Global Maritime Regulatory System ( SOLAS,MARPOL,STCW and MLC)

Safety of Life at Sea (SOLAS) & Convention for Prevention of Marine  Pollution (MARPOL): A General Overview
Source : Google

 

What is SOLAS Convention?

The word SOLAS is an abbreviation and SOLAS full form is “Safety Of Life At Sea”, an international maritime treaty, also known as SOLAS Convention or International Convention for the Safety of Life at Sea (SOLAS), which establishes the least safety measures in the construction, equipment and operation of merchant ships.

IMO SOLAS 74, the last adopted revised convention of 1974, includes a number of regulations under different SOLAS chapters, which deals with safety precautions and safety procedures starting from the construction of the ship to real emergency like – “Abandon Ship”.  The convention is updated to meet the safety norms in the modern shipping industry from time to time.

This article explains the contents of SOLAS chapters and regulations providing a summary of SOLAS, i.e. different chapters of SOLAS and the regulations they carry. Marine Insight has provided links of various articles which will help the readers to understand how the regulation of the SOLAS Annexes is implemented on a seagoing vessel and the importance of SOLAS.


The International Convention for the Safety of Life at Sea (SOLAS), 1974 describes the requirement for all merchant ship of any flag state to comply with the minimum safety norms laid down in the chapters which are as follows:

Chapter I – General Provisions: Surveys and certification of all the safety items etc are included.

Chapter II-1 – Construction – Subdivision and stability, machinery and electrical installations: Deals with watertight integrity of the ship, especially for passenger vessel.

Chapter II-2 – Fire protection, fire detection and fire extinction: This chapter elaborates the means and measure for fire protection in accommodation, cargo spaces and engine room for the passenger, cargo and tanker ship.

Chapter III – Life-saving appliances and arrangements: All the life-saving appliances and there use in different situations is described.

Chapter IV – Radio communications: Includes requirements of GMDSS, SARTEPIRB etc for cargo and passenger vessel.

Chapter V – Safety of navigation: This chapter deals with all the seagoing vessels of all sizes, from boats to VLCCs, and includes passage planning, navigationdistress signal etc.

Chapter VI – Carriage of Cargoes: This chapter defines storage and securing of different types of cargo and containers, but does not include oil and gas cargo.

Chapter VII – Carriage of dangerous goods: Defines the International Maritime Goods Code for storage and transportation of dangerous goods.

Chapter VIII – Nuclear ships: The code of safety for a nuclear-propelled ship is stated in this chapter.

Chapter IX – Management for the Safe Operation of Ships: The International Safety Management code for ship owner and the operator is described clearly.

Chapter X – Safety measures for high-speed craft: safety code for the high-speed craft is explained.

Chapter XI-1 & 2– Special measures to enhance maritime safety: Special and enhanced survey for safe operation, other operational requirements and ISPS code is briefed in this chapter.

Chapter XII – Additional safety measures for bulk carriers: Includes safety requirement for above 150 meters length bulk carrier.

Chapter XIII  – Verification of Compliance

Chapter XIV -Safety Measures for Ships Operating in Polar Waters.



Workshop On Implementing MARPOL
Source : Google







MARPOL Annex I

Regulation for the prevention of pollution by oil (October 1983).

This regulation was adopted on 2nd October 1983 to control and prevent any oil discharge from ship intentionally or accidentally. It comprises of 11 chapters which together contains 47 Regulations.

Chapter 1 gives a general description about MARPOL ANNEX I and consists of 5 regulations which explain the “Application” of this chapter in different types of the ship along with the “Definition” of different terminologies which are used in the chapter. The regulation may not apply to all types of ship hence a separate section of “Exceptions” and “Exemptions” is also provided. It also explains the condition where an administrator may allow alternative fittings, materials, appliances etc. to be installed on ships to fulfil this annex.

Chapter 2 deals with Surveys and Certifications requirement for all oil tanker ships of 150GT and other sips of 400 GT. And comprises of 5 regulations.

Related Read: How to Get Dangerous Cargo Endorsement Certificate?

Regulation 6 describes the requirement for different surveys to comply with MARPOL annex 1.

Regulation 7 provides the terms to issue or endorse the IOPP certificate to the ship post successful survey by the appropriate administration. Regulation 8 also describes how to issue or endorse the certificates by another contracting government, followed by Regulation 9 which tell the form of the certificate including languages such as English or official language of issuing country.

Regulation 10 explains the duration and validity of certificates and provide timelines for renewal of certificates.

Regulation 11 terms the authority of port state control under Annex 1 to inspect the ship for compliance.

Chapter 3 deals with the Requirements for Machinery spaces for all ships and list down the requirements under Regulation 12 to 17, so that the engine room and other machinery spaces are compliant with the MARPOL Annex 1.

Regulation 12 explains the requirement of storage tanks for oil residues produced on all types of the ship due to machinery operation and method to dispose of the oil residue. It further provides details to protect the fuel oil tanks for ships having fuel oil capacity 600m3 and above.

Related Read: List of Important Tanks on a Ship

Regulation 13 describes the requirement for standard discharge connection on a ship to dispose of oil residue from sludge and bilge tanks.

Regulation 14 The requirements of oil filtration equipment onboard ship for discharging engine room bilges or ballast water from fuel oil tanks is given in this regulation, followed by Regulation 15 which restricts the discharge of treated bilges in special areas.

Related Read: An Overview Of Sludge And Bilge Management Onboard Ships

Regulation 16 explains the requirement of segregating oil and water ballast which is carried in the fuel tank of the ship.

Related Read: A Guide To Ballast Tanks On Ships

Regulation 17 lists down the need for a compliant oil record book for machinery space in oil tankers of 150GT and above and other ships of 400 GT and above.

Chapter 4. deals with the Requirements of Cargo areas in an oil tanker ship listing down various regulation (Regulation 18 to 36).

Chapter 5 describes how to prevent pollution which can arise from an oil pollution incident. Regulation 37 which list the SOPEP or Shipboard Oil Pollution Emergency plan provides the details.

Related Read: What is Ship Oil Pollution Emergency Plan (SOPEP)?

Chapter 6 lists the requirement for the reception facilities to which the ship will dispose of the oily bilge/ sludge to under Regulation 38  providing details of the facility outside and inside special areas.

Chapter 7 provides the special requirement for fixed or floating platform to comply with Annex 1 of MARPOL with Regulation 39.

Chapter 8 deals with the prevention of pollution which may happen during cargo oil in between tankers at sea also known as Ship to Ship Transfer (STS). It comprises of 3 regulation from 40 to 42.

Related Read: What is Ship-to-Ship Transfer (STS) and Requirements to Carry Out the Same?

Regulation 40 provides the scope of application for this chapter and Regulation 41 lists down the rules on safety and environmental protection during the STS operation, followed by Regulation 42 which tells the notifications which need to be provided by the ship to port state and all the other parties involved in the operation.

Related Read: 7 Important Points For Safe Lightering Operations On Ships

Chapter 9 carries the details for the special requirement for the use of carriage of oils in the Antarctica area with Regulation 43.

Chapter 10 deals with the Verification of compliance with the provision of this convention under Regulation 44 and 45, providing details of the application and the process for verification of compliance.

Chapter 11 list down the important requirement on international code for ships operating in Polar waters under Regulation 46 and 47. Regulation 46 lists down the definition for this annexe followed by Regulation 47 for application and requirement for the ships sailing in polar waters.

MARPOL Annex II

Regulations for the control of pollution by Noxious Liquid Substance in bulk (April 1987).

This Annex was adopted on 6th of April 1987  which deals with the control and prevent pollution due to the noxious liquid substance in bulk, intentionally or accidentally. It comprises of 10 chapters which together contains 22 Regulations.

Chapter 1 gives general details on MARPOL ANNEX II and consists of 5 regulations providing the “Definition” of different terminologies which are used in the chapter and explains the “Application” of this chapter in different types of ship (Chemical tankers etc.). The regulation may not be applicable to all types of a ship; hence a separate section of “Exceptions” and “Exemptions” is also provided. It also explains the condition where an administrator may allow alternative fittings, materials, appliances etc. to be installed on ships to fulfill this annex.

Related Read: Different Types of Tankers: Extensive Classification of Tanker Ships

Chapter 2 provides the details of different categories of Noxious liquid substance under regulation 6.

Chapter 3 list down the need for surveys and certification with 4 regulations from regulation 7 to 10.  Regulation 7 deals with the surveys and certifications needed by chemical tanker following the provision of the International Bulk Chemical code.

Regulation 8 details the need for different surveys for the ships carrying noxious liquid substances in bulk followed by issuing and endorsing of the certificate under Regulation 9. The duration and validity of the certificate are provided in Regulation 10.

Chapter 4 specifies the Design, Construction, arrangement, and equipment for ships carrying Noxious cargo in bulk under regulation 11, followed by Regulation 12 which provides the details of pumping, piping, unloading arrangement and slop tanks.

Chapter 5 carries 3 regulation from 13 to 15 for providing the details of operational discharge of residues of noxious liquid substances.  Regulation 13 lists the need for control of discharges of Noxious liquid substance residues.

Regulation 14 and 15 provide the details of Procedure and arrangement manual and Cargo record book which needs to be filled by the ships’ officers.

Chapter 6 which consist of Regulation 16 describe the role of government and authorised parties such as port state control on measures of control to check, survey and assess the ships to carry the cargo under MARPOL Annex II.

Related Read: A List of Inspections And Surveys Deck Officers On Ships Should Be Aware Of

Chapter 7 deals with Prevention of Pollution arising from an incident involving noxious liquid substance and consist of Regulation 17 giving the details of Shipboard pollution emergency plan for noxious liquid substances.

Related Read: IMO: Compensation Regime For Hazardous And Noxious Cargoes A Step Closer

Chapter 8 lists the requirement for the reception facilities to which the ship can dispose of the residues and mixture generated from noxious liquid substances under Regulation 38  providing details of the facility and terminal unloading arrangements.

Chapter 9 deals with the Verification of compliance with the provision of this convention under Regulation 19 and 20, providing details of the application and the process for verification of compliance.

Chapter 10 list down the important requirement on international code for ships operating in Polar waters under Regulation 21 and 22. Regulation 21 lists down the definition for this annex followed by Regulation 22 for application and requirement for the ships sailing in polar waters.

Related Read: How The IMO Polar Code Supports Safe And Eco-Friendly Shipping

MARPOL Annex III

Regulation for prevention of pollution by harmful substance carried at sea in packaged form (July 1992).

This Annex deals with those substances which are hazardous in nature and carried in packaged cargo. The identification of such material is provided in the IMDG Code. The MARPOL Annex III came into force on 1 July 1992 and comprised of 2 Chapters containing 11 regulations.

Related Read: What is Ithe international Maritime Dangerous Goods Code (IMDG)?

Chapter 1 gives a general details on MARPOL ANNEX III and consist of 9 regulations.

Regulations 1 & 2 explains the “Definition” of different terminologies which are used in the chapter and the “Application” of this chapter in different types of ships which are carrying Hazardous goods.

Regulation 3 & 4 lists down the requirement of packaging and Marking/labelling of the packages carrying IMDG cargoes.

Regulation 5 provides the details of the documentation which are needed by the ship which is carrying hazardous material under MARPOL Annex 3

Related Read: A Guide To HAZMAT Cargo Loading On Ships

The storage requirement and quantity limitations for carrying harmful substances in bulk are provided under Regulation 6 & 7.

Regulation 8 lists down the exceptions which a ship carrying harmful cargo in bulk can have under various circumstances.

The authorisation of port-state control on the operational requirement of ships carrying such substance under MARPOL Annex III is listed in Regulation 9.

Chapter 2 deals with the Verification of compliance with the provision of this convention providing details of the application and the process for verification of compliance under Regulation 10 and 11.

MARPOL Annex IV

Regulation for the prevention of pollution by sewage from ships (Sep 2003).

Entered into force on 27 September 2003, this Annex focuses on prevention of sewage pollution from ships. It has 7 Chapters comprising of 18 Regulations.

Chapter 1 gives a general description about MARPOL ANNEX IV and consist of 3 regulations which explains the “Definition” of different terminologies which are used in the chapter and “Application” of this chapter in different types of ships. The regulation may not be applicable to all types of ship hence a separate section of “Exceptions” is also provided.

Related Read: MARPOL ANNEX 4 Explained: How to Prevent Pollution from Sewage at Sea

Chapter 2 list down the need for surveys and certification with 5 regulations from regulation 4 to 8.  Regulation 4 deals with the surveys to be done on ships implicated by this Annex. Regulation 4 & 5 provide the details for issue or endorsement of certificates by the administration and by another government.  Regulation 7 & 8 gives details of form,  duration, and validity of the sewage pollution prevention certificate.

Chapter 3 provides the need of having Equipment and control of sewage discharge from the ship. Regulation 9 under this chapter provides details of sewage system requirement on ships followed by Regulation 10 and 11 for having a standard sewage discharge connection to transfer sewage to port facilities and discharge of sewage at sea within and outside special areas.

Related Read: Sewage Treatment Plant on Ships Explained

Chapter 4 consist of 2 regulations (12 & 13) with the details of the reception facilities requirement. Regulation 12 provides the details to the government agencies regarding the compliance to have a reception facility and Regulation 13 lists down the requirement of reception facilities for Passenger ships in special areas.

Related Read: Cruise Ship Sewage Discharges Into The Baltic Sea To Be Banned

Chapter 5 which consist of Regulation 14 describe the role of government and authorised parties such as port state control on measures of control to check, survey and assess the ships under MARPOL Annex IV.

Chapter 6 deals with the Verification of compliance with the provision of this convention providing details of the application and the process for verification of compliance under Regulation 15 and 16.

Chapter 7 list down the important requirement on international code for ships operating in Polar waters under Regulation 17 and 18. Regulation 17 lists down the definition for this annex followed by Regulation 18 for application and requirement for the ships sailing in polar waters.

MARPOL Annex V

Regulation for the prevention of pollution by Garbage from ships (Dec 1998).

This annexe deals with the garbage produced onboard ships and ways to prevent pollution from the same. It was enforced on 31 December 1988, having 3 Chapters with 14 Regulations.

Chapter 1 gives general details on MARPOL ANNEX II and consists of 10 regulations providing the “Definition” of different terminologies which are used in the chapter under Regulation 1 and explains the “Application” of this chapter in different types of ship Regulation 2.

Related Read: ICS Publishes New Edition Of Industry Guidance On Garbage Management Plans

Regulation 3 lists down the details of the general prohibition on the discharge of garbage at sea followed by Regulation 4 for the discharge of garbage outside special areas.

Regulation 5 specifies the special requirements for the discharge of garbage from fixed and floating platforms. The requirement for discharge of garbage in the special area is given under Regulation 6.

Regulation 7 & 8 describes the receptions facilities exception and requirements including those who are inside the special areas.

Regulation 9 consist role of port-state control on measures of control to check, survey and assess the ships under MARPOL Annex V.

Regulation 10 deals with the need for Garbage Management Plan (GMP) including record books and placards.

Related Read: What is Garbage Management Plan (GMP) on a Ship?

Chapter 2 deals with the Verification of compliance with the provision of this convention under Regulation 11 and 12

Chapter 3 list down the important requirement on international code for ships operating in Polar waters under Regulation 13 and 14. Regulation 13 lists down the definition for the purpose of this annex followed by Regulation 14 for application and requirement for the ships sailing in polar waters.

MARPOL Annex VI

Regulation for prevention of Air pollution from ships (May 2005).

This MARPOL Annex deals explicitly with ways to prevent air pollutions from ships. It came into force on 19th May 2005 having five chapters with 25 Regulations.

Chapter 1 gives a general description about MARPOL ANNEX VI and consists of 4 regulations which explain the “Application” of this chapter in different types of the ship along with the “Definition” of different terminologies which are used in the chapter. The regulation may not apply to all types of ship hence a separate section of “Exceptions” and “Exemptions” is also provided. It also explains the condition where an administrator may allow alternative fittings, materials, appliances etc. to be installed on ships to fulfil this annex.

Chapter 2 lists the survey, certification, and means of control dealing with air pollution from the ship. It has 7 Regulation with Regulation 5 explaining the need of different surveys for the vessel having the arrangement to prevent air pollution followed by issuing and endorsing of International Air Pollution Prevention (IOPP) certificate and International Energy Efficiency Certificates (IEEC) in Regulation 6.

Regulation 7 provides the details for issue or endorsement of certificates by another party followed by the forms of certificates and statement of compliance related to fuel oil consumption reporting in Regulations 8 for both IOPP and IEEC.  The details for the validity of these certificates are provided in Regulation 9.

Related Read: Important MARPOL Amendments Enter Into Force

Regulation 10 terms the authority of port state control under Annex VI to inspect the ship for compliance.

Regulation 11 explains how the administration and authorised party can detect ships for the violation and how to enforce this annexe.

Chapter 3 deals with the requirements for control of emissions from ships and consist of 7 Regulations, starting with the details of ozone-depleting substances in Regulation12 such as in the refrigerant used on ships.

Related Read:  What are Ozone Depleting Substances on Ships?

Regulation 13 gives a brief about Nitrogen Oxides (NOx) with different Tiers  (Tier I, II and III) in and outside the emission control areas.

Related Read: What is Nitrogen Oxides or NOx air pollution from Ships?

Regulation 14  gives a brief about Sulphur Oxides (SOx) with the requirement for the quantity of sulphur in the fuel oil as per the year, in and outside emission controlled areas.

Related Read: What is Sulphur Oxides or SOx air pollution from Ships?

The emissions of Volatile Organic Compound from the oil tankers are taken into account in Regulation 15 providing the details to comply with the requirements.

Regulation 16 talks about the shipboard incineration operations and when the incineration is allowed.

Related Read: Construction and Working of Waste Oil Incinerator

Regulation 17 describes the receptions facilities requirements for disposing of ozone-depleting substance, residue from exhaust cleaning etc.

To comply with the exhaust emission requirements, proper fuel oil is made available to burn on ships, whose condition is described in Regulation 18.

Chapter 4 provides the Regulation on Energy Efficiency on Ships having Regulations 19 to 23.  Regulation 19 talks about the application of this chapter on ships of 400GT and above.

Related Read: How to Improve Energy Efficiency of Ships?

Regulation 20 and 21 provide the details of Attained Energy Efficiency Design Index (Attained EEDI) and Required EEDI.

Related Read: Energy Efficiency Management in the Maritime Industry

The Ship Energy Efficiency Management Plan (SEEMP) requirements, which should be kept onboard, is provided in Regulation 22. Further, the requirement for fuel oil consumption data collection and reporting to the administration is also listed in this regulation.

Related Read: What is Ship Energy Efficiency Management Plan?

Regulation 23 talks about the technical cooperation between different parties (Administration, Government agency, Shipping company etc.) to improve the energy efficiency of ships.

Chapter 5 deals with the Verification of compliance with the provision of this convention under Regulation 24 and 25.

Thus, SOLAS and MARPOL conventions stand as two solid pillars that support the maritime industry by protecting the most important issues – marine pollution prevention and safety of human life.



IMO's STCW Training for Seafarers in Timor Leste - mfame.guru
Source : Google



The STCW Convention & Code 2010 Manila Amendments

The Manila amendments to the STCW Convention and Code were adopted on 25 June 2010, marking a major revision of the STCW Convention and Code. The 2010 amendments are set to enter into force on 1 January 2012 under the tacit acceptance procedure and are aimed at bringing the Convention and Code up to date with developments since they were initially adopted  and to enable them to address issues that are anticipated to emerge in the foreseeable future.
 
Amongst the amendments adopted, there are a number of important changes to each chapter of the Convention and Code, including:
  • Improved measures to prevent fraudulent practices associated with certificates of competency and strengthen the evaluation process (monitoring of Parties' compliance with the Convention);
  • Revised requirements on hours of work and rest and new requirements for the prevention of drug and alcohol abuse, as well as updated standards relating to medical fitness standards for seafarers;
  • New certification requirements for able seafarers;
  • New requirements relating to training in modern technology such as electronic charts and information systems (ECDIS);
  • New requirements for marine environment awareness training and training in leadership and teamwork;
  • New training and certification requirements for electro-technical officers;
  • Updating of competence requirements for personnel serving on board all types of tankers, including new requirements for personnel serving on liquefied gas tankers;
  • New requirements for security training, as well as provisions to ensure that seafarers are properly trained to cope if their ship comes under attack by pirates;
  • Introduction of modern training methodology including distance learning and web-based learning;
  • New training guidance for personnel serving on board ships operating in polar waters; and
  • New training guidance for personnel operating Dynamic Positioning Systems ​

The STCW Code

The regulations contained in the Convention are supported by sections in the STCW Code. Generally speaking, the Convention contains basic requirements which are then enlarged upon and explained in the Code.

Part A of the Code is mandatory. The minimum standards of competence required for seagoing personnel are given in detail in a series of tables. Chapter II of the Code, for example, deals with standards regarding the master and deck department.

Part B of the Code contains recommended guidance which is intended to help Parties implement the Convention. The measures suggested are not mandatory and the examples given are only intended to illustrate how certain Convention requirements may be complied with. However, the recommendations in general represent an approach that has been harmonized by discussions within IMO and consultation with other international organizations.

 

​List of STCW Parties - Confirmed STCW Parties (regulation I/7)

MSC.1/Circ.1163/Rev.10*   23/05/2016  International convention on standards of training, certification and watchkeeping for seafarers(STCW), 1978, as amended – Parties to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), 1978, as amended, confirmed by the Maritime Safety Committee to have communicated information which demonstrates that full and complete effect is given to the relevant provisions of the Convention.

List of STCW Parties - Independent evaluation (regulation I/8)

 MSC.1/Circ.1164/Rev.18*  24/07/2017  International convention on standards of training, certification and watchkeeping for seafarers (STCW), 1978, as amended – Reports of Independent Evaluation.
 
* Please note: the above Circulars are revised as and when information from Parties is evaluated and approved by the Maritime Safety Committee.
 

Maritime training institutions approved by Member States

The STCW Convention requires that training leading to the issue of a certificate is 'approved'.

The International Maritime Organization does not approve any training courses or institutes. This is a privilege and responsibility of Member Governments who are Parties to the STCW Convention.

Approval is normally given by the Maritime Administration of an STCW Party in accordance with the Convention requirements.

Amongst other things, the Convention requires that training and assessment of seafarers are administered, supervised and monitored in accordance with the provisions of the STCW Code; and those responsible for training and assessment of competence of seafarers are appropriately qualified in accordance with the provisions of the Code.

The initial approval of a maritime training programme by a Maritime Administration might include assessment of items such as those listed below in order to ensure that the training institute or training programme meet the appropriate STCW Convention standards:

  • Scope and objectives of the training - e.g. to meet the requirements of STCW regulation II/1.
  • Minimum entry standards - age, sea experience, other training, medical fitness etc.
  • Intake limitations, student/staff ratio etc.
  • Staff qualifications, experience in subject, teaching skills, assessment skills.
  • Facilities and equipment necessary to meet objectives.
  • The written programmes, syllabus, timetable and course material.
  • Method of training: lectures, practical, videos etc and percentage of time devoted to each.
  • Assessment: methods: examination, practical, continuous assessment etc.
  • Certification to be issued on completion to meet STCW requirements.
  • Maintenance of student and other records.
  • Security of information.
  • Quality standards system requirements to ensure standards are maintained.


MLC 2006 - theory and practice
Source : Google





Contents of MLC,2006 

1. Minimum Requirements for seafarers to work on ships

  • Minimum age
  • Medical certificate
  • Training and certifications
  • Recruitment and placement

 2. Conditions of Employment 

  • Seafarer’s Employment Agreement
  • Wages
  • Hours of rest and hours of work
  • Entitlement to leave
  • Repatriation
  • Seafarer compensation for ship’s loss or foundering
  • Manning levels
  • Career and skill development and opportunities for seafarer’s employment

 3. Accommodation, Recreation, Food and Catering

  • Accommodation and recreational facilities
  • Food and catering

 4. Health Protection, Medical Care, Welfare and Social Security Protection

  • Medical care on board and ashore
  • Ship owner’s liability
  • Health and safety protection and accident prevention
  • Access to shore based welfare facilities
  • Social Security

 5. Compliance and Enforcement

  • Flag state responsibility
  • Authorization of recognized organizations
  • Maritime labour certificate and declaration of maritime labour compliance
  • Inspection and enforcement
  • On board compliance procedures
  • Port State Responsibilities
  • Marine Casualties
  • Labour Supplying responsibilities

Application of MLC,2006 to type of vessels

MLC applies to all the registered commercial vessels regardless of the flag state they belong to. This will also include leisure and commercial yachts, which are engaged on international voyages besides a few exceptions as stated in their circular discussing application of MLC on types of vessels. Vessels must be over 500 GRT to carry the MLC certificate. For vessels under 500 GRT, guidelines recommend the vessels to be voluntarily complying with the convention and as documented by the flag states.









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