The United Kingdom Maritime and Coastguard Agency (MCA) will shortly be issuing a Merchant Shipping Notice (MSN) which will change the arrangements and responsibilities for ship arrival and departure notifications to meet the requirements of the EU Vessel Traffic Monitoring and Information System Directive 2002/59/EC and the Merchant Shipping (Vessel Traffic Monitoring and Reporting Requirements) Regulations 2004 (as amended). These notification procedures will enable shipping movements to be monitored throughout the EU area through an EU wide system known as SafeSeaNet (SSN) managed by the European Maritime Safety Agency (EMSA). These provisions within the Vessel Traffic Monitoring Directive and the associated SSN system have been introduced as a result of the pollution caused by the foundering of the ERIKA III off Brittany and PRESTIGE off Spain and are intended to enable the immediate identification of ships and any dangerous or polluting cargos in the event of an accident or incident anywhere within the European Economic Area (EEA). The MCA have put in place a new information management system, referred to as the Consolidated European Reporting System (CERS), which will in time be used to capture all national notifications and infringements and forward them electronically to the EU SSN system. The first phase of the CERS roll out, dealing with Vessel Traffic Monitoring Directive notifications, port waste infringements and bulk carrier loading/unloading infringements, will go operational on 1 January 2008.
The 2004 Regulations place a requirement on owners, operators, agents or masters of most ships over 300 gt to make a general arrival notification to the Port Authority of the port to which a ship is bound. In addition, all vessels carrying dangerous or polluting goods will be required to make a more detailed notification to the port authority on departure and also on arrival if arriving from outside the EEA. Port Authorities will, in turn, be required by the MSN to pass these notifications to the MCA’s CERS. To meet these requirements, the PLA has established an interface through the port’s management information system (POLARIS) that will automatically pass arrival and departure notifications and changes electronically to CERS.
A summary of the notification requirements in the MSN as they relate to port arrivals and departures is at Annex A. Most of the notification details are already being gathered from standard reports managed routinely through the Port Control Centre London.
For general arrival notifications, the Estimated Time of Departure (ETD) must always be passed as part of the arrival notification recognising that this may, in some instances, be only a rough estimate. Custom and practice has permitted acceptance of “am” or “pm” for ETAs and ETDs. This will no longer be acceptable for reporting purposes and the best estimate of time must always be given. The reported times may be refined the closer they are to departure or arrival. CERS requires that the time be updated if the original ETA or ETD changes by more than 6 hours.
The most significant reporting change relates to notifications involving any ship carrying dangerous or polluting goods. Such notifications have to date been submitted to MCA through MRCC Dover but, from 1 January 2008, will be handled by the Port Authority. The departure notification must include the next port of call and the ETA at the next port (except when no orders have been received where the next port should be indicated as “UNKWN” and no time reported). In addition, vessels arriving from outside the European Economic Area (EEA) with London as the first port of call, are required to make an arrival notification to London on leaving the loading port or, for ships without orders, as soon as London is identified as the first port of destination within the EEA. There is also a requirement for all ships carrying dangerous or polluting goods to notify the port authority of cargo information. The minimum notification requirements for dangerous or polluting goods are for the contact details to be passed to CERS through the port authority. However, it is important to note that the contact details provided must link through to a person who is contactable at any time, day or night, and able to transmit the appropriate dangerous or polluting manifest details (see Annex A para B.3.d) to the MCA electronically on request in the event of an incident or accident. Care should be taken, therefore, in providing contact details, that they link through to a person capable of fulfilling this role. Attention is drawn to the mandatory requirement to provide the location of the contact in UNLOCODE. The nominated contact will be required to hold the dangerous or polluting manifest details at least until the ETA at next port plus 7 days. It should also be noted that there is pressure within the EU to include the dangerous or polluting goods manifest details electronically and routinely with every hazardous or polluting notification; it is expected that this additional requirement will be introduced within the next few years. Finally, there is a requirement for the owner, operator, agent or master to confirm that a dangerous or polluting goods manifest is held onboard and this must be confirmed to the port authority as part of the notification process.
Whilst provision is made for exemptions in the hazardous or polluting goods notifications for vessels on regular scheduled services, there is no corresponding provision for exemptions in the general arrival notification process. It is, however, expected that notifications for vessels on regular scheduled services can be generated from the standard information currently reported to PCC London either in timetable or individual voyage form. These reports will be generated and reported to CERS automatically through POLARIS. The Harbourmaster must be informed of those vessels that have been granted exemptions by the MCA on behalf of the Secretary of State in accordance with the regulations. In the absence of a formal exemption, a full notification will be required for each individual voyage when dangerous or polluting goods are carried.
The standard notification form on the PLA website will be amended to include these additional requirements and a provisional draft is included at Annex B (PDF or Word). It includes all data that is mandatory for reporting into CERS and also those fields that are mandatory for the PLA’s requirements. To ensure that all mandatory data is provided, this form must be used for all notifications from agents and berth operators; masters making their own notifications should also use this form wherever possible. It should be noted that further amendments may be made to this form prior to the introduction of the new reporting arrangements on 1 Jan 08 and the version of the form posted on the PLA website should always be used for reporting purposes.
This Notice to Mariners covers only requirements for reporting arrivals and departures through the Port Authority. The MCA should have contacted facilities responsible for reporting waste or bulk carriage infringements and separate arrangements should be in place to make such infringement reports or alerts to the MCA direct through a web based interface. Such reports will not be processed through the PLA but the PLA will have the ability to view reports relating to vessels arriving or departing to or from the Port of London.
Unfortunately, requests from the PLA that the Dangerous Substances in Harbour Areas (DSHA) reporting requirements be more closely aligned to those required to meet the VTM Directive have not been forthcoming. DSHA reporting requirements, therefore, remain unchanged. Approvals for the movement of Class 1 throughout the port should continue to be requested separately through the Harbourmaster. Notifications for tankers and bulk carriers should be made through the standard notification form (Annex B). The requirement for notification of containerised dangerous or polluting goods will be satisfied through the nomination of a contact. As noted above, more detailed data for containerised goods may become mandatory at a future date and, to this end, the PLA will accept a dangerous and polluting goods manifest in electronic format if this is available.
