Bahamas: Guidelines for passenger ship bottom inspections

The Bahamas Maritime Authority (BMA) issued revised Marine Notice 75 providing comprehensive guidelines for the inspection and maintenance of passenger ship hulls, specifically providing the option to conduct an In-Water Survey (IWS) instead of traditional dry-docking under certain conditions.

1. General Overview and Objectives

Marine Notice 75 aims to provide a structured pathway for operators of passenger ships to apply for in-water inspections rather than a dry-dock survey. The traditional method of dry-docking involves moving the vessel to a shipyard, where it is lifted out of the water, allowing for comprehensive checks of the hull and other underwater parts. IWS is an alternative that, if implemented under stringent conditions, enables vessels to undergo inspection while remaining afloat, offering operational continuity and potentially reducing downtime.

The goal is to balance the operational benefits of IWS with rigorous standards that ensure the safety and integrity of the vessel, safeguarding both passengers and the environment. This notice addresses the procedures, requirements, and eligibility criteria for IWS applications, with specific protocols based on vessel age.

2. Eligibility and Conditions Based on Vessel Age

Marine Notice 75 outlines specific eligibility criteria for vessels based on age, with requirements increasing as the vessel's age advances:

Ships Under 15 Years: These vessels are generally in better structural condition, so they may apply for an IWS once within a five-year period if they meet all other regulatory requirements. Operators must demonstrate that they have maintained high standards in hull integrity, ballast tank coating conditions, and have conducted periodic hull thickness measurements.
Ships Aged 15-20 Years: Ships in this category are subject to more stringent regulations, requiring advanced maintenance capabilities. This includes having systems in place to replace critical parts like stern tube seals, rudder bearings, and propeller shaft equipment without dry-docking. Additionally, these vessels are required to have routine maintenance records on hand, proving that critical components have been well-maintained to prevent safety issues during IWS.
Ships Over 20 Years: For ships older than 20 years, IWS is generally restricted. However, the new provisions in Marine Notice 75 allow these ships to undergo one in-water inspection every five years instead of dry-docking, but only if they pass a thorough “ship-specific study.” This study must be conducted by a Recognised Organisation (RO) and include detailed evaluations of the ship's loading and structural integrity, previous survey records, and maintenance practices. The BMA requires documentation of the ship’s trading routes and maintenance history, as well as an assessment of the hull structure and internal ballast tanks.

3. Application Process and Requirements

Ship operators interested in IWS must submit an application at least four weeks before the planned inspection date. The application must include comprehensive documentation covering:

A structural assessment of the hull condition
Proof of adherence to scheduled maintenance protocols
Confirmation of compliance with international standards for safety and stability
Any records or history of structural issues or repairs that could impact safety during an in-water inspection

The BMA requires assurance that the vessel's condition does not compromise its seaworthiness or safety standards. Any issues identified during the IWS that impact safety must be reported immediately to the BMA.

4. Diving and Inspection Protocols

Marine Notice 75 specifies stringent conditions for in-water surveys, including standards for the diving company, water conditions, and communication during the inspection. Key guidelines include:

Approved Diving Companies: Only certified diving companies with experience in maritime inspection are permitted. These companies must use approved equipment and operate under conditions ensuring the accuracy of visual and photographic evidence.
Visibility and Water Conditions: Inspections must occur in clear, calm waters with good visibility to ensure the accuracy of observations and to reduce risks to divers. The area surrounding the vessel should be free from debris, strong currents, and other conditions that might hinder visibility or inspection quality.
Communication Protocols: Constant communication between divers and onboard personnel is essential. Any critical findings or areas of concern must be relayed immediately. The BMA also mandates that clear video or photographic documentation of the hull’s condition be provided as part of the inspection record.

5. Responsibilities of Recognised Organisations (ROs)

Recognised Organisations play a pivotal role in ensuring that IWS procedures meet the standards outlined in Marine Notice 75. Their responsibilities include:

Pre-inspection Surveys and Documentation: ROs must thoroughly review all available documentation on the vessel, including maintenance records, previous survey results, and structural integrity reports, before approving an IWS application.
Onsite Supervision and Monitoring: During the IWS, ROs may provide onsite personnel to monitor the inspection, ensuring compliance with procedural standards. They are responsible for promptly communicating any findings that may affect the vessel’s safety.
Reporting to the BMA: ROs must report any findings related to hull condition, stability, or structural integrity to the BMA. This ensures that the maritime authority is informed of any potential risks and can enforce corrective actions if necessary.

6. Additional Safety and Structural Requirements

Marine Notice 75 mandates extra safety and structural considerations, particularly for older ships. Vessels must demonstrate that:

All necessary hull reinforcements and repairs have been made, especially if signs of corrosion or wear are present.
Critical areas, such as ballast tanks, are well-maintained, with anti-corrosion coatings in good condition.
If the IWS reveals any areas of concern, additional inspections or repairs may be required, possibly necessitating a follow-up dry-dock inspection.