Safe manning certificate also required for small ships
On 23 July 2021, the Federal Ministry for Traffic changed the German Safe Manning Ordinance; this amendment was published in 2021 in the "Bundesgesetzblatt" (Federal Gazette) Part I on page 1849. Since then, small ships and boats of 8 m and less in length require a safe manning certificate. This mostly concerns water taxis, small surveying boats and commercially used recreational craft. Upon application, the Ship Safety Division of BG Verkehr issues safe manning certificates electronically.
However, open or partly decked fishing vessels in restricted passive coastal fishing (mainly set net fishing) do not require a safe manning certificate. This is stipulated in sec. 8 para. 1 sent. 3 and 9b of the German Safe Manning Ordinance. For these small fishing vessels, the skipper requires a maritime recreational craft driver's licence ("Sportbootführerschein See") as well as a medical fitness certificate for deck service. Recreational craft hired out without skipper or crew ("bareboat") as well as inland recreational craft do not require a safe manning certificate either.
Based on a recommendation by the Federal Bureau of Maritime Casualty Investigation (BSU), the Federal Ministry for Traffic had amended the German Safe Manning Ordinance. The BSU recommended in its Casualty Report 258/51 on the maritime casualty of the surveying boat "Geo Profiler" to make safe manning certificates mandatory for work boats of less than 8m in length as well.
At the same time, the Federal Ministry for Traffic amended the German Seafarers' Competencies and Proficiencies Regulations. The new certificate of competency for master NK 100 for service on ships up to 100 GT was developed with small commercially used ships under German flag in mind. As before, Annex 4 of the German "See-Sportbootverordnung" applies for manning commercially used recreational craft; a certificate of competency NK 100 is not required for these kinds of boats.
The Ship Safety Division of the BG Verkehr is responsible for verifying safe manning. On small ships, this is usually part of the 3-year inspections acc. to the German Maritime Labour Act (unless these are commercially used recreational craft under 24 m in length acc. to Maritime Labour Act sec. 1 para. 1 sent. 2). If the required safe manning certificate is not carried on the ship or the ship is undermanned, it is an administrative offence and may be fined. In addition, the Ship Safety Division of the BG Verkehr may prohibit the ship to leave or proceed its voyage.
The Ship Safety Division of the BG Verkehr provides further information in an information paper (in German only). Please direct your queries regarding the application and issuance of safe manning certificates at the Certificates Pool of the Ship Safety Division of the BG Verkehr: e-mail: certificates@bg-verkehr.de, Tel.: +49 40 361 37 229. Information regarding inspections acc. to maritime labour law on ships can be obtained at the ISM/ILO Department of the Ship Safety Division of the BG Verkehr: e-mail: ism-mlc@bg-verkehr.de, Tel.: +49 40 361 37 213.