Intermediate inspection window and the renewal split in certificate expiry (MLC Regulation 5.1.3)

Two questions have to be answered with the maritime labour certificate in hand. When the intermediate inspection is due, and how long the new certificate runs once the renewal inspection is done. MLC, 2006 Standard A5.1.3 answers both with date rules, and the second answer is a fork. The expiry date changes with when the inspection was completed.

First, whether this is a ship that has to carry the certificate

Regulation 5.1.3 sets the scope in two lines. Ships of 500 gross tonnage or over engaged in international voyages, and ships of 500 gross tonnage or over flying the flag of a Member and operating from a port, or between ports, in another country. International voyage here means a voyage from a country to a port outside that country.

A ship outside that scope can still be brought in at the shipowner’s request to the Member. Ships in by obligation and ships in by request run on the same certificate rules.

The ceiling on validity is five years

Standard A5.1.3 paragraph 1 has the competent authority, or a recognized organization duly authorized for the purpose, issue the certificate for a period not exceeding five years. The list of matters to be inspected before issue is in Appendix A5-I.

Five years is a ceiling, not a fixed value. Paragraphs 3 and 4 further down produce the actual expiry date, and the result can come out shorter than five years.

The intermediate inspection opens between the second and third anniversary dates

If only one intermediate inspection is carried out and the period of validity of the certificate is five years, it shall take place between the second and third anniversary dates of the certificate.

Conditions are attached: this is the rule where only one intermediate inspection is carried out and the certificate runs five years. The definition of the anniversary date follows immediately.

Anniversary date means the day and month of each year which will correspond to the date of expiry of the maritime labour certificate.

The anniversary date is not the day and month of issue but the day and month of expiry. If the certificate expires on 30 June 2032, the anniversary date is 30 June each year, the second anniversary is 30 June 2029 and the third is 30 June 2030. The intermediate inspection falls between them.

The depth is fixed as well.

The scope and depth of the intermediate inspection shall be equal to an inspection for renewal of the certificate.

The scope and depth of the intermediate inspection equal a renewal inspection. It is not an abbreviated check. Completed satisfactorily, it is endorsed on the certificate.

The new expiry date forks on when the renewal inspection was completed

Notwithstanding paragraph 1 of this Standard, when the renewal inspection has been completed within three months before the expiry of the existing maritime labour certificate, the new maritime labour certificate shall be valid from the date of completion of the renewal inspection for a period not exceeding five years from the date of expiry of the existing certificate.

If the existing certificate expires on 30 June 2027, the fork looks like this.

Renewal inspection completed	New certificate valid from	New certificate expires
10 May 2027 (within three months of expiry)	Date the inspection was completed	30 June 2032
20 January 2027 (earlier than three months before expiry)	Date the inspection was completed	20 January 2032

The same ship had the same inspection and the expiry dates differ by more than five months. Complete it within three months of expiry and the existing expiry date is kept as the anchor; complete it earlier and the anchor moves forward to the date the inspection was completed. Pulling the schedule earlier is not always the safe choice.

The case where the new certificate cannot be issued and placed on board straight away is in the provision too. Where the renewal inspection was completed before expiry and the ship is found to continue to meet the requirements, validity may be extended, and endorsed, for a further period not exceeding five months from the existing expiry date. The new certificate’s expiry is then set by the rule in the table above.

An interim certificate runs six months and cannot be chained

There are three cases where an interim maritime labour certificate may be issued: new ships on delivery, a change of flag, and a shipowner assuming responsibility for the operation of a ship that is new to that shipowner. The period may not exceed six months.

No further interim certificate may be issued following the initial six months referred to in paragraph 6 of this Standard.

The route of extending once more on an interim basis is closed. A full inspection under paragraph 1 has to be carried out before the interim certificate expires so the full-term certificate can be issued. A declaration of maritime labour compliance need not be issued for the interim period.

Worth confirming

The passages above come from printed pages 83 to 85 of the consolidated MLC, 2006 (including the 2022 amendments). The dates in the table are worked examples of the rule; the actual expiry date is the one the issuing body writes on the certificate. What day and month the certificate on that ship expires, whether an intermediate endorsement is already on it, and whether the renewal schedule falls within three months of expiry are where the actual judgement starts.