New Compliance on Passenger Vessel that Carries Containers
Authors
General
As we collectively have been aware from the recent updates on the maritime industry, which in this matter, its the activity of transporting containers using the passenger vessels. In response from such developments, the Director General of Sea Transportation (“Seacomm”) has recently issued the Head of Seacomm Circular Letter No. SE-DJPL 16 of 2023 (“Seacomm CL 16/2023”), which stipulates the requirements updates on Indonesian flagged passenger vessel’s seaworthiness, specifically for passenger vessel that carries containers (peti kemas).
With this new circular letter in force, Seacomm aims to ensure the seaworthiness of Indonesian-flagged passenger vessels that are also used for transporting containers, as a safeguard for the passengers on board.
Circular Letter Instruction
Seacomm CL 16/2023 assesses and distinguishes passenger vessels carrying containers based on its construction design. In this regard, if a Passenger Vessel is initially designed and equipped to transport containers, it must comply with the following provisions:
- Certificate/document of seaworthiness of the vessel;
- Classification certification with specific notations for container transport or equivalent from a recognized classification body;[1]
- Stability calculations endorsed by Seacomm or a recognized organization, including the determination of the arrangement of container cargo on the vessel;
- Container transport document in the form of a cargo securing manual approved by Seacomm or a recognized classification body;
- Procedures for loading containers in the ship's safety management system;
- Containers transported must meet container seaworthiness requirements.[2]
On the other hand, Passenger Vessels that are not initially designed and equipped for container transport, in addition to comply with the above requirements, must also comply with the following conditions:
- Modification of the vessel's structure and equipment, accompanied by approved drawings for the purpose of ship reconstruction/modification;
- Change of classification notation on the classification certificate with specific notations for container transport or equivalent from a recognized classification body.
Through the enactment of this circular letter, Seacomm has also instructed the Heads of the Prime Harbourmaster Office (Kantor Kesyahbandaran Utama) and Port Authorities (Otoritas Pelabuhan) to oversee and report on the seaworthiness and activities of Passenger Vessels carrying containers.
Based on the Ministry of Transportation Regulation No. 7 of 2013 regarding the Classification Obligations for Indonesian Flagged Vessel at the Class Institution as amended by the Ministry of Transportation Regulation No. 61 of 2014, Indonesian Flagged Vessel which met the certain criteria must conduct vessel’s class at the national class institutions (PT Biro Klasifikasi Indonesia) or at the approved foreign class institutions (i.e, Nippon Kaiji Kyokai, Korean Register of Shipping, Det Norske Veritas, etc). ↩︎
The provisions regarding container seaworthiness are regulated in the Minister of Transportation Regulation number PM 25 of 2022. ↩︎