Purpose
This bulletin clarifies the position of Tokyo MOU Member Authorities on when statutory certification may be extended under international conventions including but not limited to the International Convention for the Safety of Life at Sea (SOLAS). It describes what we are finding and our actions to uphold international standards for the extension of certificates.
This safety bulletin is for:

• Ship owners and operators;
• Surveyors and Recognised Organisations (ROs);
• Master’s and ships’ officers; and
• Maritime Administrations, their officers, investigators and technical advisors.
  

Risk
The issue of extending statutory certificates beyond established requirements is not merely an administrative or certification matter. It is intrinsically linked to the verification of a ship’s ongoing compliance, condition, and maintenance regime.

The impact of the COVID-19 pandemic on ship maintenance programmes has been well documented. As a result, many ships are only now approaching their first scheduled drydocking cycle since the pandemic.
While deferring non-critical maintenance activities to a planned drydocking period is a common industry practice, such deferrals are predicated on ships remaining within approved survey and certification intervals.
Allowing ships to continue commercial operations beyond agreed drydocking and survey intervals introduces avoidable risk to maritime safety and environmental protection. Port and coastal States should not be expected to accept such risk where
operators have had reasonable opportunity to plan for and complete required surveys, maintenance, and drydocking activities in accordance with statutory requirements.

Extension decisionmaking
The International Maritime Organization (IMO) has provided recommendations to administrations for extending the validity of certificates in MSCMEPC.5/Circ.1.
Moreover, the Survey Guidelines under the Harmonised System of Survey and Certification (HSSC) 2025 (IMO Resolution A.1207(34)) (the IMO Guidance) provides a framework for extending a certificate when it is ‘proper and reasonable to do so’,
in paragraph 5.9.1. Under that framework, extension decisions should consider whether the ship will sail directly to a named final agreed cargo discharge port and then directly to a named agreed port to complete the survey and/or dry-docking.
Tokyo MOU Member Authorities can only accept an extension if all of the following conditions are met:

• the extension is granted under a regulation in a Convention, an Annex to a Convention, an Article of a Convention or within a Code with limited time requirement;
• it is for the purpose of allowing a ship to complete its voyage to a final cargo discharge port, then directly to the port in which it is to be surveyed, but not be used to continue commercial operations;
  and
• it appears proper and reasonable to do so. (The IMO Guidance, in full (at paragraph 5.9.2), provides the basis for determining what is proper and reasonable).

General requirements for the extension of statutory surveys:
In accordance with IMO circular MSCMEPC.5/Circ.1, where a ship is located at a port where the required survey cannot be completed, and the Convention permits the relevant Administration to extend the validity of the certificate, the Administration should be guided by the following provisions:

1. An additional survey equivalent to at least the same scope of an annual survey required by the relevant certificate(s) should be carried out.
2. If a renewal survey is due, it should be progressed to the maximum extent possible.
3. In cases where dry docking is required but cannot be conducted, an underwater inspection of the ship’s bottom should be
   carried out.
4. In cases where an underwater inspection is not possible (e.g. poor water visibility, draft restrictions, excessive current, refusal by the port authority), an internal inspection of the ship’s bottom structure should be carried out to the maximum extent practicable.
5. The ship should be permitted to sail directly to a named final agreed cargo discharge port and then proceed directly to a named agreed port to complete the survey and/or dry docking.
6. The extension period should be the minimum time required to complete the survey and/or dry docking under the relevant certificate(s).
7. The condition of the ship identified in the foregoing surveys should be taken into account when determining the duration,distance and any operational restrictions applicable to the voyage required to complete the survey and/or dry docking.
8. The extension period of the relevant statutory certificate(s) should not exceed the validity period of the new certificate that may be issued to document compliance with the structural, mechanical and electrical requirements of the recognized classification society.

What we find
Port State control officers are finding that ships have had their statutory certificates extended under SOLAS Chapter I, Reg 14(e) or (f) but continue to trade commercially and do not proceed directly to the port of survey.
We see ships that have been issued three-month extensions, and these ships continue to trade, or intend to trade, commercially for that period. These ships:

• are not undertaking a direct voyage to their named cargo discharge and/or survey port
• have extensions for more than the minimum amount of time needed to complete the survey
• usually require dry docking as part of theirrvey

An extension is not an additional period of ordinary certificate validity. It may be granted only for the limited purpose permitted by the applicable Convention provision and only where the Administration determines that doing so is proper and
reasonable.
We acknowledge that during the COVID-19 pandemic, relaxations were granted by the IMO (Circular Letter No.4204/Add.19) due to restrictions put in place by governments internationally. However, reliance on these temporary relaxations have been withdrawn as normal statutory survey and certification procedures have been reinstated.

Our actions
Where a ship has been found to have its statutory certificates extended contrary to a Convention or Code requirements, the ship may be detained as part of a port State control inspection. Where a flag State’s appointed Recognised Organisation (RO)
has issued the extension, the RO may be held responsible for such detention.