Page 21: of Maritime Reporter Magazine (February 2004)

Government Update

Continuous Synopsis Record

Dennis L. Bryant, Senior Maritime

Counsel at the law firm of Holland & Knight, Washington, D.C., is a contributing editor of MR/EN.

One of the numerous provisions in the December 2002 amendments to the International Convention on the Safety of Life at Sea (SOLAS Convention) requires ships subject to the Convention to maintain a continu- ous synopsis record as of July 1, 2004. All is not going smoothly though. Owners and operators should pre- pare to take individual action prior to the deadline.

The continuous synopsis record is intended to pro- vide an on-board record of the history of the ship. The record is to be issued by the flag administration and is to contain: a. The name of the nation whose flag the ship is entitled to fly; b. The date on which the ship was registered with that nation; c. The ship s identification number; d. The name of the ship; e. The port at which the ship is registered; f. The name(s) of the registered owner(s) and their address(es); g. The name(s) of the registered bareboat charterer(s) and their address(es), if applicable; h. The name of the company for purposes of the International

Safety Management (ISM) Code, along with its address and the address from which it carries out its safety-management activities; i. The name of all classification societies with which the ship is classed; j. The name of the administration, contracting government, or recognized organization that issued, under the ISM Code, the

Document of Compliance to the company operating the ship and

Circle 216 on Reader Service Card 18 the name of the body that conducted the audit on which the

Document was based; k. The name of the administration, contracting government, or recognized organization that issued, under the ISM Code, the

Safety Management Certificate to the ship and the name of the body that conducted the audit on which the Certificate was based;

I. The name of the administration, contracting government, or recognized security organization that issued, under the

International Ship and Port Facility Security (ISPS) Code, the

International Ship Security Certificate (ISSC) to the ship and the name of the body that conducted the verification on which the

ISSC was based; and m. The date on which the ship ceased to be registered with that nation.

Any changes relating to entries in the continuous syn- opsis record are to be made by the flag administration within three months and provided to the ship so that the information remains current. In the interim, until the revisions issued by the flag administration have been received, the company or the master may be authorized and required to amend the continuous synopsis record to reflect the changes. In such cases, the company is to, without delay, inform the flag administration of the amendments.

The continuous synopsis record is to be in English,

French, or Spanish, as well as the official language of the flag administration. The record is to be maintained in the format developed by the IMO and maintained in accordance with IMO guidelines. Entries may not be deleted, modified, erased, or defaced. The record is to remain on board the ship when it is transferred to another flag, sold to a new owner (or taken over by a new bareboat charterer), or when another company assumes responsibility for operation of the ship.

When the ship is to be transferred to the flag of another nation, the company is to notify the current flag administration so that it can forward to the new flag administration a copy of the current continuous synopsis record. The new flag administration is to append the old continuous synopsis record to the new one that it issues to the ship.

The continuous synopsis record is to be kept on board the ship and made available for inspection by govern- ment officials at all times.

Like the ISPS Code and related maritime security measures, this requirement is a large undertaking and little time is afforded for its implementation. The IMO has yet to officially issue a format in which the record is to be developed, nor has it issued guidelines explain- ing how the record is to be maintained. Few, if any. flag administrations have yet issued their own guid- ance. although the Netherlands has developed an appli- cation form. Otherwise, flag administrations have not established procedures for collection of information required to be in the continuous synopsis record that is not already routinely collected and maintained.

The U.S. Coast Guard has stated that it will comply with the IMO format once it has been adopted. The agency intends to issue a continuous synopsis record before July 2004. The currency of the information will be based primarily on the information provided by the owner or operator. The Coast Guard goes on to state that sanctions can be imposed for any inaccurate infor-

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