Maritime

Clarification on the use of service providers of LSA equipment

IMO Resolution MSC.402(96) for the maintenance, thorough examination, operational testing, overhaul and repair of LSA equipment has been in force since 1 January 2020. There are, however, still challenges and unclarities in the adoption of its requirements. This statutory news aims to further clarify DNV’s interpretation of this regulation.

Clarification on the use of service providers of LSA equipment

Relevant for suppliers, ship owners and managers.

The main purpose of IMO Resolution MSC.402(96) is to establish a uniform, safe and documented standard for the maintenance, thorough examination, operational testing, overhaul, and repair of lifeboats and rescue boats, launching appliances, and release gear. Some aspects of the regulations have been clarified within IACS with Revision 14 of UR Z17, and others are still under discussion. Below are recommendations on how to comply with these regulations. Our Technical and Regulatory news No. 18/2019 also discussed IMO Resolution MSC.402(96).

Service provider (or supplier) authorization

Annual and 5-yearly thorough examination, operational testing, overhaul, and repair of LSA equipment shall be undertaken either by the original equipment manufacturer (OEM) or an authorized service provider / approved service supplier. This provider or supplier shall be authorized/approved by a flag administration or Recognized Organization (RO) and shall hold an Approval of Service Supplier (AoSS) certificate for the make and type* of the equipment installed on board. The AoSS certificate shall be issued under the service provider’s name or, if another company carries out the servicing, this has to be listed as the subsidiary (company partly or wholly owned by the service supplier) on the AoSS certificate for the parent company.

Personnel certification and employment

A company undertaking the servicing shall employ technicians certified by either the OEM or the company itself for the make and type of equipment installed on board. According to Revision 14 of the IACS UR Z17, an approved service supplier can certify their own personnel only (i.e. employed by the same service supplier) unless the flag administration accepts otherwise. DNV also accepts personnel employed by a subsidiary of the company, but not by agents (person or company authorized to act for or to represent the approved/ recognized service supplier).

DNV acceptance criteria

DNV has experienced cases where the servicing has been undertaken by a service provider (Company A) not authorized/approved for a given make and type of equipment, but the reports and statements left on board were issued by another service provider (Company B) holding the authorization/approval for the make and type in question. This is not acceptable, as Company A should be authorized/approved for the equipment make and type being serviced, or alternatively be listed as a subsidiary in the AoSS of Company B.

In other cases, it has been found that Company B provides training and also certifies personnel employed by Company A for the make and type of equipment, whereby Company A is not authorized/approved for and Company B is not the OEM. Although it is in general acceptable that Company A makes use of an external training provider for education and training, it is not acceptable for Company B to certify personnel employed by Company A. It is also not acceptable if Company B employs personnel from Company A on a temporary basis, since they would be considered agents.

Recommendations

We recommend customers consider the above interpretations for the use of service providers and be aware of DNV’s acceptance criteria. Nevertheless, we want to emphasize that any flag-specific requirement and interpretation, that differs from those of DNV, shall prevail.

References

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