Article 10 of the EU Regulation No 391/2009 on common rules and standards for ship inspection and survey organisations states that “Recognised organisations shall, in appropriate cases, agree on the technical and procedural conditions under which they will mutually recognise the class certificates for materials, equipment and components based on equivalent standards, taking the most demanding and rigorous standards as the reference”. The EU Recognised Organisations (ROs) have accordingly established procedures and technical requirements for Mutual Recognition (MR) and coordinate their work through an Advisory Board supported by a Technical Committee. Products are grouped into varying levels of safety (Level I to VI), and for the lower levels certain tiers with defined products and preconditions have been developed.
IUMI’s position is that classification plays an important role in ensuring a vessel and its equipment has achieved a certain level of safety. There is usually a requirement under most individual insurance contracts that a vessel is classed with a pre-approved classification society before the cover commences. However, if any RO is allowed to certify and approve components and equipment for a vessel at any safety level and regardless of classification society, neither the classification society nor the owners or underwriters will have any confidence or real understanding of the actual quality or safety levels achieved.
Accordingly, IUMI’s view is that allowing MR on safety critical materials, equipment and components would undermine the significance of ship classification as a key component of today’s safety regime at sea. Hence IUMI urges to limit MR to non-safety critical parts as currently contained in Level I to III of the EU RO MR Group’s system.
To ensure this, IUMI is in regular and productive contact with the EU RO group, manufacturers and the responsible EU DG Move. In June 2018 IUMI took part in a stakeholder workshop in Copenhagen organised by the European Shipyard & Maritime Equipment Association “SEA Europe” and was able to explain IUMI’s view and concerns. In September 2018, IUMI presented in a workshop during the SMM Hamburg event organised by the EU RO MR Group and attended by all relevant stakeholders including EU representatives.
To date, less certificates for MR have been issued than expected. Not least, this is due to the questions posed by third-party flag states relating to the acceptance of the EU RO regime and their reluctance to accept a vessel under their flag following the MR system.