} Comoros Maritime Circular Ref No. 20/01855/COM3 on COVID-19 – Guidance relating to the postponement /extension of statutory certification & services

Technical Circular No :116/2020

Subject: Comoros Maritime Circular Ref No. 20/01855/COM3 on COVID-19 – Guidance relating to the postponement /extension of statutory certification & services

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  1. The Maritime Administration of Comoros vide Circular Ref No. 20/01855/COM3 has provided following guidance relating to the postponement/extension of statutory certification and surveys including ISM / ISPS and MLC audits/ inspections as an exceptional measures in view of outbreak of COVID-19 pandemic.

    a. Where a surveyor is not able to undertake scheduled surveys due to restrictions imposed by COVID-19, Recognized Organizations to request authorization for issuance of a Conditional Certificate valid for three (3) months using remote surveys, provided all relevant records and justifications are reported to the Administration.

    b. In case of annual servicing of life saving appliances and firefighting equipment expiring between September and November 2020, application is to be made via RO for extension for a maximum of three (3) months period, submitting also an official statement by the Master of the ship that the equipment is in good operational condition.

    c. Vessels holding a Conditional Certificate due to deficiencies or damages onboard, which cannot be rectified or corrected, shall in coordination with their RO communicate with the Administration for further guidance.

    d. All statutory certificates (except for Conditional Certificates) expiring between September and November 2020 will exceptionally be extended for a period of three (3) months including DOC/SMC/ISSC/MLC and Exemption Certificates, subject to RO’s acceptance and in coordination with it.

    e. The postponement/ Extension of the inspection of the outside ship’s bottom will continue to be processed on a case by case basis. Inspections afloat using remote inspection techniques might be allowed under exceptional circumstances. Extensions beyond three (3) months may require a Risk Assessment approved by the RO, including mitigation measures.

    f. An extension for a period of three (3) months from the below indicated deadlines will be granted by the Administration for the following regulations of MARPOL Convention /Annex VI;

    i. The notification of fuel oil consumption data within  a period of three months from the end of each calendar year (Reg. 22A.3), whose deadline was 31st March 2020;

    ii. The issuance of the Statement of Compliance related to the ships fuel consumption data reports (Reg. 6.6), whose deadline was on 31st May 2020;and

    iii. The report of the fuel oil consumption data of the ships, after the issuance of the Statement of Compliance of said ships (Reg.22A.9), whose deadline was on 30th June 2020.

    g. The validity of colour copies of Original Certificates as per Administration’s Circular 18/01165/COM, issued as of September 2020 and afore, to be considered valid for a three (3) months period. 

  2. The measures stated above is effective immediately. However, the attached circular will not apply once the current crisis due to the pandemic is overcome and the RO consider as safe and risk-free to perform the relevant surveys/audits.

  3. Ship owners/ operators and masters of Comoros flagged ships are advised to be guided by above.

  4. This Technical Circular supersedes and revokes earlier Technical Circular No. 092/2020, dated 25th June 2020.



This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority. 

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