Non-compliance with crew change regulations

03 Jun 2021 / Singapore

All ship agents/managers/owners are strongly reminded and advised to continue to adhere to the prevailing Port Marine Circulars and its related appendices, together with the SG Crew Change Guidebook. You are also strongly advised to relay to your staff, your manning/crewing department, your crew, your masters that they MUST observe and fulfil the compliance and criteria set forth when preparing to undergo crew change in the Port of Singapore.

In the event of a reported incident of a positive Covid19 crew arising from crew change, the MPA will issue:

  • An immediate notice to suspend crew change for ship managers/agents, while MOH/MOT/MPA and Port Heath begin investigations. This usually starts with the crew members. You can be sure that the MOH conducts a VERY EXTENSIVE interview (intensive interrogation, mobile phone checks on BlueTooth/location history etc). This is how Singapore is able to have a very tight and detailed Contact Tracing/Source Tracing mapping.
  • While the investigations are undergoing, the ship agents/manager/owners will need to submit their company’s processes and detailed procedures as to how the company has done its utmost to comply with the criteria as listed in the PMCs and the Crew Change Guidebook…

…we see a trend in the investigation processes for Covid19 positive cases of seafarers, when the papers declared by ship agent/managers/owners stated that all process has been complied with.

Common cases of which a crew does not meet crew change to be conducted in Singapore, are the following broad examples:

  • went ashore (breaching the compliance to not have gone ashore)
  • have interacted and in contact with other parties (and exposed to transmission)
  • did not do proper quarantine prior to sign-on, and was never aware of the SG Crew Change criteria
  • were not informed or aware that they have to comply with the SG crew change criteria…

…It is almost a recurring theme that the majority of the crew’s responses are that crew gave the reason that they were NEVER TOLD or not briefed or not aware by the company, manning agent, ship agent/manager/owner…

We need to one more step further. And that is, to have all ship agent/managers/owners ensure that the crew and master SIGN a declaration that the entire vessel crew is

  • aware, read and understood the criteria and conditions for safe and responsible crew change to be conducted in SG.
  • and that the instructions have been relayed by the master of vessel/shipowner/manning agent to all crew members…

…EVERYONE is responsible. The master who signs the declaration, the crew, the agent, the manager, the shipowner…

…While this may seem tedious and administrative, I do believe that once the master and all crew sign that declaration, the ship agent/managers/owners will have demonstrated that they have done their best. That piece of the declaration must be in English and on the reverse side, in the local language so that the Master and crew members cannot say they do not understand what they were signing. This will also apply equal pressure and responsibility UP and DOWN the entire chain (from individual crew members, the Master who signs the declaration, to the agent/manager/owner who is supposed to brief them)…

…This will at least minimize the anxiety and remove doubts as to whether somewhere down the line, there were breaches or lapses in execution and fulfilling the need for proper education, briefing and instructions to all crew and Master…

(For further details and updates, as well as information about operations in Singapore, contact GAC Singapore at [email protected])

Source: Extract from Singapore Shipping Association (SSA) statement

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