Seven HSSC survey types, the anniversary window, where the new period starts by renewal timing and how an extension is counted (Resolution A.1120(30))

The certificates under SOLAS, Load Lines, MARPOL, the Ballast Water Management Convention, the IBC, IGC and BCH Codes and the Polar Code run on one clock. That is the harmonized system of survey and certification (HSSC). Resolution A.1120(30) is the survey guidelines under that system, adopted to reflect the amendments in force up to 2017.

The guidelines are recommendatory. The Assembly “invites” Governments to apply them when carrying out surveys. But the windows and starting points the guidelines spell out come from the provisions of each convention, and the guidelines attach those regulation numbers one by one. This article takes the common clock out of chapters 1 to 5. The seven survey types, the window of 3 months either side of the anniversary date, where the new period starts by renewal timing, and extensions and what follows them.

The date arithmetic is run once at the end on a hypothetical example.

There are seven survey types and only the renewal survey creates a new certificate

(R) 2.3 A renewal survey is the same as a periodical survey but also leads to the issue of a new certificate.

(In) 2.4 An intermediate survey is an inspection of specified items relevant to the particular certificate to ensure that they are in a satisfactory condition and fit for the service for which the ship is intended.

(A) 2.5 An annual survey is a general inspection of the items relating to the particular certificate to ensure that they have been maintained and remain satisfactory for the service for which the ship is intended.

(Ad) 2.7 An additional survey is an inspection, either general or partial according to the circumstances, to be made after a repair resulting from investigations or whenever any important repairs or renewals are made.

Code	Survey	What it looks at
I	Initial survey	Complete inspection of all items for the certificate before the ship enters service
P	Periodical survey	Inspection of the items for the certificate to confirm satisfactory condition
R	Renewal survey	Same as a periodical survey, but leads to a new certificate
In	Intermediate survey	Inspection of specified items relevant to the certificate
A	Annual survey	General inspection to confirm the items have been maintained
B	Inspection of the outside of the ship’s bottom	The underwater part of the ship and related items
Ad	Additional survey	General or partial inspection after a repair from investigations or any important repairs or renewals

The definition of the renewal survey is the key. In content it is the same as a periodical survey. The only difference is that a new certificate comes out. The other surveys are endorsed on a certificate that already exists. The guidelines put a certificate code and a survey code in front of each item. (EI) is the initial survey for the Cargo Ship Safety Equipment Certificate, (OIn) the intermediate survey for the IOPP Certificate, and (PR) the renewal survey for the Passenger Ship Safety Certificate (3.8).

Annual, intermediate and periodical surveys run inside a window of 3 months either side of the anniversary date

.2 a scheme providing the necessary flexibility to execute each survey, with provision for: .1 completion of the renewal survey within three months before the expiry date of the existing certificate with no loss of its period of validity; and .2 a “time window” of six months – from three months before to three months after the anniversary date of the certificate for annual, intermediate and periodical surveys;

The standard interval of the system is one year (1.3.1). On top of it sits a six-month window. From 3 months before to 3 months after the anniversary date of the certificate. The annual survey is held in the window of each anniversary date (4.2.1).

The intermediate survey, as required by the relevant regulations (see 2.8.4) and as shown diagrammatically in appendix 2, should be held within three months before or after the second anniversary date or within three months before or after the third anniversary date of the appropriate certificate and should take the place of one of the annual surveys.

The intermediate survey is held in either the window of the second anniversary date or the window of the third, and takes the place of that year’s annual survey (4.3.1). The two windows are not joined. The six months from 3 months after the second anniversary to 3 months before the third are not a window. The periodical survey sits in the same place. For the Cargo Ship Safety Equipment Certificate it is held in the window of the second or third anniversary date, and for the Cargo Ship Safety Radio Certificate in the window of each anniversary date (4.4.1).

The intermediate survey for the Cargo Ship Safety Construction Certificate is one of the changes the HSSC brought in. The guidelines list those changes in 1.4. Unscheduled inspections dropped and annual surveys became mandatory for cargo ships, the periodical surveys for the safety equipment certificate alternate between two and three years, and all cargo ship certificates may be issued for any period up to five years.

A renewal survey completed within 3 months before expiry loses no validity

The first item of 1.3.2 fixes where the renewal survey goes. Complete it within 3 months before the expiry date of the existing certificate and no validity is lost. That is because the new certificate counts five years from the existing expiry date, not from the day the survey was completed. The guidelines repeat the same point from another angle in 5.2. The new certificate issued after the renewal survey dates from the five-year expiry of the existing certificate, and the corresponding provisions of SOLAS, the Load Line Convention, each MARPOL annex and each code are listed side by side.

The cargo ship safety construction renewal survey may be commenced at the fourth annual survey and may be progressed during the succeeding year with a view to completion by the fifth anniversary date. The survey items of the fourth annual survey should not be credited to the completion of the renewal survey.

A renewal survey is not a one-day survey. The renewal survey for the Cargo Ship Safety Construction Certificate may be commenced at the fourth annual survey, progressed through the following year and completed by the fifth anniversary date (4.5.1). The items of the fourth annual survey are not credited to the completion of the renewal survey, though. Crediting the survey of the same spaces to both the intermediate and the renewal survey is not acceptable either (4.5.2.3).

Where a certificate has been issued for a period of less than five years, it is permissible under these regulations or article to extend the certificate so that its maximum period of validity is five years provided that the pattern of surveys for a certificate with a five-year period of validity is maintained (see appendix 2).

A certificate issued for less than five years can be extended to five years. The condition is that the pattern of surveys for a five-year certificate is maintained. The examples in the guidelines are concrete. Extending a two-year Cargo Ship Safety Equipment Certificate to five years requires one more periodical survey and two more annual surveys, and extending a four-year Cargo Ship Safety Construction Certificate to five years requires one more annual survey (5.2).

An extension is 3 months to complete a voyage or 1 month for short voyages, and the new certificate counts from the expiry date before the extension

.5 a system for the extension of certificates limited to three months, enabling a ship to complete its voyage, or one month for ships engaged on short voyages; .6 when an extension has been granted, the period of validity of the new certificate starting from the expiry date of the existing certificate before its extension;

There are two extensions. The extension that lets a ship complete its voyage runs up to 3 months, and the period of grace for ships engaged on short voyages up to 1 month. The guidelines note in 1.4.8 that these figures changed with the HSSC. The voyage-completion extension came down from five months to three, and the one-month grace period was limited to ships on short voyages.

For the purpose of these regulations or article, a “short voyage” means a voyage where neither the distance from the port in which the voyage begins to the final port of destination nor the return voyage exceeds 1,000 miles.

The definition of a short voyage is in 5.4. A voyage where neither the distance from the port of departure to the final port of destination nor the return voyage exceeds 1,000 miles. If either leg exceeds it, the voyage is not a short voyage.

5.9.1 In SOLAS 74/88 and other mandatory IMO instruments the following provision applies: If a ship at the time when a certificate expires is not in a port in which it is to be surveyed, the Administration may extend the period of validity of a certificate but this extension should be granted only for the purpose of allowing the ship to complete its voyage to the port in which it is to be surveyed, and then only in cases where it appears proper and reasonable to do so. No certificate should be extended for a period longer than three months, and a ship to which an extension is granted should not, on its arrival in the port in which is to be surveyed, be entitled by virtue of such extension to leave that port without having a new certificate.

The 3-month extension has three conditions. The ship is not in the port where it is to be surveyed when the certificate expires, the purpose is to let it complete the voyage to that port, and doing so appears proper and reasonable. On arrival at that port the ship cannot leave without a new certificate. Where the extension is granted in a port where the survey cannot be completed, 5.9.2 adds conditions. An additional survey of at least annual-survey scope, the renewal survey to the maximum extent possible, an underwater inspection where dry-docking cannot be done, direct sailing to a named discharge port and a named survey port, and an extension of the minimum time needed to complete the survey are among them.

Once an extension has been granted, the new certificate starts from the expiry date before the extension (1.3.6). Time bought by the extension comes out of the next five years.

Running the date arithmetic once on a hypothetical example

Suppose a Cargo Ship Safety Construction Certificate expires on 15 June. The anniversary date is 15 June each year, and the annual survey window runs from 15 March to 15 September each year.

• Annual surveys are held in the windows of the first and fourth anniversary dates.
• The intermediate survey is held in either the window of the second anniversary or the window of the third, and takes the place of that year’s annual survey. If it was done in the second-anniversary window, the third-anniversary window takes an annual survey.
• The renewal survey may start at the fourth annual survey. If it is completed between 15 March and 15 June, the 3 months before the fifth anniversary, the new certificate counts five years from 15 June. No validity is lost.
• If the ship was not in the survey port at expiry and got a 3-month extension, the certificate runs to 15 September. If the ship reaches the survey port and completes the renewal survey in that time, the new certificate counts five years from 15 June, the expiry date before the extension. Not from 15 September.
• If the renewal survey was completed after expiry without an extension, the new certificate again counts from the old expiry date. The only exception is where the Administration accepts special circumstances under 5.5.

The purpose of these regulations or article is to permit Administrations to waive the requirement that a certificate issued following a renewal survey that is completed after the expiry of the existing certificate should be dated from the expiry date of the existing certificate. The special circumstances when this could be permitted are where the ship has been laid up or has been out of service for a considerable period because of a major repair or modification.

Special circumstances are where the ship has been laid up or out of service for a considerable period because of a major repair or modification. Only then need the new certificate not be dated from the old expiry date. Even then, the guidelines say, the renewal survey is as extensive as for a ship that stayed in service, and the Administration considers whether additional surveys are needed depending on how long the ship was out of service.

A survey not completed within its window invalidates the certificate, and carrying out that survey restores it

A certificate ceases to be valid if the periodical, intermediate or annual survey, as appropriate, or the inspection of the outside of the ship’s bottom is not completed within the periods specified in the relevant regulation or article. The validity of the certificate should be restored by carrying out the appropriate survey which, in such circumstances, should consist of the requirements of the survey that was not carried out, but its thoroughness and stringency should have regard to the time this survey was allowed to lapse. The Administration concerned should then ascertain why the survey was allowed to lapse and consider further action.

If a periodical, intermediate or annual survey, or the inspection of the outside of the bottom, is not completed within its period, the certificate ceases to be valid. That holds even with time left to the expiry date. The way back is to carry out the survey that was missed. Its scope is the requirements of the missed survey, and it gets stricter the longer the lapse. The Administration then ascertains why the survey lapsed and considers further action (5.6).

Where a survey finds that the condition of the equipment does not correspond substantially with the certificate, corrective action is taken immediately and the Administration is notified. If it is not taken, the certificate is withdrawn, and if the ship is in a port of another Party the port State is notified immediately too (4.8.1). Where the condition does correspond substantially but deficiencies cannot be rectified at the time of survey, a condition with a due date is issued and the information is kept on board (4.8.4).

A transfer of flag invalidates the certificates. The new flag State issues new certificates after satisfying itself that the ship has been properly maintained and that there have been no unauthorized changes. To keep the surveys harmonized, the new Administration may recognize the former Administration’s surveys and issue new certificates with the same expiry date as the ones that ceased to be valid (5.8).

Worth confirming

The passages above come from chapters 1 to 5 of the annex to resolution A.1120(30). This article covers that text only. The guidelines reflect amendments in force up to 31 December 2017. Later editions are checked separately.

• The guidelines are recommendatory. The provisions behind the windows and starting points are in each convention, and the guidelines attach those numbers in chapter 5.
• Not every certificate uses the same clock. The Passenger Ship Safety Certificate has a ceiling of 12 months (1.3.4), and MARPOL Annex IV has only initial and renewal surveys (1.3.1).
• The outside of the bottom is inspected twice in the five-year period, with no more than 36 months between inspections (1.3.7). An extension does not stretch the 36-month limit (5.3).
• The survey items for each certificate are in annexes 1 to 5. This article does not cover those items.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

• IMO · A.1120(30)

Continue with the related operational guidance

• IAPP Certificate survey types, endorsements and validity by renewal timing
• Intermediate inspection window and the renewal split in certificate expiry (MLC Regulation 5.1.3)