Wednesday 15 September 2010

Argentina : new customs regulation

The following brief post aims to inform that, as per new customs regulation valid in Argentina since 15th of August, all Bills of Lading have to appear with TAX ID and NCM in each Bill of Lading, where NCM is a harmonized tariff schedule related to international commerce within Mercosur. All importers have to present one original Bill of Lading together with the import license prior to vessel's arrival to ports of Argentina with both pieces of information added in the original B/L. If Bills of Lading have been issued without same, the solution could be to change the Bills of Lading: the old Bills of Lading can be put NULL AND VOID, and the new Bills of Lading can be prepared for signing and releasing.

Tuesday 7 September 2010

Best Management Practices in deterring piracy

In the post of today, we would like to discuss the Best Management Practicies (BMPs) in deterring and combating piracy including but not limited to the coast of Somalia and the Arabian Sea area. We will focus on the self-potection measures that might be within the capability of the vessel and the ship crew using equipment that is readily available. Shipowners and/or operators who frequently transit the High Risk Area are welcome to discuss alterations to the vessels beyond the scope of the "readily" available equipment in order to further reduce the risk of piracy attacks.


Prior to commencement of transit of the High risk area, it is essential to ensure enhanced watchkeeping and vigilance, therefore, binoculars for the enhanced bridge team should be available in sufficient quantity. It may be even worthwhile to consider night vision optics, if available. Also, well designed dummies placed alongside the vessel at strategic positions can give an impression of greater number of people on watch.

If the pirates are firing weaponry at the vessel, it is difficult and dangerous to monitor whether the pirates have boarded the vessel or not. The use of closed circuit television (CCTV) allows a better degree of monitoring the attack from a less vulnerable position. Install the CCTV cameras ensures coverage of the vulnerable areas such as the poop deck. Furthermore, the recorded CCTV footage provides useful evidence after an attack... .

Thursday 2 September 2010

Vetting Salvage and Marine Firefighting and Lightering (SMFF) provider ...

This post aims to inform the reader about the process of vetting the Salvage and Marine Firefighting and Lightering (SMFF) providers and also to discuss the requirements which become effective on the 22nd of February, 2011. Shipowners, operators and/or managers, later referred to as Planholders, must perform SMFF audits in selecting SMFF provider, which has to follow at least 15 “adequacy” criteria as follows:

1/ the candidate for SMFF provider actually works in subject response; 2/ history in operations; 3/ SMFF owns or has contract for necessary equipment; 4/ trained personnel with experience; 5/ 24(7) availability and history of meeting response times; 6/ Ongoing training; 7/ Proof of successful participation in drills and exercises; 8/ Proof of approved SMFF plans from real accidents; 9/ Participation in National and/or International organizations; 10/ Insurance cover for work to perform; 11/ sufficient “up front” capital to support an operation; 12/ sufficient equipment in all regions where the coverage is provided; 13/ Logistical and Transport support to sustain ongoing operations; 14/ Safety support of safeguard health; 15/ Familiarity with SMFF protocols outlined in ACPs for regions they provide coverage; 16/ … ??? .

As per position of Coast Guard, the planholder is responsible for vetting all possible SMFF providers to determine the adequacy of each company and decide which best suits the needs and meets the minimum of SMFF criteria. Meanwhile, the Coast Guard reserves the right to request a proof from the Planholder, as to how the decision was made in selecting an SMFF provider.

In performing the vetting, each provider must prove compliance with each of the 15 criteria; if they have any gaps in coverage, this will require obtaining a waiver from the Coast Guard. Review of copy of their new SMFF contract and the funding agreement is a good idea. The funding agreement must be USCG and P&I club approved. You should also inquire about pricing.

Please note, the SMFF provider may request to review the SOLAS pre-fire plan (FP), along with Supporting documents Part II-2 Reg. 15. Once the FP is acceptable for the SMFF provider, it may also be integrated in the Vessel’s Response Plan (VRP)….