Bermuda (UK) - Specific requirements by the Bermuda Administration
Flag instructions relating to statutory surveys
National Authorities
Refer to the contact details for the Bermuda Shipping and Maritime Authority (BSMA) in the attached file BSN 2026-001 dated March 2026.
Flag procedural requirements
| Standing requirements | Action by |
|---|---|
| 1- Reporting on entry into class | MOC |
| 2- Reporting on requests for exemptions or interpretations | MOC |
| 3- Reporting on cases of major deficiencies, as per IACS Recommendation 98 (Duties of surveyors under statutory conventions and codes) and Addendum A to Appendix 2 (attached file) | MOC |
| 4- Pre-authorisation prior to extending statutory certificates | MOC |
| 5- Pre-authorisation prior to issuing conditional certificates | MOC |
| 6- Reporting on detentions | DO-FM |
| 7- Submission of copies of statutory certificates | DO-FM |
| 8- Reporting on class suspension or class modification | MOC |
| 9- Reporting on class withdrawal | DO-FM |
General policy
Contact
Recognised Organisation (RO) London is the contact point between Recognised Organisation (RO) and the Bermuda Registry of Shipping.
Agreement
An agreement has been signed between Recognised Organisation (RO) SA and the Bermuda Shipping and Maritime Authority on 01/03/2021 (refer to Agreement governing the delegation of statutory certification services to Annex 4 to the Agreement).
Authorisations for services outside the scope of Appendix 1 to this Agreement (see Annex 1 to the Agreement) will be dealt with as mutually agreed on a case-by-case basis (as per paragraph 4.2 of the Agreement, refer to Agreement governing the delegation of statutory certification services).
Interpretations
(Paragraph 5.2 of the Agreement, refer to Agreement governing the delegation of statutory certification services)
While interpretations of the applicable instruments, as well as the determination of equivalents or the acceptance of substitutes to the requirements of the applicable instruments are the prerogative of the Administration, Recognised Organisation (RO) will co-operate in their establishment as necessary.
Recognised Organisation (RO) applies the IMO interpretations and Circulars, as well as the available IACS Unified Interpretations as stated below unless they conflict with written instructions/guidance from the Administration.
For acceptance of IACS Unified Interpretations (“UIs”) the following conditions apply:
IACS UIs that have been adopted by the IMO shall be applied with respect to statutory certification and services provided by Recognised Organisation (RO) on behalf of the Administration.
IACS UIs that have been submitted to, but which are still under review of, the IMO or have yet to be submitted, shall be subject to review on a case by case basis.
Deviations and Equivalent solutions
(Paragraph 5.3 of the Agreement, refer to Agreement governing the delegation of statutory certification services)
Exemptions and deviations from, and equivalents to, the requirements of the applicable instruments are the prerogative of the Administration and only the Bermuda Shipping and Maritime Authority may approve them prior to issuance. Recognised Organisation (RO) will co-operate in their establishment as necessary.
In instances where, temporarily, the requirements of an applicable instrument cannot be met under particular circumstances, Recognised Organisation (RO) will specify such measures or supplementary equipment as may be available to permit the vessel to proceed to a suitable port where permanent repairs or rectifications can be effected or replacement equipment fitted, and shall immediately inform the Bermuda Shipping and Maritime Authority in writing of any such action taken.
Reporting
(Appendix 2 of the Agreement, refer to Annex 2 to the Agreement)
Recognised Organisation (RO) should inform the Bermuda Shipping and Maritime Authority in where special circumstances are thought appropriate for:
the issue of a certificate which has a validity exceeding five (5) years from the date of expiry of the previous full term certificate in accordance with applicable instruments,
the extension of certificates in accordance with Survey and Certification Regulations,
where the issue of an exemption certificate by the Bermuda Shipping and Maritime Authority is considered necessary.
Withdrawal / Cancellation of Statutory Certificates
(Paragraph 5.4 of the Agreement, refer to Agreement governing the delegation of statutory certification services)
(Paragraph 4.6 of Appendix 2 of the Agreement, refer to Annex 2 to the Agreement)
The Administration reserves the right to suspend, cancel or revoke any certificate, document or approval issued by Recognised Organisation (RO) pursuant to the agreement. In case of a cancellation or revocation the Administration will inform Recognised Organisation (RO) in good time, stating the reasons for this action.
Statutory certification issued by Recognised Organisation (RO) under the authority of Bermuda shall not be withdrawn, by Recognised Organisation (RO), without informing the Bermuda Shipping and Maritime Authority in good time stating the reasons for this action.
In the circumstances when a ship is found to be in operation with deficiencies or discrepancies such that the condition of the ship or its equipment does not correspond substantially with the particulars of its certificates or the requirements of applicable International Conventions and/or national requirements, if corrective action is not taken to the satisfaction of Recognised Organisation (RO), then Recognised Organisation (RO) shall immediately consult the Bermuda Shipping and Maritime Authority and, if given approval, withdraw the relevant certificate(s).
The Bermuda Shipping and Maritime Authority will provide written authorisation to withdraw the certificate(s). The right to withdraw certificates may not always exist and where cancellation is the only possible action the Bermuda Shipping and Maritime Authority retains responsibility for such cancellations.
Transfer of Class
(Paragraph 7.5 of the Agreement, refer to Agreement governing the delegation of statutory certification services)
(Paragraph 2.4 of Appendix 2 of the Agreement, refer to Annex 2 to the Agreement)
In cases of transfer of the certification of the ship from one RO to another, the gaining organisation shall, within one month from the issuance of the certificates. advise the Bermuda Shipping and Maritime Authority and the losing organisation of the date of issue of the certificates and confirm the date, place and action taken to satisfy each overdue survey, overdue recommendation and overdue condition of class.
In the event that a ship registered in Bermuda transfers class from another Recognised Organisation to Recognised Organisation (RO), Recognised Organisation (RO) shall ensure that it has obtained all, to its knowledge, relevant information on the survey status of the ship, including structural and operational limitations and any outstanding conditions given by the previous Recognised Organisation. The structural and operational limitations of the ship shall be checked and agreed to by Recognised Organisation (RO).If the ship is not classed on transfer, the requirements of IACS procedural requirements for transfer of Class shall apply.Outstanding conditions shall be reassessed and if considered acceptable by Recognised Organisation (RO) followed up within the time limits given by the losing Recognised Organisation.The above procedures shall be carried through before assignment of class to a ship, or before an unclassed ship is registered by Recognised Organisation (RO). This information shall also be copied to the Bermuda Shipping and Maritime Authority on request.
For Bermuda registered vessels transferring class from Recognised Organisation (RO), but remaining registered in Bermuda, Recognised Organisation (RO) will provide the same information to the gaining Recognised Organisation upon request.
Recognised Organisation (RO) shall not issue statutory certificates to a ship de-classed or changing class for safety reasons before consulting with the Bermuda Shipping and Maritime Authority to determine whether a full inspection is required.
Statutory certificates - Endorsement
Bermuda is one of the Red Ensign registries of the United Kingdom.
As such, the statutory certificates issued since 1 January 2010 to ships registered in the Bermuda are endorsed with the following mention: “This Certificate is issued on behalf of the Bermuda under the responsibility of the United Kingdom as Flag state under the Convention.”
The mention is automatically printed onto the certificates by ASMS Certificates Editor. The surveyor nevertheless verifies that the mention is duly endorsed when issuing a certificate.
Conditions of Class relating to statutory items
(Letter from MCA MS16/62/2 dated 4th November 2011 and email dated 10th February 2012)
The use of Condition of Class (CoC) to manage the rectification of minor deficiencies relating to classification items, e.g. hull structure, machinery and electrical/control systems, is acceptable to Bermuda. It is not necessary to issue short term Safety Construction and / or Load Line certificates in such cases.
However, the use of a CoC to manage the rectification of deficiencies (or multiple deficiencies) relating to non-classification items, e.g. safety equipment, safety radio, etc. which in the opinion of the RO surveyor may affect the validity of the relevant certificate, is not acceptable to Bermuda as the only course of action to take. Such deficiencies (or multiple deficiencies) are to be reported to Bermuda which will advise how the deficiencies are to be dealt with, e.g. by the issue of a short term certificate.
Closure of simple Conditions of Class/Statutory Recommendation
(RO BCC meeting - 20 November 2019)
The Administration has no objection to Recognised Organisation (RO) undertaking closure of simple Conditions of Class/Statutory Recommendation, or outstanding survey items for which no more than documentary evidence is required, by remote inspection/verification provided Recognised Organisation (RO) follows procedure in the planned inspection programme Section 13.
It should be noted that Recognised Organisation (RO) remote acceptance of evidence provided by a ship’s manager or owner does not obviate its accountability with respect to verification of Convention compliance.
Electronic Certificates
Certificates may be issued in an electronic format according to FAL.5/Circ.39/Rev.2.
For further information, refer to the attached files “Electronic Certification Authority Recognised Organisation (RO)” and Shipping Notice 2021-033 for periodic endorsements of surveys undertaken by Recognised Organisation (RO) and certificates issued by the Administration.
Instruction on Arrangements “To the Satisfaction of the Administration”
For guidance or instruction on arrangements identified in the IMO Conventions (SOLAS, MARPOL, Load Line and COLREGs) which are not explicitly prescribed, but are to be “to the satisfaction of the Administration”, refer to Shipping Notice 2021-032 in attached files.
Port State Control follow up
Recognised Organisation (RO) may be requested to assist in follow up of a PSC defect. In the event of a detention, the Administration procedures require an additional ISM audit to be conducted directly by the Administration within 3 months.
Sister ships
The term should only include a vessel in the same series (i.e. vessels built under the same contract between the ship owner and builder) constructed to the same approved plans, in the same yard(s) as the lead ship, either concurrently or consecutively. The yard(s) should have a certified quality management system scoped to cover the entire ship building activity.
Where a sister ship is constructed (keel laid) more than 6 months after completion (date of delivery) of her preceding ship in the series, the RO should carry out additional tests as for the lead ship unless specially agreed otherwise by the Administration.
Remote surveys
The approach towards Remote Surveys is as follows:
Annual/Intermediate/Renewal Surveys will not be considered.
Remote Surveys for the reporting of defects whilst the vessel is at sea will be considered on a case by case basis.
Remote Surveys for the reporting of defects whilst the vessel is in port will be considered on a case by case basis, provided that there are extenuating circumstances preventing physical attendance.
Remote surveys for the closure of findings will be considered, on a case by case basis, provided the remote evidence provided is agreed by the surveyor who attended the physical survey that identified the defect.
Technical requirements
Merchant Shipping Notices and Guidance
Refer to Administration website: www.bsma.bm
Shipping Notices: https://bsma.bm/merchant-shipping-notices/
Guidance Notices: https://bsma.bm/merchant-shipping-notices/merchant-shipping-guidance-notices/
Information Notices:
https://bsma.bm/merchant-shipping-notices/bermuda-merchant-shipping-information-notices/
Bermuda Legislation allows for the application of Bermuda Merchant Shipping Notices as primary guidance. UK MCA issued Merchant Shipping Notices may be applied where no Bermuda Guidance exists.
LL 66
Multiple Load Line Certificates
The Administration approves the issuance of multiple Load Line Certificates to certain vessels on a case-by-case basis. The following guidance in the issue of such certificates should be followed:
All changes in the load line marks or trade involving a change in the certificates are to be conducted under the surveillance of a Recognised Organisation (RO) surveyor.
If a Recognised Organisation (RO) surveyor is not available, the change may be conducted by the Master. At the first convenient port, where a Recognised Organisation (RO) surveyor is available, the Master is to request the surveyor to verify the marks, the vessel's condition and the certificates in use.
The Master is responsible to see that the logbook entries are made when changes are made.
All Load Line certificates are to be issued/endorsed, so that all show as valid in the vessel status
SOLAS 74
Cargo Ship Safety Construction Certificate
Initial testing of watertight bulkheads (SOLAS II-1/11)
The Administration accepts the application of IACS UR S14 Rev 7 as an equivalent provision for initial testing of watertight bulkheads under SOLAS Chapter II-1/Reg.11, subject to the conditions stipulated in annex of the attached file “SOLAS-UK Acceptance UR S14_XQ164387”.
Application of IACS UI SC178 on Unified Interpretation of chapter 12 of FSS Code
The Administration accepts the IACS UI SC178 Rev.1, the application date of which is for ships contracted for construction on or after 1st January 2012, and construction commenced before 1st January 2013, for a period of one year until 1st January 2013 and, thereafter, the date of application will be for ships constructed on or after 1st January 2013.
Devices to prevent the passage of flame in cargo tanks - UK / REG policy on MSC.1/Circ.1324
See the attached file “MCA Policy on MSC-Circ-1324”, and specifically its provisions in chapter 5 (“Survey requirements”).
SOLAS II-1/3-2 (IMO PSPC) - Delay in delivery of ships
(4.2 of the Minutes from the 20th BCC Meeting dated 15th June 2012)
The Administration will be adopting the principles in MSC.1/Circ.1247 (“Unified Interpretation of “unforeseen delay in delivery of ships””) and will consider requests in the following manner:
The Administration will deal with ships under this provision case-by-case.
Full details and particulars of the unforeseen circumstances under which the ship is to be accepted to be submitted to the administration along with a statement from the owners and builders that these circumstances were beyond their control.
Further evidence may be required from the authorities of the country where the ship was built confirming the unforeseen circumstances were beyond the control of the owner / builder.
If it appears to the administration that the delay results from the market conditions for the ship, the owner / builder must provide evidence to the satisfaction of the administration that the decision to delay the delivery of the ship was made at a stage of build when it would not have been reasonable to make modifications to comply with the new standards.
(For example after a substantial piece of the ship has been constructed, but not if it only relates to a drawing.)
A footnote will be added to class certification (Passenger Ship Safety Certificate, Cargo Ship Safety Construction Certificate or Cargo Ship Safety Certificate) with delivery date annotated, to indicate that the ship is accepted by the administration under the unforeseen delay in delivery provisions of this interpretation.
Loss of anchor and validity of Safety Construction Certificate
In case of loss of a single anchor, the Administration is to be advised, as the decision that this can be handled through the issue of a class recommendation or a memoranda (rather than require the issue of a short term Safety Construction Certificate) remains with the Flag Administration.
Steering gear
(Action 8 of the RO BCC dated 31/10/2014)
The Administration is content for the amendments to SOLAS Regulation II-1/29 to be applied on a voluntary basis until they enter into force on 1 January 2016.
Collision bulkhead
Cargo ships may, in lieu of complying with the requirements of Regulation II-1/12.5.1, comply with the following:
Except as provided in paragraph 5.2, the collision bulkhead may be pierced below the bulkhead deck in passenger ships and freeboard deck in cargo ships by not more than one pipe for dealing with fluid in the forepeak tank, provided that the pipe is fitted with a screw-down valve capable of being operated from above the bulkhead deck in passenger ships and freeboard deck in cargo ships, the valve being located inside the forepeak at the collision bulkhead. The Administration may, however, authorize the fitting of this valve on the after side of the collision bulkhead provided that the valve is readily accessible under all service conditions and the space in which it is located is not a cargo space. Alternatively, for cargo ships, the pipe may be fitted with a butterfly valve suitably supported by a seat or flanges and capable of being operated from above the freeboard deck. All valves shall be of steel, bronze or other approved ductile material. Valves of ordinary cast iron or similar material are not acceptable.
For further information, refer to the letter from MCA to IMO, referenced MS 067/011/0006 and dated 23 February 2018, in the attached file “EquivalenceForButterflyValves_2018”.
Extended Dry Docking (EDD) Programme
Refer to Guidance Notice 2019-003 in attached file “Guidance Notice 2019-003.pdf”.
Guidelines for lifting appliances (MSC.1/Circ.1663)
(Administration email dated 27/06/2024)
When applying SOLAS regulation II-1/3-13, the Administration expects the Guidelines for lifting appliances (MSC.1/Circ.1663) to be followed on Bermuda ships not later than the first renewal survey after 1st January 2026.
Surveyors employed by approved RO’s are considered competent for this task.
Manoeuvring tests
(34th RO BCC meeting - 11 June 2025)
The MSC Resolution 137(76) - Standards for Ship Manoeuvrability are considered as guidelines and should be used to evaluate the manoeuvring performance of ships of all rudder and propulsion types, of 100m in length and over, and chemical tankers and gas carriers regardless of the length.
The instruction in relation to RO Surveyor attendance during manoeuvring tests would primarily apply during newbuild sea trials; but should also be considered during sea trials following alterations or modifications, which in the opinion of the RO, may influence the ship's manoeuvrability characteristics.
Cargo Ship Safety Equipment Certificate
Interaction between high foam and high fog fixed fire-extinguishing systems
(Instruction ref. RO/0105 dated 06/07/2005 - Extract)
This instruction applies to new vessels and retrofitted systems.
Fixed high expansion foam systems fitted in compliance with regulation 10.4.1.1.2 and operated in conjunction with local high fog systems fitted in compliance with regulation 10.5.6. will not meet statutory and FSS Code requirements due to interaction between the two systems.
The potential for a reduction in fire extinguishing capability arising from simultaneous operation of high fog and high expansion foam has not yet been addressed by IMO and responsibility therefore falls upon the administration to determine the suitability of such an arrangement.
This administration has no objections to the installation of a high fog system in conjunction with a high expansion foam system, provided that the high fog system cannot be operated simultaneously with the high expansion foam system. To prevent simultaneous operation of both fire-extinguishing mediums an interlock should be provided at the high expansion foam local and remote stations.
Breathing apparatus
(Email from MCA dated 14/01/2015)
The Administration’s interpretation of SOLAS II-2 Regulation 5.2.2.6 as amended by MSC.338(91) in relation to the suitable number of spare cylinders is as follows:
In addition to the fully charged spare cylinders required by the regulations for each Self Contained Breathing Apparatus (SCBA), where no means for recharging such cylinders is provided on board, sufficient additional spare cylinders must be provided for training purposes. Factors to be considered by the ship-owner when deciding upon the number of training cylinders to be provided include the requirements in the Safety Management System (SMS) for the number / frequency of drills on board where SCBA cylinders may be used, and the nature of the vessels trading pattern with respect to shore based charging facilities. Cylinders intended for training purposes should be prominently marked to indicate their intended use.
The SMS must take account that at least one fully charged spare cylinder for training purposes must be provided for each SCBA set required by regulation to be on board.
If additional training SCBA sets are provided on board (each with a fully charged training cylinder) then the equivalent number of SCBA sets required on board by regulation need not be provided with a spare cylinder for training purposes.
EEBD
In addition to the SOLAS requirements in machinery spaces, at least one (1) EEBD for each crew member stipulated in the Safe Manning Certificate for the Engine Department should be kept.
Manually operated call points (SOLAS Chapter II-2 Regulation 7.7)
(Email from MCA dated 22/06/2015)
Recognised Organisation (RO) must not apply the IACS UI SC 241 on manually operated call points but must follow the convention requirements.
(Action 14 from the BCC meeting 2015)
Fixed fire detection systems with manually operated call points shall be capable of immediate operation at all times as per the FSS code (i.e. isolation of a fire zone should not inhibit the manually operated call points in that zone).
Lifeboat and rescue boat release and retrieval system
Recognised Organisation (RO) is fully authorised to conduct the following work on behalf of the Administration: Replacement of lifeboat and rescue boat Release and Retrieval Systems (RRS), not meeting SOLAS III/1.5, in accordance with MSC.1/Circ.1392 paragraphs 18-26.
This includes:
Review and approval of replacement lifeboat and rescue boat RRS (MSC.1/Circ.1392 paragraph 20)
Discretion to decide if the hook fixed structural connections need to be replaced (paragraph 21)
Witnessing of the installation (paragraph 23)
Witnessing of the post installation testing (paragraph 25)
Issuing the statement of acceptance as per MSC.1/Circ.1392 appendix 4 (paragraph 26).
MSC.1/Circ.1392 requires Administrations to send IMO reports on evaluation of hooks. These reports are to be sent by Recognised Organisation (RO) to the Administration’s contact point.
The Administration strongly recommends the use of fall preventer devices in accordance with MSC.1/Circ.1392 but their use is not mandatory. The arrangements and any necessary modifications to the existing equipment are to be approved by Recognised Organisation (RO).
Launching with a mechanism from within the survival craft or rescue boat - Passenger ships on short international voyages
The Administration has agreed to an equivalence whereby the launching mechanism required by LSA Code 6.1.2.2 may be omitted on passenger ships on short international voyages. The equivalent arrangement has been uploaded to IMO GISIS ref: X Q51360.
Where the launching arrangement from the survival craft or rescue boat is omitted on a Bermuda vessel, the following note is to be added to the Passenger Ship Safety Certificate in the free text box to the left of the signature block:
“The omission of the survival craft/rescue boat launching mechanism has been accepted as an equivalent arrangement to LSA Code 6.1.2.2. This has been submitted to IMO GISIS ref: XQ51360.”
Equivalent arrangements for stored mechanical power
The Administration has agreed to an equivalent arrangement of the requirement for stored mechanical power to launch a rescue boat as required by LSA Code 6.1.1.3. The equivalent arrangement has been uploaded to IMO GISIS ref: XQ26200.
On ships equipped with a six persons rescue boat which is not one of the ship's survival craft, having weight less than 5500N in fully equipped condition, with engine, but without crew, the launching appliance of the crane does not need to be fitted with stored mechanical power. Slewing of the launching appliance shall be possible by one person against an adverse list of 20 degrees and a trim of 10 degrees. For the other aspects the launching appliance shall be in full compliance with paragraphs 6.1.1 and 6.1.2 of the LSA Code.
The following note is to be added to the Cargo Ship Safety Construction Certificate/Passenger Ship Safety Certificate in the free text box to the left of the signature block:
“The Administration has agreed that the rescue boat launching device does not need to be fitted with stored mechanical power. This has been submitted to IMO GISIS ref: XQ26200.”
A copy of the equivalent arrangement is to be kept with the statutory certificates on board the vessel in case of any queries by Port State Control Officers or third party inspectors.
Simulated launching of free-fall lifeboats
IMO resolution MSC.325(90) introduces an amendment to SOLAS Chapter III Regulation 20 to permit the simulated launching of free-fall lifeboats during the regular tests. IMO has recommended early implementation of this amendment through circular MSC.1/Circ.1411.
The Administration confirms early implementation, with reference to the requirements on guidelines for simulated launching of free-fall lifeboats from MSC.1/Circ.1206/Rev.1.
Refer to the attached file “Guidelines for simulated launching”.
Inflatable liferafts
The Administration has accepted equivalent arrangements for the servicing of inflatable liferafts in accordance with Chapter Ill regulations 4 and 20.8.3 of the International Convention for the Safety of Life as Sea, 1974 as amended.
SURVITEC SAS inflatable liferafts, other trademarks: “SURVITEC, CREWSAVER, ELLIOT, DSB, SURVITECZODIAC, RFD” are packed for extended service intervals.
Servicing will be carried out at 30 month maximum intervals, only at approved servicing stations which have additionally been appointed for this purpose by SURVITEC SAS.
As long as the hermetic seal has not been compromised, the 30 month service intervals will apply for the first 10 years of their service lives, and thereafter at the frequency required by SOLAS regulation III/20.8.1.1. Hermetic seal verification must be performed at maximum intervals of 12 months from the date of last service. This is done on board the ship according to the manufacturer’s instruction for on board inspection.
All servicing tests prescribed in IMO Resolution A.761(18) which would have been carried out during the period of the extended service interval will be carried out by the service station at the next service after the nominal “due date” of that test.
For further information, refer to the IMO circular SLS.14/Circ.576 in the attached file “SLS.14-Circ.576”.
VDR
(Email from the Administration dated 19/08/2014 and Action 4 of the RO BCC dated 31/10/2014)
With respect to the installation of Voyage Data Recorders (VDRs) in accordance with MSC.333(90), VDR “installed” is to mean “set in position, connected to relevant peripheral equipment, and ready for use and evidence of proper operation is verifiable by the Flag / RO or its representative”.
Arrangement for remotely located survival craft
(Administration email dated 05/07/2019)
The Administration agreed the revised Unified Interpretation of SOLAS Reg III/31.1.4 detailed in MSC.1/Circ.1490/Rev.1.
Quote
1. Liferafts required by SOLAS regulation III/31.1.4 should be regarded as "remotely located survival craft" with regard to SOLAS regulation III/7.2.1.4.
2. The area where these remotely located survival craft are stowed should be provided with:
.1 a minimum number of two lifejackets and two immersion suits;
.2 adequate means of illumination complying with SOLAS regulation III/16.7, either fixed or portable, which should be capable of illuminating the liferaft stowage position, as well as the area of water into which the liferaft should be launched; portable lights, when used, should have brackets to permit their positioning on both sides of the vessel;
.3 an embarkation ladder or other means of embarkation enabling descent to the water in a controlled manner* as per SOLAS regulation III/11.7; and
.4 self-contained battery-powered lamps (i.e. luminaires) may be accepted as means of illumination for complying with SOLAS regulation III/16.7. Such lamps should be capable of being recharged from the ship's main and emergency source of electrical power, and should be stowed close to the liferaft and embarkation ladder they are intended to serve, under charge. When disconnected from the ship's power, the lamp should give a minimum duration of three hours of undiminished performance. The lamps should comply with the requirements of section 1.2.3 of the LSA Code. The lamps (i.e. luminaires) should meet the requirements of Ingress Protection rating IP 55. The batteries for the subject lamps should comply with IACS Unified Requirement (UR) E18 requirements irrespective of whether the expiry date is marked by the manufacturer or not.
3. With regard to the distance between the embarkation station and stowage location of the liferaft as required by SOLAS regulation III/31.1.4 (remotely located survival craft), the embarkation station should be so arranged that the requirements of regulation III/13.1.3 can be satisfied.
4. Exceptionally, the embarkation station and stowage position of the liferaft (remotely located survival craft) may be located on different decks provided that the liferaft can be launched from the stowage deck using the attached painter to relocate it to the embarkation ladder positioned on the other deck (traversing a stairway between different decks with the liferaft carried by crew members is not acceptable).
5. Notwithstanding paragraph 2, where the exceptional cases mentioned in paragraph 4 exist, the following provisions should be applied:
.1 the lifejackets and the immersion suits required by paragraph 2.1 may be stowed at the embarkation station;
.2 adequate means of illumination complying with paragraph 2.2 should also illuminate the liferaft stowage position, embarkation station and area of water where the liferaft is to be embarked;
.3 the embarkation ladder or other means of embarkation as required by paragraph 2.3 may be stowed at the embarkation station; and
.4 notwithstanding the requirements in paragraph 4.1.3.2 of the LSA Code, the painter should be long enough to reach the relevant embarkation station.
Unquote
Measurement of General Emergency Alarm and Public Address System
(RO BCC meeting - 20 November 2019)
Sound pressure measurements shall be done separately on each ship.
Servicing and Testing of Life-Saving Appliances, their release and retrieval systems including On-load Release Hooks, Guidance on Free- fall Lifeboats and Fall Preventer Devices
(Shipping Notice 2022-016)
The notice provides requirements for:
Requirements for Annual Inspection and testing of Life Saving Appliances and release and retrieval systems
Authorised Service providers for Lifeboats, launching appliances and on-load release gear
Five Yearly overhaul and 110% dynamic testing
Servicing of Inflatable Life-rafts, Inflatable Boats, Rescue Boats, Fast Rescue Boats, Inflatable Lifejackets and Hydrostatic Releases
Guidance on Drills involving Free Fall Lifeboats
Notes on Fall Preventer Devices and Testing Following Lifeboat and Rescue Boat Hook Replacement
Maintenance, testing and inspection of fire protection and extinguishing systems
Maintenance and Inspection of Fire Protection Systems, Appliances and Certain Emergency equipment
(Shipping Notice 2024-021)
Maintenance, testing and inspections shall be carried out based on the guidelines developed by the Organisation (MSC.1/Circular 1432, as amended by MSC.1/Circular 1516) and in a manner having due regard to ensuring the reliability of fire-fighting systems and appliances.
Maintenance and Inspection of Fixed Carbon Dioxide Fire Extinguishing Systems
(Shipping Notice 2024-027)
Maintenance, testing and inspections shall be carried out based on the guidelines developed by the Organisation (MSC.1/Circ 1318/Rev.1) and in a manner having due regard to ensuring the reliability of fire-fighting systems and appliances.
Maintenance, testing and inspection of portable fire extinguishers
(Shipping Notice 2021-028)
Maintenance, testing and inspections shall be carried out based on the guidelines developed by the Organisation (IMO Resolution A.951(23)) and in a manner having due regard to ensuring the reliability of marine portable fire extinguishers.
Carriage of Immersion Suits – Remote Locations
(Shipping Notice 2022-035)
Applies to Cargo Ships over 500GT and Commercial Yachts over 500GT, regardless of age
With reference to SOLAS Ch III Reg 32.3.3, the Administration considers two (2) additional suits on the navigating bridge, and two (2) additional suits within the ECR to be the minimum required.On smaller ships where the safe manning document only require one engine room watch-keeper the number of additional immersion suits in the machinery space may be reduced to one (1).This is required for ships which hold UMS notation as well as ships that have manned engine-rooms.
Exceptions: Ships other than bulk carriers, may apply to the Administration for agreement that these immersion suits need not be required if the ship is constantly engaged on voyages in warm climates. Such applications will be considered on a case by case basis and will be documented by way of a Statement.
Carriage of Infant and Oversized Lifejackets
(Shipping Notice 2011-008)
The Administration is of the view that the intent of the amendments to SOLAS III/7.2 (MSC.201(81)) is that the change should apply to all passenger ships and all cargo ships over 500 GT from 1st July 2010, and apply regardless of the keel laying date of the ship.
Refer to the Shipping Notice 2011-008 (in attached file) which sets out the position of the Administration with regard to infant and oversized lifejackets.
BNWAS
(Shipping Notice 2011-010 and Shipping Notice 2011-011)
BNWAS units installed in ships before 1st July 2011 and which do not meet the IMO Performance Standards may still be accepted by the Administration and owners with such systems should contact the Department with the details of their systems. If appropriate the Department will issue an exemption from full compliance with the standards.
This BNWAS requirement will also apply to yachts certified under the LY2 Code
ECDIS
(Shipping Notice 2011-010)
Any ECDIS fitted to a ship as a mandatory requirement or as an alternative to the carriage of paper charts is required to be type approved to the appropriate standard, Assembly Resolution A.817(19) as amended if installed before 1st January 2009 and MSC.232(82) if installed on or after 1st January 2009.
The performance standard for ECDIS requires that there should be a back up, the Administration will accept either:
Two separate and independent ECDIS units and no paper charts other than any that might be needed to provide the minimum coverage in areas where there is only raster chart data, or
One ECDIS unit and an up to date suite of paper charts
In ships where ECDIS is the primary navigational system there is a requirement for all navigational officers to have completed both generic ECDIS training and ship specific ECDIS training.
The company operating the ship should ensure that the ship specific training is carried out and clearly documented. Given the critical nature of this training and the records of it this process should be incorporated in the ships Safety Management System (SMS).
EPIRB (IACS UI SC295)
Regarding the vague phrase “installed on or after 1 July 2022" in relation to application of new performance standards for EPIRB (adopted by IMO Resolution MSC 471 (101)), it is confirmed that there had been discussions at IMO MSC 106 on a generic interpretation of the terminology “installed on board”, resulting in MSC.1/Circ.1500 Rev 2 (published 30 Nov 2022).
The Administration confirms the acceptance of the guidance agreed by IMO, and that this reflects the wording within IACS UI SC295.
Equivalent Arrangements for Magnetic Compasses carriage requirements
In accordance with SOLAS Chapter I, Regulation 5, the Administration has determined that the carriage requirements for Standard and Spare magnetic compasses under Regulations V/19.2.1.1 and V/19.2.2.1, and a gyro compass under Regulation V/19.2.5.1 may be satisfied by either of the following methods:
Fitting of three gyro compasses, under the following conditions:
Each gyrocompass shall:
be independently connected to both main and emergency sources of electrical power, and;
have a transitional source to be able to supply uninterrupted electrical power for up to 30 minutes (this may be satisfied by use of ship transitional power, if fitted), and;
be type approved in accordance with the international standards, and;
Display the reading at the main steering position.
To avoid ‘single point of failure’ and to afford redundancy, the installation arrangements should be such that a fire, or other incidents, in one compartment should not render all of the compasses inoperative i.e. One gyrocompass shall be separated from the other units by at least one A Class fire boundary.
Fitting of two gyro compasses and one GNSS compass, under the following conditions:
Each gyrocompass and the GNSS compass shall:
be independently connected to both main and emergency sources of electrical power, and;
have a transitional source to be able to supply uninterrupted electrical power for up to 30 minutes (this may be satisfied by use of ship transitional power, if fitted), and;
Display the reading at the main steering position.
The gyrocompasses shall be type approved in accordance with international standards.
The GNSS compass shall be type approved in accordance with the requirements for a Transmitting Heading Device (THD) complying with SOLAS V/19.2.3.5
The GNSS compass is separate to the GNSS requirement stipulated within V/19.2.1.6
To avoid ‘single point of failure’ and to afford redundancy, the installation arrangements should be such that a fire, or other incidents, in one compartment should not render all of the compasses inoperative i.e. One gyrocompass or the GNSS compass shall be separated from the other units by at least one A Class fire boundary.
For further information, refer to General Equivalency Letter to IMO (XQ162569) in attached file “Equivalent Arrangements for Magnetic Compasses carriage requirements - XQ162569”
REG interpretation of SOLAS II-2/7 as applicable to cargo ships
(Refer to attached file “Manually Operated Call Points Policy”)
The phrase “Manually operated call points complying with the Fire Safety Systems Code shall be installed throughout the accommodation spaces, service spaces and control stations” does not require the fitting of a manually operated call point in an individual space within the accommodation spaces, service spaces and control stations.
However, a manually operated call point shall be located at each exit (inside or outside) to the open deck from the corridor such that no part of the corridor is more than 20 m from a manually operated call point.
Service spaces and control stations which have only one access, leading directly to the open deck, shall have a manually operated call point located at the same deck not more than 20 m (measured along the access route using the deck and/or corridors) from the exit.
A manually operated call point is not required to be installed for spaces having little or no fire risk, such as voids and carbon dioxide rooms.
REG interpretation of amendments to SOLAS II-2 (MSC.1/Circ.1694)
(UK MCA email dated 26/11/2025)
(Information Notice 2026-01)
With regards to point 5. of MSC.1/Circ.1694 – Unified interpretations of SOLAS Chapter II-2 and the HSC Codes (1994 and 2000), the UK/REG position relating to, which standards are considered “recognized” by the Administration is as follows:
Noting that all Aqueous Film Forming Foam (AFFF) should be PFOS free as per the SOLAS requirements. Also noting that PFOS has been banned by the UK and EU for over ten years (including for marine use).
Noting that the guidance requires a recognised standard and that there is no UK/REG standard for PFOS testing currently, the UK/REG is open to approval based on other acceptable standards.
The UK/REG understand that the NPR-CEN/TS 15968 standard has now been withdrawn, however as that standard was withdrawn as it does not work for the testing of other banned PFAS which are banned in the UK and the EU but not in the maritime sector and that no alternative has been published, the UK/REG believe it is still appropriate to use NPR-CEN/TS 15968.
The UK/REG will also accept a modified version of ISO 25101 that has been adapted for use on foams instead of its intended use in water sampling.
The UK/REG will be willing to consider other recognised tests methods (for example the US EPA Method 8327) but for now the aforementioned are the preferred tests.
Escape routes and safety equipment markings
(Guidance Notice 2019-002)
IMO Resolution A.1116(30) entered into force on 1st January 2019 and contains new requirements on the form of fire control signs and safety signs to be used on board ships. This Guidance Notice reproduces in part the guidance contained in IMO Resolution A.1116(30) and provides general guidelines on applicability to Bermuda flagged ships.
LRIT
(Information Notice 2019-04)
This information notice provides guidance relating to the LRIT Conformance Test Reports (CTR) issued to Bermuda Registered ships by Polestar under the provisions of MSC.1/Circ.1296.
Cargo Ship Safety Radio Certificate
Installation of GMDSS equipment
(Fax dated 27 May 1996)
Where the Society is required to survey the fitting of a GMDSS installation, a copy of the newly issued interim certificate is transmitted to the Administration through Recognised Organisation (RO) London on urgent basis to enable them to deliver a new “Safe manning certificate”, where necessary.
Passenger Ship Safety Certificate
Recognised Organisation (RO) has a limited delegation for Passenger Ship Safety certification. Surveys are completed jointly with the Administration.
Passenger Ship stability approval: delegation by the Administration will be granted on a case by case basis with review of approval by the Administration.
A Partial Declaration (ROSF.318) is to be issued and copied to the Administration whenever a class periodical survey is carried out on board a passenger ship flying the Bermuda Flag.
Damage Control Drills for Passenger Ships
(Guidance Notice 2019-11)
Changes to SOLAS that enter into force on 1st January 2020 require passenger ships to complete damage control drills every three months and update their muster lists accordingly.
For further information, refer to attached file “Guidance Notice 2019-11 - Damage Control Drills for Passenger Ships”.
Carriage of Infant and Oversized Lifejackets
(Shipping Notice 2011-008)
Refer to Carriage of Infant and Oversized Lifejackets.
Passenger Ship Bottom Inspection Requirements
(Shipping Notice 2025-039)
This Shipping Notice provides the requirements in relation to bottom inspections of passenger ships and applies to all Bermuda Ships holding a Passenger Ship Safety Certificate, except RoRo passenger ships.
Recognised Organisation (RO) shall advise the Administration of the outcome of all in water surveys where there is any need for further examination of the ship and/or remedial action which may need to be taken with the ship in dry-dock.
The relevant survey report shall be made available for review by the Administration. For ships over 15 years of age, Recognised Organisation (RO) shall send the survey report to the Administration by email at survey@bermudashipping.bm on completion of the IWS.
The survey report shall include an assessment of the condition of the hull coating, structure, and all remaining underwater parts, acceptability of measurements taken and other relevant findings.
Recognised Organisation (RO) is to advise the Administration without delay of any new conditions of class or memos related to hull, propellers, rudders, Azipods, transverse thrusters, fin stabilisers and underwater fittings.
Safe Return to Port (SRtP)
Refer to :https://www.redensigngroup.org/media/1282/safe-return-to-port_oct-2019.pdf
Others
IGC Code
A0 Wheelhouse windows (IGC Code §3.2.5)
(BBC Meeting dated 28 November 2018)
The Administration supported the removal of the A0 windows as the vision through A0 glass can be distorted and it is not possible to get A0 clearview screens. They agree for the early implementation and in the process of drafting a notification to IMO on early implementation of MSC.1-Circ.1549.
POLAR Code
(Guidance Notice 2019-004)
For cargo ships, Recognised Organisation (RO) is authorized to verify adherence to the requirements of the Polar Code and to issue the Polar Ship Safety Certificate.
For Passenger ships, adherence to the requirements of the Polar Code, and issuance of the relevant documentation is conducted by the Administration.
For further information, refer to attached file “Guidance Notice 2019-004.pdf”.
Offshore Supply Vessels
Recognised Organisation (RO) is fully authorized for survey and issuance of:
Document of Compliance OSV according to Resolution MSC.235(82)
Certificate of Fitness according to IMO Res.A.673(16)
Certificate of Fitness according to IMO Res.A.1122(30) (OSV Chemical Code)
IGF Code
(Administration email dated 28/03/2023)
Recognised Organisation (RO) is authorized for approval and assessment of equipment and arrangements in accordance with the IGF Code as follows:
Cargo ships: full delegation.
Passenger ships: partial delegation and will be specified on a case-by-case basis for new builds and flag in.
Alternative Design and Arrangements (ADA)
(REG-UI 009)
Until the interim guidelines for use of alternative fuels are made mandatory under the IGF code or otherwise, an Alternative Design and Arrangements (ADA) process is to be followed.
The interim guidelines for the fuel or system components in consideration can be used as a basis for the ADA unless otherwise stated by the administration.
In accordance with the ADA process, when the alternative design and arrangements has received final approval, the administration will issue the document of approval and submit the report on approval to the IMO via the IMO Global Integrated Ship Information System (GISIS) website.
Where all risk assessments required by the interim guidelines have been completed and compliance with the prescriptive and functional requirements of the interim guidelines has been confirmed via the plan approval and site survey, the qualitative and quantitative risk analysis as referenced in MSC.1/Circ.1455 are not required.
Where a vessel is unable to comply with any of the provisions of the interim guidelines, no exemption request is necessary as the ‘deviation’ can be addressed within the ADA process and within the context of the whole design. However, these deviations should be highlighted to the Administration.
IMDG Code
Recognised Organisation (RO) is authorized to conduct plan approval and survey on board for Cargo ships in accordance with the IMDG Code. The Administration retains responsibility for the survey of Passenger ships in respect to the IMDG code.
International Code on Intact Stability, 2008
The Administration accepts that the alternative criteria as contained in Chapter 4 of MSC.1/Circ.1281 may be applied in lieu of the requirements of Paragraph 2.2.3 of the 2008 IS Code to ship types eligible for application of such provision.
MARPOL 73/78
Annex I. IOPP certificate
Refer to Merchant Shipping (Prevention of Oil Pollution) Regulations 2021, in attached files.
Regulation 12.2.2
The Administration adopts the Unified Interpretation for regulation12.2.2 (MEPC.1/Circ.753).
Add-on equipment for upgrading resolution MEPC.60(33) - compliant oil filter equipment
(Email from MCA dated 11/10/2012)
Recognised Organisation (RO) is authorised to issue the certificate of type approval for add-on equipment on behalf of the Administration providing the equipment performance has meet the requirements contained within the “2011 guidelines and specifications for add-on equipment for upgrading resolution MEPC.60(33) - compliant oil filter equipment” (resolution MEPC.205(62)).
A format for this certificate is included in the appendix 1 of these guidelines.
It should be noted however, that the add-on equipment is not a mandatory requirement by the administration.
Stability instrument
(Email from MCA dated 09/09/2015)
The Administration does not authorise Recognised Organisation (RO) to grant waivers on their behalf from using stability computers under the conditions laid down in the resolutions and related guidelines (i.e. MEPC.248(66), MSC.369(93) and MSC.370(93)).The Administration default position is that a loading instrument should be fitted / provided ashore for these vessels. The waiver should only ever be a last resort for oil tankers where fitting a loading instrument is impractical or the costs of providing one would be prohibitive and may only be granted by the Administration based upon evidence provided by Recognised Organisation (RO). The waiver would need to be accompanied by comprehensive approved information available on-board to support this.
Regulation 12A
(Item 2.b. of the 2015 BCC meeting)
Definition of “major conversion” under MARPOL Annex I (Regulation 1.9.1) includes “any modification which otherwise so alters the ship that, if it were a new ship, it would become subject to relevant disposition of the present convention not applicable to it as an existing ship”. Any modification of tank/s on any ship (existing or new) that results in overpassing the total FO capacity on board over 600 m3 would thus be considered as a major conversion in regard to application of Regulation 12A (Oil fuel tank protection).
In principle, full compliance with Regulation 12A is required. Nevertheless where full compliance with Regulation 12A is not feasible on any specific case, this should be brought to the attention of the Administration by Recognised Organisation (RO) for consideration of any alternate proposal.
SOPEP Approval
For existing ships, if at change of flag to Bermuda the SOPEP was previously approved by Recognised Organisation (RO), then Recognised Organisation (RO) can continue to approve the SOPEP including any amendments copy to be forwarded to the Administration.
All other occasions case by case authorization for approval of the SOPEP.
Where Recognised Organisation (RO) is authorized to approve the SOPEP, the SOPEP may be approved in electronic format.
Annex II. NLS certificate
SMPEP Approval
For existing ships, if at change of flag to Bermuda the SMPEP was previously approved by Recognised Organisation (RO), then Recognised Organisation (RO) can continue to approve the SOPEP including any amendments copy to be forwarded to the Administration.
All other occasions case by case authorization for approval of the SMPEP.
Where Recognised Organisation (RO) is authorized to approve the SMPEP, the SMPEP may be approved in electronic format.
Annex IV. ISPP certificate
(Merchant Shipping (Prevention of Pollution by Sewage and Garbage from Ships) Regulations 2015, BR 44/2015 dated June 2015, in attached file)
MARPOL Annex IV has been extended to Bermuda by the UK on 02 November 2023, which means that International Certificates are now to be issued for Recognised Organisation (RO) classed Bermuda ships.
Maximum permissible rate of discharge
(Shipping Notice 2022-034)
Recognised Organisation (RO) is to approve the maximum permissible rate of discharge of untreated sewage (as per MARPOL Annex IV reg.11.1.1) which should be vessel specific and achievable, taking fully into account the capacity (fixed/variable) of the pump provided, for different combinations of draft and speed.
Administration confirms it shall be retrospective with reviews for discharge rates taking into account this requirement undertaken at the first available opportunity. This would be in line with Annex IV Reg 4.6.
Variable Discharge Pumps
(Administration email dated 05/09/2022)
Recognised Organisation (RO), undertaking approval of maximum discharge rates for untreated sewage in accordance with MARPOL Annex IV Regulation 11.1.1, can accept existing variable rate discharge pumps providing that the variable rate of the pump can be fixed to a discharge rate which renders the most effective discharge rates compliant with the Regulation.
Above pump discharge rate should be detailed on the sewage discharge rate table approved by Recognised Organisation (RO). Also, suitable instructions should be included within the ship’s SMS Sewage discharge procedures to ensure that the approved pump discharge rate is not exceeded in service during sewage discharge operations.
(33rd RO BCC meeting - 2nd May 2024)
Where a variable discharge rate pump is fitted, it can be accepted, subject to the rate being fixed at whatever rate is the most suitable for the pump (e.g. in relation to suction, flow rate, cavitation, overheating etc) provided the discharge rate is within the requirements of the Regulation.
If the maximum discharge rate of the installed pump(s) means the discharge is greater than that allowed under the Regulation, then a lower rate will need to be used that is within the Regulation parameters, if that rate is not suitable for the pump in question (i.e. ineffective or damages the pump) a new or alternative pump will need to be used, that allows discharge in line with regulation.
Annex V
Annex VI. IAPP, EIAPP and IEE certificates
IAPP, EIAPP and IEE delegation
(Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2019, BR 106/2019 dated October 2019, in attached file)
(Information Notice 2024-01 in attached file)
MARPOL Annex VI has been extended to Bermuda by the UK on 08 May 2024, which means that International Certificates are now to be issued for Recognised Organisation (RO) classed Bermuda ships.
For ships already issued with an IAPP Statement of Compliance, it is acceptable to Bermuda to administratively replace the SoC by the corresponding IAPP Certificate.
MEPC.184(59) - Guidelines for exhaust gas cleaning systems
Bermuda does not consider as acceptable averaging SOx emissions from “over performing” equipment against untreated equipment as the means to comply to the SOx emission limits requirements.
To further clarify, Bermuda does not interpret this arrangement to cover engine streams where the stack is not common, e.g. a ship with multiple stacks where one stack is treated while another emits higher sulphur.
Boil-off gas co-firing equivalence
(Email from MCA dated 22/06/2015)
The Administration accepts co-firing of high sulphur oil with boil-off natural gas for Liquefied Natural Gas (LNG) carriers when operating in the North Sea and Baltic Sea Emissions Control Areas and for compliance with European at-berth requirements as permitted by the European Commission Decision of December 2010 (2010/769/EU), as per the letter from the European Commission to the European Community Shipowners Association, dated 6th June 2014.
(Email from MCA dated 05/08/2015)
Recognised Organisation (RO) is requested to keep the Administration informed should Recognised Organisation (RO) has an approved job in relation to the boil-off gas co-firing equivalence.
Approved method
(Email from MCA dated 13/10/2015)
The Guidelines on the approved method process for engine in compliance to IMO NOx emission limits (Resolution MEPC.243(66)) are applicable to Bermuda flag vessels.
EEDI & SEEMP
(Email from MCA dated 11/10/2012)
As the new EEDI and SEEMP requirements are based on the amendment of MARPOL Annex VI (as per the resolution MEPC.203(62)), Recognised Organisation (RO) is authorised to carry out survey and issue Statement of Compliance for these new requirements, under the existing MARPOL Annex VI authorisation.
Data Collection System for fuel oil consumption of ships
(Item 3.5.3 Addendum A of Appendix 1 to the Agreement in attached files)
Recognised Organisation (RO) is authorized to perform the following statutory services:
Reviewing of SEEMP Part II and issuance of Confirmation of Compliance, (MARPOL Annex VI, Regulation 5, para. 4.5)
Verification of reported data, (MARPOL Annex VI, Regulation 22A)and Issuance of Statement of Compliance (MARPOL Annex VI, Regulation 5, para. 4.5)
Submission of reported data to the IMO Ship Fuel Oil Consumption Database ((MARPOL Annex VI, Regulation 22A, para. 9). A copy of the data should be sent to the Administration at survey@bermudashipping.bm, the same time it is submitted to IMO.
Enhanced Collection of Fuel Usage Data
(REG-UI 006 Amendment 02)
The simplest and most direct method to record and report the enhanced DCS is by fitting flow meters for each consumer taking into account the guidance provided within MEPC.346(78), section 7.2.
These meters would then be read each year and the difference calculated. Photographic evidence of flow meter readings may be used in support of the required data submission. Recognised Organisation (RO) verifying the submission may be sent the evidence and the completed submission at the agreed time. Flow meters should be maintained and calibrated in accordance with manufacturer recommendations.
The IMO also allow for systems of calculation and estimation to be used as the basis for submission of the Enhanced DCS. The Administration do not recommend the use of such systems for recording the enhanced DCS given the potential for the data to be compromised by inconsistencies over the course of a year.If such a system is to be used, the SEEMP must incorporate clear and detailed instructions of the measurements and estimates to be used for the submission. In this case the data will need to be accumulated consistently throughout the year.
Recognised Organisation (RO) shall:
Ensure ships have in place all required equipment for measuring or otherwise determining the fuel usage in each consumer.
Ensure that for all ships, the SEEMP has been modified with all procedures required to complete the required measurements or alternative procedures.
Ensure all ships are recording Enhanced DCS data for submission in January 2027 and each year thereafter.
SEEMP Part III and Carbon Intensity Indicator (CII)
(Administration email dated 16/09/2022)
The authorisation for approval of SEEMP Part III under MARPOL VI/26 and verification of Carbon Intensity Indicator (CII) under MARPOL VI/28 of Bermuda ships is extended to the respective Bermuda RO who has additionally taken on the responsibility for IMO Data Collection System (DCS) for Fuel Oil Consumption of those ships, i.e. the DCS and CII verification, and issuance of Statement of Compliance for a Bermuda ship must be carried out by the same Bermuda RO irrespective of whether that RO has classed the ship.
This permission is subject to that RO taking full legal responsibility for the whole of the DCS, CII and SEEMP Part III work, or the ship owner ensuring an agreement exists between the DCS/CII RO and the ships’ primary RO as to who owns responsibility for the shipboard elements of the DCS and CIII work and related certifications. The Administration would emphasise the importance of the owner having documented, legal clarity as to who takes responsibility for each element.
In addition, the DCS/CII RO shall provide an annual list of Bermuda ships for which they have undertaken the verification work before 30th June of each year starting 2023.
Biofuels
Ships using fuel blends with biofuels or synthetic fuels, regardless of percentage, do not fall under “alternative fuel oils” as defined in MARPOL Annex VI Regulation 4. Therefore, no acknowledgement by the Administration is required, and there is no obligation to report particulars to IMO under MARPOL Annex VI Regulation 4. However, this does not remove the obligation to report fuel usage under the Data Collection System (DCS) (Regulation 27).
The following schemes are considered acceptable for biofuel certification:
ISCC and RSB (recognised internationally and by IMO).
Schemes listed under the UK RTFO recognised voluntary schemes.
ICAO-approved sustainability schemes and CORSIA criteria.
Other schemes aligned with EU RED Directive sustainability criteria may be assessed individually.
Documentation such as Proof of Sustainability (PoS) and LCV values (either within certification or via laboratory results) is deemed adequate alongside Bunker Delivery Notes.
Use of Cf based on Well-to-Wake emissions for certified sustainable biofuels is accepted for DCS reporting and CII calculation, provided:
The biofuel is certified under an international scheme.
It achieves at least 65% WtW emissions reduction compared to fossil MGO (94 gCO2e/MJ), resulting in less or equal to 33 gCO2e/MJ.
For blends, Cf should be calculated as a weighted average based on energy content.
(REG-UI 008)
This REG-UI 008 is to provide the REG position on the application of the guidance in interpretation 15 of MEPC.1/Circ.795/Rev.9 as amended. The flow chart given in Figure 1 provides a comprehensive summary of the REG policy position on biofuels and NOx emissions for all scenarios.
EEXI
Cruise passenger vessels fitted with gas turbine
(REG-UI 003 Amendment 01)
Cruise passenger vessels fitted with gas turbine plant as part of a diesel engine / gas turbine installation are allowed to exclude the gas turbines from the power-weighted average calculation of the specific fuel consumption used in the EEXI calculations for these ships.
This is conditional on the gas turbines only being used for emergency situations to secure the safety of the ship or saving life at sea.
When a Gas Turbine, which has been excluded from the ship’s EEXI rating, is used in an emergency situation it will be considered a use of the power reserve. Examples of this include operating in, or the avoidance of, adverse weather and ice-infested waters, participation in search and rescue operations, when sick passengers or crew need to be transferred ashore urgently, avoidance of pirates and for engine maintenance. Details must be recorded in the Onboard Management Manual (OMM) as described in MEPC.335(76) section 3.2. Use of the power reserve must be reported to the Recognised Organisation (RO) and the port of destination. The flag administration will report all cases of the use of power reserve to the IMO on an annual basis.
If an operator wishes to continue to use gas turbines during the routine operation of the vessel, then the gas turbines must be taken into account when calculating the EEXI rating for the ship.
Use of SHaft Power Limitation (SHaPoLi) systems (IACS Rec.172)
(REG-UI 004 Amendment 03)
The Administration accepts the IACS Recommendation 172 as amended, provided SHaPoLi systems comply with the following requirements:
The SHaPoLi system should be fitted with a visual indication and an audible alarm at the control position on the bridge. The visual indicator should indicate when the power is approaching the power limit and remain visible whilst the power limit is being exceeded. The audible alarm may be acknowledgeable (silenced).
In addition to the above an alarm is to be fitted to indicate system malfunction.
The SHaPoLi / EPL system should be non-permanent but should require the deliberate positive action of the ship's master or the OICNW to enable the use of unlimited shaft / engine power (power reserve) of the ship. This should be via the use of a key switch or similar. For existing vessels where the use of a key switch to access the power reserve is not practicable, a suitable alternative may be considered. By way of example, the acknowledgement of the audible alarm(s) required in 3.1.1 and the continued use of the reserve power may be considered as deliberate positive action. For systems that use a Password/PIN to control access to the power reserve override, attention should be paid to ensure that the necessary Password/PIN is always available when override is required by the ship in a scenario specified in regulation 3.1 of MARPOL Annex VI, which may endanger safe navigation of ship. Immediate use may be achieved by procedural arrangements for pre-emptive un-limiting of the SHaPoLi / EPL system.
Records of the use of the power reserve shall be submitted to Recognised Organisation (RO) and the port of destination without delay. The Administration interprets ‘without delay’ to mean within 24 hours of the last event. Recognised Organisation (RO) is authorized to transmit these records onward to the IMO, at the appropriate intervals. Recognised Organisation (RO) is also requested to transmit copies of these records to the office of the Administration which is responsible for the vessel.
If the power limit is exceeded inadvertently (due to a change in sea or tidal conditions, for example) the system should alert the bridge and automatic data recording shall begin within 300 seconds (5 minutes) after the limit is exceeded. This time delay is intended to allow the operator to modify the input if the use of reserve power is not necessary.
Any use of the power reserve or inadvertent exceedance of the power limit (beyond the 300s time limit) must be recorded in the OMM and in accordance with the guidelines.
The reactivation or replacement of the SHaPoLi / EPL system following any use of the power reserve, must be confirmed and supported by documentary evidence such as OMM log extracts and photographic evidence, by the Master or operator of the vessel, to Recognised Organisation (RO) at the earliest opportunity. Recognised Organisation (RO) shall review all documentary evidence submitted, to verify the satisfactory reactivation or replacement of the SHaPoLi / EPL system. Such verification may, if so required, extend to an occasional survey, which may be undertaken via stablished remote survey means.
Recognised Organisation (RO) shall during the required MARPOL Annex VI (IAPP) periodical attendances, verify that all occasions where the reactivation or replacement of the SHaPoLi / EPL system has taken place, have been reported. Recognised Organisation (RO) shall verify that corresponding entries are contained within the OMM log, together with supporting documentary evidence demonstrating the reactivation or replacement of the SHaPoLi / EPL system.
For overridable systems, the existing manoeuvring booklet, if available, and the manoeuvring information displayed on the navigating bridge shall (1) include the ship’s power; if it has been limited and (2) state the limiting power for the attention of the Master to account for the ship’s performance in case no corresponding sea trials are carried out.
For non-overridable systems, the stopping times and distances, and the data of the turning circles as per SOLAS Reg. II-1/28.3 and Res.MSC.137(76) respectively, are to be recorded on new trials, where applicable. Also, the existing manoeuvring booklet, if available, and the manoeuvring information displayed on the navigating bridge (pilot card and wheelhouse poster) are to be updated.
The Administration requires that any update of the manoeuvring characteristics of the ship (in respect to Overridable or Non-overridable system) is verified by Recognised Organisation (RO) and to be completed no later than the next scheduled periodical survey related to the Safety Construction Certificate (SAFCON).
In cases where the manoeuvring characteristics of the ship are determined by new sea trials; Recognised Organisation (RO) will, as part of the verification stated above, verify that the new sea trial has been undertaken in accordance with the requirements for new sea trials contained within IACS Recommendation No. 172 (as amended).
In cases where Recognised Organisation (RO) has witnessed the new sea trial, a witness statement attesting to the effect of the SHaPoLi arrangement, shall be issued by Recognised Organisation (RO).
Alternative methods for updating the manoeuvring characteristics, such as CFD (Computational Fluid Dynamics) numerical calculations, are acceptable subject to plan appraisal, and are to be included in the EEXI technical file.
Issuance of short term/limited validity letter/permit in relation to any interim compliance scheme for EEXI (ShaPoLi/EPL systems)
(32nd RO BCC meeting - 29th June 2023)
Recognised Organisation (RO) is to approach the Administration when situation arise, for possible temporary dispensation, on a case by case basis.
EEXI implications in case of change from Bulk Carrier to General Cargo
(33rd RO BCC Meeting - 2nd May 2024)
The position of the Administration is: if a vessel has been built and designed as a bulk carrier, and there is no evidence of significant change, then it will remain a bulk carrier.
VOC Management Plan
(Shipping Notice 2011-009)
VOC Management Plans are required to be approved by the Administration and this task has been delegated to Recognised Organisation (RO). Owners who have prepared VOC management Plans and who wish to have them approved should approach Recognised Organisation (RO) for this service.
MARPOL Electronic Record Books
(REG-UI 002)
The Administration delegates the approval of electronic record books to Recognised Organisation (RO).
This is applicable to the use of the following electronic record books and recording requirements under the MARPOL Annexes and the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (NOx Technical Code):
Oil Record Book, parts I and II (MARPOL Annex I, regulations 17.1 and 36.1)
Cargo Record Book (MARPOL Annex II, regulation 15.1)
Garbage Record Book, parts I and II (MARPOL Annex V, regulation 10.3)
Ozone-depleting Substances Record Book (MARPOL Annex VI, regulation 12.6)
Recording of the tier and on/off status of marine diesel engines (MARPOL Annex VI, regulation 13.5.3)
Record of Fuel Oil Changeover (MARPOL Annex VI, regulation 14.6)
Record Book of Engine Parameters (NOx Technical Code, paragraph 6.2.2.7)
The generic system must have been approved by a REG authorised Recognised Organisation (RO) or member of the REG (in most cases this will be by a RO); and
Recognised Organisation (RO) must be contacted in order to arrange for the system to be accepted for use onboard the ship. Recognised Organisation (RO) is to verify the system has been installed correctly on the ship, including anything ship specific such as back-up systems. If satisfied the system is acceptable, Recognised Organisation (RO) is to issue a Declaration of electronic MARPOL Record Book to the ship. This Declaration must be retained onboard as evidence that the system has been accepted.
TONNAGE 69
Tonnage certificate
(Paragraph 3.2 of Appendix 2 of the Agreement, refer to Annex 2 to the Agreement)
The TO shall send to the Administration:
one copy of the tonnage certificate
one copy of the certificate of survey
(Agenda item 10 of the BCC meeting 2015)
Recognised Organisation (RO) is to ensure all Tonnage Certificates (ITC 69) contain the correct information as required in the convention and the specimen certificate thereto, and also to ensure the original Certificate of Survey contains the correct information of the ship and its tonnages.
In circumstances where the original Certificate of Survey had been reissued with insufficient data, then this certificate must be promptly updated when the correct data is available at the time of completion of vessel’s construction and delivered to the owner.
Change of tonnage - REG Unified-Interpretation
(Administration email dated 03/06/2020, REG-UI 0001.A01)
The Administration would not normally consider small changes made solely for compliance with a new regulation to affect tonnage or application of regulations under other Conventions.
For “new” ships under the Tonnage Convention, tonnage shall always be re-measured following changes to enclosed spaces and if <=1% then either annotate the current certificate or issue a new certificate, at owners discretion; in either case using retaining the existing tonnage. If the cumulative effects of more than one such change exceeds 1% of the original tonnage, then the recalculated figure shall be used on the Tonnage Certificate and all other Convention certificates.
For “existing ships” the current 1% allowance under TM5./Circ.6 applies.
Yachts
(REG Tonnage Guidelines for Yachts Rev.1.2)
Yachts can be regarded as purpose-built ships which have some unique constructional features in exterior areas for aesthetical reasons or for guest recreation that do not affect the overall size or useful capacity for which it would be unreasonable to include in the vessel’s tonnage.
The document “REG Tonnage Guidelines for Yachts Rev.1.2” provides Recognized Organizations (ROs) acting on behalf of this Administration additional guidance on how to apply the International Convention of Tonnage Measurement of Ships, 1969 and TM.5/Circ.6 for typical yacht arrangements.
Guidelines Rev.1.2 are applicable to vessels with contracts signed on or after 1st January 2025 and projects with contracts signed before 1st January 2025 keel to be laid no later than 1st January 2026.
BWM Convention
BWM Certificate
(Information Notice 2024-01 in attached file)
Ballast Water Management Convention has been extended to Bermuda by the UK on 08 May 2024, which means that International Certificates are now to be issued for Recognised Organisation (RO) classed Bermuda ships.
For ships already issued with an Ballast Water Management Statement of Compliance, it is acceptable to Bermuda to administratively replace the SoC by the corresponding BWM Certificate.
Ballast Water Management systems
(Guidance Notice 2024-01)
The Administration will accept type approval certificates issued for Ballast Water Management Systems equipment approved in accordance with the G8 Guidelines (Resolution MEPC.279(70)) or Resolution MEPC.300 (72) by the other Contracting Administrations or other Recognised Organisations, on Bermuda ships.
Initial Survey for D-1 compliance only
(UK/REG interim policy received on 24/08/2017).IMO BWM.2/Circ.40 provides for a three-month period of grace for BWM Plans to be approved and placed onboard vessels. This implies that completion of the initial survey has a similar grace period, until an approved plan is onboard.
The validity of the Statement of Compliance issued by Recognised Organisation (RO) shall reflect the status of the initial survey required by the convention. Once Recognised Organisation (RO) is satisfied that the requirements of the initial survey have been fully met, then a full term Statement of Compliance may be issued.As a consequence of the above, if the initial survey requirements are substantially met and Recognised Organisation (RO) is satisfied that the vessel is compliant with the applicable requirements of the Convention, then a one-off Statement of Compliance valid until 7th December 2017 is issued to allow sufficient time for verification of full compliance onboard.
For further information, refer to attached file “BWMC - REG Initial Survey Policy.docx”.
Hopper Dredgers
(Administration email dated 29/06/2018)
With reference to BWM.2/Circ.32, the Administration position is that water held in the hopper of a dredger does not fall under the requirements of the Convention. This does not impact on application of the Convention to any water held in the ballast tanks of hopper dredgers, should they have them.
Electronic Ballast Water Record Book
(REG-UI 007)
The generic system must have been approved by a REG authorised Recognised Organisation (RO) or member of the REG (in most cases this will be by a RO); and
Recognised Organisation (RO) must be contacted in order to arrange for the system to be accepted for use onboard the ship. Recognised Organisation (RO) is to verify the system has been installed correctly on the ship, including anything ship specific such as back-up systems. If satisfied the system is acceptable, Recognised Organisation (RO) is to issue a Declaration of electronic Ballast Water Management Record Book to the ship. This Declaration must be retained onboard as evidence that the system has been accepted.
Refer to attached file REG-UI 007 for Administration’s policy on electronic signatures, storage of data and offline records.
ILO Conventions
Cargo handling gear - ILO convention 152
Approval of ship’s cargo handling gear shall be in accordance with Recognised Organisation (RO)’s rules and requirements.
Miscellaneous technical requirements
Commercial yachts
Load Line & SOLAS certificates endorsements
The endorsement requirements for all Load Line and SOLAS certificates for large commercial yachts should be along the following lines.
Load Line Certificate endorsements
For yachts compliant with LY1 (“the code of practice for safety of large commercial sailing & motor vessels”)
QUOTE
CONDITIONS: This vessel is to comply with the requirements of “LY1” – “The Code of Practice for Safety of Large Commercial Sailing & Motor Vessels”, as an equivalent to the International Convention on Load Lines 1966, under the terms of IMO Circular Letter No.1996, dated 25 July 1997, as a “yacht engaged in trade as a commercial vessel (12 passengers max)”
UNQUOTE
For yachts compliant with LY2 (“the Large commercial Yacht code”)
QUOTE
CONDITIONS: This vessel is to comply with the requirements of “LY2” – The Large Commercial Yacht Code, as an equivalent to the International Convention on Load Lines 1966, under the terms of IMO Circular Letter No. 2937, dated 13 January 2009, as a “yacht engaged in trade as a commercial vessel (12 passengers max)”
UNQUOTE
For yachts compliant with LY3 (“the Large commercial Yacht code”)
QUOTE
CONDITIONS: This vessel is to comply with the requirements of “LY3” – The Large Commercial Yacht Code, as an equivalent to the International Convention on Load Lines 1966, under the terms of IMO Circular LL.3/Circ.228, dated 16 September 2013, as a “yacht engaged in trade as a commercial vessel (12 passengers max)”
UNQUOTE
SOLAS Certificates endorsements
For yachts compliant with LY1 (“the code of practice for safety of large commercial sailing & motor vessels”)
QUOTE
CONDITIONS: This vessel is to comply with the requirements of “LY1” – “The Code of Practice for Safety of Large Commercial Sailing & Motor Vessels”, as an equivalent to the International Convention for the Safety Of Life At Sea, 1974, under the terms of IMO Circular Letter No.1996, dated 25 July 1997, as a “yacht engaged in trade as a commercial vessel (12 passengers max)”
UNQUOTE
For yachts compliant with LY2 (“the Large commercial Yacht code”)
QUOTE
CONDITIONS: This vessel is to comply with the requirements of “LY2” – The Large Commercial Yacht Code, as an equivalent to the International Convention for the Safety Of Life At Sea, 1974, under the terms of IMO Circular Letter No. 2937, dated 13 January 2009, as a “yacht engaged in trade as a commercial vessel (12 passengers max)”
UNQUOTE
For yachts compliant with LY3 (“the Large commercial Yacht code”)
QUOTE
CONDITIONS: This vessel is to comply with the requirements of “LY3” – The Large Commercial Yacht Code, as an equivalent to the International Convention for the Safety Of Life At Sea, 1974, under the terms of IMO Circular SLS.14/Circ.523, dated 16 September 2013, as a “yacht engaged in trade as a commercial vessel (12 passengers max)”
UNQUOTE
Launching Appliances - Replacement Intervals for Synthetic Fibre Rope Falls
(REG-UI 005)
The provision for the use of synthetic fibre rope falls and this REG-UI regarding their replacement intervals is limited to those vessels certificated in accordance with the REG Yacht Code only.
The REG has concluded than an extension of the renewal interval to no more than 24 months in order to align with the annual attendance by Surveyors is considered appropriate, subject to compliance with the criteria outlined below.
Synthetic fibre rope falls shall be designed with a Factor of Safety on the basis of the maximum working load assigned and the ultimate strengths of the materials used for construction. The required Factor of Safety shall be at least 7.5 or in accordance with the Rules of a Recognised Organisation (whichever is higher).
Synthetic fibre ropes including the details of any splicing and terminal connections shall comply with the requirements of a Recognised Organisation, be certified accordingly and be suitable for the specific application for which they are proposed.
The weekly and monthly tests and inspections as required by Regulations 20.6 and 20.7 of SOLAS Chapter III shall be carried out onboard under the direction of a senior ships officer.
The thorough examination of synthetic fibre rope falls for man riding launching appliances (both LSA and non-LSA) shall be undertaken by an Authorised Service Provider in accordance with the applicable requirements of IMO Resolution MSC.402(96).
In lieu of compliance with the above paragraph, launching appliances installed onboard vessels of less than 500GT may be dealt with in accordance with the provisions of Part A, 13.4 (3) (g) of the REG Yacht Code (2024 Edition).
The inspection of launching appliances including their synthetic fibre rope falls during periodical surveys shall be dealt with by the attending Surveyor in accordance with standard survey procedures.
Synthetic fibre rope falls shall be replaced at intervals specified either by the manufacturer, the Rules of the applicable Recognised Organisation or 24 months, whichever is less. It shall, however, be noted that the aforementioned provisions are subject to ensuring that no defects are identified during the periodical inspection regime outlined above that would require their replacement any sooner.
Where replacement intervals are based on the number of operating cycles, records of the same shall be maintained and kept onboard as part of the mini-ISM or ISM system as applicable.
Disapplication of requirements of the 2024 Edition of the REG Yacht Code
(REG Yacht Code Guidance Information 2024/1 Amendment 03)
REG has taken the decision to disapply the following requirements of the 2024 Edition of the Code to those vessels, whose contract for construction is signed prior to 01 January 2027, or, in the absence of a building contract, the keel of which is laid, or the vessel is at a similar stage of construction prior to 01 January 2027:
Stability Criteria: Stability criteria for vessels with openings in the hull, the lower edge of which is less than 600mm above the uppermost load line and floodable tender garages (Part A, Chapter 11, sections 11.5 & 11.6 refer).
Refer to section 2 of the REG Yacht Code Guidance Information 2024/1 Amendment 03 for the final set of regulatory amendments to the criteria for vessels with openings in the hull, the lower edge of which is less than 600mm above the uppermost load line including vessels with floodable tender garages.
These amendments shall apply to those vessels, whose contract for construction is signed on or after 01 January 2027 or, in the absence of a building contract, the keel of which is laid, or the vessel is at a similar stage of construction on or after 01 January 2027. However, the early adoption of these amendments, either partial or in full, is recommended.
Following the inspection of several sub 500GT yachts specifically to examine the technical feasibility of installing structural fire protection in tender garage spaces and larger lockers containing Personal Watercraft (PWC’s), due consideration being given to the damp and sometimes wet environment within such spaces and a further review of incident data in relation to fires in such spaces, the REG has taken the decision to remove the following requirement from the 2024 edition of the Code:
Fire Safety: Vessels of less than 500GT - Passive fire protection for enclosed spaces containing vehicles with petrol in their tanks (Part A, Table 14A.1 and 14A.2 (3) (b) refer).
Spaces containing lithium-Ion batteries in isolation or lithium-Ion batteries in combination with petrol shall still need to be provided with passive fire protection in accordance with the requirements of the REG Yacht Code 2024, Part A, Chapter 14A, Table 14A.1 and MGN 681 (M) Fire Safety and storage of small electric powered craft on yachts.
Heliports on Large Yachts
(REG-GN 001 Rev.1)
Aviation Inspection Bodies (AIBs) are approved by the UK Maritime and Coastguard Agency (MCA), under the authority of the UK Department for Transport (DfT). AIBs are authorized to conduct yacht heliport inspections and certification against the requirements of the REG Yacht Code (YC) Annex H – ‘Helidecks’.
The ROs have authority to approve aspects of the yacht heliports which are relatively routine for them, such as shipboard heliport structural strength and fixed firefighting systems.
The full division of work between AIBs and ROs is as per the delegation matrix in Annex 1 to this Guidance Note REG-GN 001 (attached file).
Any ‘equivalent arrangements’ to prescriptive requirements must be supported by a robust technical justification which is supported by the AIB and/or RO, in order to receive Flag approval. AIBs and ROs should not be involved in prescribing any mitigation measures, this is the responsibility of the builder/designer or operator, who should seek advice from an independent expert when necessary. Each REG Administration with have their own template for an ‘equivalent arrangement application form’; the AIB or RO, as appropriate, will submit to Flag for approval.
For a newbuild project, the AIB will issue a ‘Helideck Landing Area Technical Certificate (HLATC)’ to the yacht builder when they are satisfied with the shipboard heliport’s physical characteristics and associated hardware under their direct purview as well as the matters being dealt with by the RO.
Code on Noise Levels on Board Ships
Interpretation: Ch. 6 Acoustic Insulations between Accommodation Spaces
Further to email dated 11/07/2017, the Administration agrees the following interpretations:
Public spaces and Offices:
- Rw45 is required to the boundaries between public spaces and cabins/hospitals.
- “Offices” are not categorized as “Public Spaces”, but may be regarded as “Accommodations” in accordance with SOLAS Chap. II-2/ Reg.3.1 which defines each spaces.
Category of Stairways/staircases/elevator:
Stairways/staircases/elevator should not be categorized as corridor, and then the airborne sound insulation for bulkheads between cabins and stairways/elevator are NOT required.The Administration agrees the code does not require sound insulation in this case, but the maximum noise levels (dB(A)) required for cabins in section 4.2 of the Code must be followed.
Concealed or inaccessible space:
As to concealed or inaccessible space behind lining, the airborne sound insulation for bulkheads and decks are NOT required.
Extended periods out of services - Lay up
Refer to Guidance Notice 2019-05 in attached file “Guidance Notice 2019-005.pdf”.
Electronic Log and Record Books
(Guidance Notice 2019-07)
(Item 3.6 & 4.4 addendum A of Appendix 1 to the Agreement in attached files)
This Guidance Notice is issued to provide guidance on the use of electronic record keeping systems, including log books and record books, on board ships registered in Bermuda.
Recognised Organisation (RO) may approve e-record books and issue declarations in accordance with the Guidance Notice.
For further information, refer to attached file “Guidance Notice 2019-017 - Electronic Log Books”.
Ship Recycling and IHM
(Shipping Guidance Notice 2020-12)
Hong Kong Convention
Recognised Organisation (RO) is fully authorized for survey and issuance of:
International Certificate on Inventory of Hazardous Materials
International Ready for Recycling Certificate
As the Hong Kong Convention is not yet entered into force, Recognised Organisation (RO) shall issue a Statement of Compliance under the name of Recognised Organisation (RO).
Regulation (EU) No 1257/2013
Recognised Organisation (RO) if fully authorized to survey ships and issue voluntary Statement of Compliance on Inventory of Hazardous Material (non-EU flag) on behalf of the Flag.
Marine Equipment - Acceptance of Testing Standards
(Shipping Guidance Notice 2022-01)
Equipment to be used on UK flagged ships must, after 1st January 2023 be approved in accordance with MSN1874.
The Administration will continue to accept the use of equipment on board Bermuda registered ships as follows:
Equipment approved to the standards outlined in the SOLAS Convention or its affiliate Codes and Circulars must be approved by an REG Flag State (Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, Isle of Man, UK) or one of the Recognised Organisations appointed by Bermuda (ABS, Recognised Organisation (RO), Class NK, DNV, LR, RINA).
Equipment approved in accordance with the requirements of the EU Marine Equipment Directive.
Equipment approved in accordance with the requirements of the UK conformity assessment procedures as detailed in MSN 1874.
PR17 reports
PR17 reports issued by Recognised Organisation (RO) are to be submitted to the Administration at survey@bermudashipping.bm, after their validation by the MO, with copy to c-r_stat@bureauveritas.com, yannis.calogeras@bureauveritas.com and gbr_clo@bureauveritas.com.
Small Commercial Vessels
Recognised Organisation (RO) Newcastle should be contacted when a request for such a code survey is received.
MODU
Mobile Offshore Drilling Units (MODU) are included in the definition of ships under Bermuda Merchant Shipping legislation and hence must comply with National Merchant Shipping legislation including the Load Line Regulations. Stability information complying with Chapter 3 (para 3.1 to 3.3) of the 1979 or 1989 MODU Codes is acceptable as an equivalent provision to the requirements of paragraph 2(2) of Part 1 of Schedule 2 to Merchant Shipping Notice 1752 (or subsequent amendment), which forms an integral part of the Load Line Regulations.
The issue of the Load Line Certificate will be governed by the requirements of the Load Line Regulations, as amended. The certificate will however be suitably endorsed to indicate that the requirements of the Load Line Regulations have been met by the application of the relevant sections of the MODU Code.
The Administration should be consulted where an interpretation of the MODU Code requirements is necessary. The Administration in turn will advise other ROs on these interpretations to ensure there is uniformity of application.
The Administration will retain responsibility for granting exemptions from specific requirements. Application for such applications for exemptions by the owner should be supported by Recognised Organisation (RO).
For surface units and self-elevating units a dead-weight survey is to be conducted at intervals not exceeding 10 years. Where the dead-weight survey, or any other source, indicates a change from the calculated light ship displacement in excess of 1% of the operating or afloat displacement for surface units and self-elevating units an inclining test is to be conducted. The Recognised Organisation (RO) surveyor at each survey required by the Load Line Regulations, as amended should ensure that no structural changes have been carried out that may affect the displacement and/or waterplane area of the unit at any particular draft.
Hydrostatic particulars and tank inertia (or free surface moments) are to be calculated for, and capable of derivation about, the axis of inclination of the inclining test.
When wind tunnel test results are to be used, calculated wind heeling moments must also be submitted to Recognised Organisation (RO). Where the wind tunnel test results in a higher wind heeling moment than from calculation the higher wind heeling moments are to be used. Where the wind tunnel test results are lower than the calculated wind heeling moments a mean value between the calculated and wind tunnel test moments is to be used.
Where an alternative stability criteria is proposed the Administration shall be consulted.
UWILD
The Administration do not accept the “Alternative Approach By Inspection From Inside the Hull”. However, the Administration accepts substitution of the required dry docking inspection of the underwater parts for UWILD (with divers/ROV’s).
Bridge visibility exemption
The Administration does consider exemptions for restricted bridge visibility on offshore vessels such as drill ships, FPSO’s and MODU’s etc. Each case is considered individually and in applying for an exemption against Regulation 22, or indeed any other regulation under SOLAS Chapter V, the Administration expects to be contacted directly by the owner/manager with supporting documentation for the exemption.
In the case of restricted bridge visibility such documentation normally takes the form of a plan and profile showing the blind sectors and details of what actions the vessel is taking to mitigate any risk.
Such actions may include the provision of a radar in front of the obstruction or CCTV cameras which can be viewed by the watch officers on the bridge. Additionally the Administration expects extra personnel, in contact with the Bridge, positioned so as to see ahead of the obstruction at all times when the unit is in transit.
ISM Code
Authorizations and Instructions
| Ship type | PS | PH | PR | BC | OT | CT | GC | CH | CS | MO |
Document of Compliance | ||||||||||
| Interim | ||||||||||
| Initial | ||||||||||
| Periodical | ||||||||||
| Additional | ||||||||||
| Renewal | ||||||||||
Safety Management Certificate | ||||||||||
| Interim | ||||||||||
| Initial | ||||||||||
| Intermediate | ||||||||||
| Additional | ||||||||||
| Renewal | ||||||||||
Note: | Recognised Organisation (RO) issues voluntary certificates only. The Administration will consider when conducting their own verification. Case by Case. | |||||||||
| Requirements of the Administration | Action by |
|---|---|
| Recognised Organisation (RO) submits voluntary certificates to the Administration. | DO-FM |
| Recognised Organisation (RO) submits copy of audit report to the Administration. | DO-FM |
| Statutory certificates issued by the Administration. | Administration |
| Fax No. 1238 dated 22/10/1996. Implementation of Chapter IX of SOLAS for the safe operation of ships. |
Specific requirements
When Recognised Organisation (RO) is authorized to do audits, a fire and/or abandon ship drill should be conducted as part of the audit.
Cyber Security
(Guidance Notice 2020-14)
Resolution MSC.428(98) requires cyber risks to be considered and anticipated through the ISM Code and for such an assessment to be completed and documented within the SMS by the first Document of Compliance verification after 1st January 2021.
ISPS Code
Authorizations and Instructions
| SSP approval / review | Ship audit | ISSC issuance |
|---|---|---|
| No | Yes | No |
Observation(s): BSMA authorises named individuals to undertake the initial audit on specific cargo ship o.b.o. BSMA. Contact: Bermuda Shipping and Maritime Authority: Tel: +1441 294 5818, 24hrs: +1441 799 7251, email: survey@bermudashipping.bm | ||
| Note: ISPS audits on-board Bermuda Registered ships are only delegated on a case by case basis as these are normally conducted in conjunction with a Flag State Inspection by BSMA surveyors. | ||
| Item | Specific requirements | Observation(s) |
|---|---|---|
| Language required | ||
| MSA qualification | In accordance with IACS. | |
| SSP approval / review | Only by BSMA (Bermuda Adminis- tration). | Approved SSP may be reviewed by MSA before audit. |
| Minimum period of SSP implementation on board | ||
| SSA and SSP according to specific template | ||
| Part B mandatory | ||
| SSP amendments | ||
| CSO / SSO training | ||
| ISSC issuance | By BSMA. | BSMA issues after receiving audit report + Bermuda declaration. |
| Annex to ISSC (related to Part B) | ||
| Audit reports submission to Administration | ||
| Minimum period for filing records | ||
| Ship Security Alert System (SSAS) | For SSAS testing and EPIRB Registration:
| Refer to Guidance Notice 2026-02 |
| Document of reference | Fax SP 8/21 dated 04/03/04. | |
Specific requirements
When Recognised Organisation (RO) is authorized to do audits, a fire and/or abandon ship drill should be conducted as part of the audit.
Appendix — Agreement governing the delegation of statutory certification services
Agreement
Refer to the attached file “Agreement_Bermuda_RO_01032021”.
Definitions
Refer to the attached file “Appendix 3_Bermuda_RO”.
Appendix — Annex 1 to the Agreement
Applicable instruments and degree of authorisation
Refer to the attached file “2025-11 Bermuda RO Agreement - Appendix 1 - Recognised Organisation (RO) signed”.
Appendix — Annex 2 to the Agreement
Reporting to the Administration
Refer to the attached file “Appendix 2_Bermuda_RO”.
Appendix — Annex 4 to the Agreement
List of current Recognised Organisations
Refer to the attached file “Appendix 4_Bermuda_RO”.