Maritime Safety Information (MSI) via the recognized mobile satellite service Iridium, which has been recognized by IMO since 2018. Therefore, the German Flag recommends not to rely exclusively on Iridium systems in Sea Area A3. However, distress calls can be made globally via Iridium without any problems.

For more safety at sea, the ship commands of sea-going ships covered by the SOLAS Convention are obliged to be able to transmit and receive distress calls as well as Maritime Safety Information (MSI) in the sea areas they are navigating at any time. MSI – i.e. navigational, meteorological and other safety-related information – is part of the Global Maritime Distress and Safety System (GMDSS), which has its basis in the SOLAS Convention.

In the Iridium GMDSS service of the US provider Iridium Satellite LLC, which has been recognized by IMO since 2018, distress calls can be transmitted and received globally without any limitations. However, reception of MSI via the Enhanced Group Call (EGC) of the Iridium SafetyCast Service is not yet completely possible in all sea areas. In some NAVAREASs and METAREAs (= established area for broadcasting navigational and meteorological information and warnings) Iridium is not yet operational or is in trial operation. The current status can be found on the website of the International Hydrographic Organization.

Due to the current network covering issues, shipping companies should not rely solely on Iridium systems at present. Therefore, the German Flag recommends to shipping companies with sea-going vessels navigating sea area A3 to still provide an Inmarsat EGC system (Ship Earth Station, SES) – for example as backup arrangements. Only this way can the reception of MSI via the mandatory Enhanced Group Call (EGC) be guaranteed at any time.

Interim Guidance for the use of biofuels

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 1st 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.

For a long time, asbestos was considered a miracle product: the natural mineral is fire resistant, an insulator, easy to process and inexpensive. But asbestos causes illness and can give rise to cancer. BG Verkehr summarized the things shipping companies have to observe when they flag-in a ship that is contaminated with asbestos.

Those who worked with asbestos in the past often used to breath in the dust and thereby the fine asbestos fibres. A possible result: malignant cancer tumours or changes in the lining of the lung. The employer's liability insurance associations recognize asbestos as a cause of a lung disease known as asbestosis, and as an occupational disease. Asbestosis is the most common cause of death among the terminal occupational diseases. There can be several decades between working with asbestos and the onset of the disease. On average the latency period is 38 years.

Since 1993, asbestos may not be produced or used in Germany, and on a European level since 2005. From 2019 all ships under EU flag from 500 GT must have an inventory of hazardous materials, which must also include asbestos. With the Regulation EU/1257/2013 the EU legally implements the provisions of the Ship Recycling Convention (“Hong Kong Convention”).

Globally, however, there is no ban on asbestos. So, there may still be asbestos present on older ships. If such a ship flags-in under the German flag, the shipowner will have to conduct a risk assessment, compile an asbestos cadaster and arrange mandatory medical check-ups for the seafarers. The prevention division at BG Verkehr has developed a compilation of the shipowner’s obligations when operating an asbestos-contaminated ship.

In addition to this compilation, ship operators have to comply with the provisions of the international SOLAS Convention regarding the ban of asbestos on sea-going vessels. The Circular by the Maritime Safety Committee of the IMO MSC.1/Circ.1374 "Information on prohibiting the use of asbestos on board ships" provides more detailed requirements and information on the topic asbestos on sea-going vessels:

  1. On ships built before 1 July 2002, asbestos containing materials (ACMs) may be installed and approved as long as they do not pose a risk to the crew's health.
  2. On ships built on or after 1 July 2002 and before 1 January 2011, new installation of ACMs has been allowed only in exceptional cases.
  3. On ships built on or after 1 January 2011, ACMs have not been allowed to be installed (refer to SOLAS Chapter II-1/3-5).

The Circular was published in the German "Verkehrsblatt" (transport gazette) 19/2013 on 23 September 2013 in the German language and is mandatory for ships flying the German flag.

Specialists discover asbestos on some sea-going vessels during inspections at a later point in time – for example while compiling an Inventory of Hazardous Materials (IHM) in accordance with EU Regulation 1257/2013 and the Hong Kong Convention on the Recycling of Ships. In these cases, a transitional period of three years applies to carry out an asbestos abatement on board or an exchange of all of the ACMs (refer to Circular MSC.1/Circ.1374). This transitional period of not more than three years cannot be extent, not even if:

  1. during this time period the ship was temporarily flying a different flag or
  2. asbestos had already been identified three years prior on a ship that was flying a foreign flag and is now about to change to the German flag.

For questions regarding these requirements, the experts of the Machine Department of the Ship Safety Division of BG Verkehr are gladly of assistance (e-mail maschine@bg-verkehr.de or contact qualified engineer Holger Steinbock via phone: +49 40 361 37-217).

The German flag is always available for you - on 365 days of the year. You can reach our specialists under the phone number +49 3190-7777 for all questions about maritime shipping under German flag

The maritime 24/7 hotline is offered by the Federal Maritime and Hydrographic Agency, BSH. In addition, the stand-by service of the Ship Safety Division of BG Verkehr is also available. More information is given under "Contact Details".

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