The move towards a paperless world has faced many hurdles over the past few years, and Gard has now warned of another, noting that ships were continuing to experience instances of port state control (PSC) interventions, and sometimes hefty fines, allegedly because the validity of the vessels’ electronic statutory and class certificates could not be verified during onboard inspections.
Gard noted that the practice of issuing signed paper certificates to document compliance with maritime rules and regulations might be nearing its end. “Recognizing that paper certificates are subject to loss or damage and can be impractical to send to globally-trading ships, most major flag administrations and classification societies now facilitate the use of electronic certificates”, said Gard.
The process has also been formalized through several IMO documents. One of these, the harmonized “Procedures for port state control”, requests port state control officers (PSCOs) to note that, where the ship relies upon electronic certificates:
- the certificates and website used to access them should conform with the Guidelines for the use of electronic certificates (FAL.5/Circ.39/Rev.2 and Corr.1);
- specific verification instructions are to be available on the ship; and
- viewing such certificates on a computer is considered as meeting the requirement that certificates be “on board”.
However, Gard has observed that “from time to time” its Members had experienced instances of port state control (PSC) interventions where the validity of electronic certificates, as well as other official documents, were questioned by the attending PSCO.
During November and December 2021 four ships covered by Gard were penalized during port calls in Gabon because the attending PSCOs claimed they were not able to verify the authenticity of the ships’ certificates. The accompanying inspection reports stated that some of the certificates requested contained neither a QR code nor a Unique Tracking Number (UTN) to facilitate the onboard verification process.
Gard said that, while Gabon was known for its strict PSC inspection regime, the insurer would take this opportunity to remind all ship operators and masters to always carry valid, nonexpired, ship certificates and permissions onboard. Although this could be in hard copy or an electronic version, when relying on electronic certificates and documents, it was important to ensure that the crew was familiar with a reliable method to verify their validity and authenticity.
Most flag administrations and classification societies provided two ways of verifying electronic documents and certificates.
Commonly a verification portal URL is provided, and the certificate can be verified by entering the certificate’s UTN, normally in combination with the ship’s IMO number or document issued date.
A QR code on each certificate will have a URL unique to the certificate comprising the parameters required for the verification portal to return the search result. This also eliminates the potential for any typing errors in entering data manually on the verification portal webpage.
Gard said that the use of electronic certificates and documents must also be controlled through the ship’s safety management system. The onboard procedures for verifying electronic certificates should be kept up to date at all times and be aligned with the latest instructions and user manuals published by the ship’s flag administration and classification society. Consideration should be given to the need for separate instructions addressing how offline verification can be done in case of loss of connectivity
However, Gard noted that, despite efforts by the IMO, flag states, classification societies, and other official entities, to facilitate the use of electronic certificates and documents in the maritime industry, theory and practice occasionally diverged.
In some of the cases experienced by its Members, a paper copy printed out from an email sent by the local agent was all that existed onboard. Even if the crew did everything in their power to prove the document’s legitimacy, it was still not accepted by the attending inspector.
There had also been reports of attending PSCOs not carrying smartphones, which made impossible the checking of the validity of online documents. Sometimes it was said that the PCSO’s did not wish to use their own internet credit for the purpose.
Gard noted finally that, for ship operators and masters trading to ports in Gabon, it was worth noting that all ships were subject to PSC inspection and that the Gabonese authorities operated with a long list of “frequent deficiencies” which vessels should take care to try to rectify beforehand, or otherwise risk being fined. Gabonese correspondent Eltvedt & O’Sullivan’s confirmed that, at the time of writing, there had been no regulatory changes since 2019 and little change in local authorities’ official position on the grounds for penalties.
“However, recent experience suggests that the authorities nevertheless, in practice, may be prepared to accept electronic versions of documents – but only when said documents contain a QR code, bar code, or UTR that allows the attending inspector to check their validity and authenticity on a website”, Gard concluded