Government Update: Continuous Synopsis Record

Tuesday, February 10, 2004

One of the numerous provisions in the December 2002 amendments to the International Convention on the Safety of Life at Sea (SOLAS Convention) requires ships subject to the Convention to maintain a continuous synopsis record as of July 1, 2004. All is not going smoothly though. Owners and operators should prepare to take individual action prior to the deadline.

The continuous synopsis record is intended to provide an on-board record of the history of the ship. The record is to be issued by the flag administration and is to contain:

a. The name of the nation whose flag the ship is entitled to fly;

b. The date on which the ship was registered with that nation;

c. The ship's identification number;

d. The name of the ship;

e. The port at which the ship is registered;

f. The name(s) of the registered owner(s) and their address(es);

g. The name(s) of the registered bareboat charterer(s) and their address(es), if applicable;

h. The name of the company for purposes of the International Safety Management (ISM) Code, along with its address and the address from which it carries out its safety-management activities;

i. The name of all classification societies with which the ship is classed;

j. The name of the administration, contracting government, or recognized organization that issued, under the ISM Code, the Document of Compliance to the company operating the ship and the name of the body that conducted the audit on which the Document was based;

k. The name of the administration, contracting government, or recognized organization that issued, under the ISM Code, the Safety Management Certificate to the ship and the name of the body that conducted the audit on which the Certificate was based;

l. The name of the administration, contracting government, or recognized security organization that issued, under the International Ship and Port Facility Security (ISPS) Code, the International Ship Security Certificate (ISSC) to the ship and the name of the body that conducted the verification on which the ISSC was based; and

m. The date on which the ship ceased to be registered with that nation.

Any changes relating to entries in the continuous synopsis record are to be made by the flag administration within three months and provided to the ship so that the information remains current. In the interim, until the revisions issued by the flag administration have been received, the company or the master may be authorized and required to amend the continuous synopsis record to reflect the changes. In such cases, the company is to, without delay, inform the flag administration of the amendments.

The continuous synopsis record is to be in English, French, or Spanish, as well as the official language of the flag administration. The record is to be maintained in the format developed by the IMO and maintained in accordance with IMO guidelines. Entries may not be deleted, modified, erased, or defaced. The record is to remain on board the ship when it is transferred to another flag, sold to a new owner (or taken over by a new bareboat charterer), or when another company assumes responsibility for operation of the ship.

When the ship is to be transferred to the flag of another nation, the company is to notify the current flag administration so that it can forward to the new flag administration a copy of the current continuous synopsis record. The new flag administration is to append the old continuous synopsis record to the new one that it issues to the ship.

The continuous synopsis record is to be kept on board the ship and made available for inspection by government officials at all times.

Like the ISPS Code and related maritime security measures, this requirement is a large undertaking and little time is afforded for its implementation. The IMO has yet to officially issue a format in which the record is to be developed, nor has it issued guidelines explaining how the record is to be maintained. Few, if any, flag administrations have yet issued their own guidance, although the Netherlands has developed an application form. Otherwise, flag administrations have not established procedures for collection of information required to be in the continuous synopsis record that is not already routinely collected and maintained.

The U.S. Coast Guard has stated that it will comply with the IMO format once it has been adopted. The agency intends to issue a continuous synopsis record before July 2004. The currency of the information will be based primarily on the information provided by the owner or operator. The Coast Guard goes on to state that sanctions can be imposed for any inaccurate information provided by the owner or operator. In other words, the various flag administrations are waiting for the IMO to act — and the IMO has its hands full handling a multitude of maritime security issues as well as responding to demands of various member nations for accelerated phase-out of single hull tankers and its other marine safety work.

Meanwhile, the U.S. Coast Guard has issued guidance to its field offices telling boarding officers, as of July 1, 2004, to review the continuous synopsis records and compare the information with that supplied in the advance notice of arrival. The information is also to be compared with that found on other documents, such as the Passenger Ship Safety Certificate, the Cargo Ship Safety Construction Certificate, and the International Oil Pollution Prevention Certificate (IOPPC).

If the ship arrives off a U.S. port on or after July 1, 2004 without a continuous synopsis record or with one that is clearly inadequate, one should expect the U.S. Coast Guard to deny entry. If the deficiency is not discovered before the ship arrives in port, one should expect to Coast Guard to expel the ship until the record is provided or, at a minimum, isolate the ship and prevent all cargo and passenger operations until the record is provided.

This puts the ship owner and operator in a difficult position. The ship needs a continuous synopsis record in order to operate, but it can only obtain an official continuous synopsis record from the flag administration, which is waiting for further guidance from the IMO.

Rather than continuing to engage in a useless finger-pointing exercise, it is strongly recommended that ship owners and operators develop their own continuous synopsis record for each of their ships. This will serve two important purposes. First, it will consolidate in one location all the information that flag administrations will eventually demand of owners and operators (probably on short notice). Second, it will be available on the ship during the inevitable period between July 1, 2004 and whatever date the official continuous synopsis record is actually received from the flag administration.

The concept behind the continuous synopsis record originated with concerns about substandard shipping and efforts to improve transparency. Following the 2001 terrorist attacks, its value as a security measure was recognized.

The concept of the continuous synopsis record is sound. It includes relevant information that should be consolidated in one location and that should also be available to the flag administration and port state control officials. The execution of the requirement has, to date, been lacking.

The IMO set for itself and for flag administrations a highly ambitious deadline that now looks impossible. Owners and operators should be prepared for some bumps in the road as this measure comes into effect.

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