Procedures for in-transit fumigation by ship's crew

Fumigation for cargo shall be conducted by fumigators who is arranged by shipper. However, because of restrictions of COVID-19, there are cases that fumigators cannot go onboard for in-transit fumigation, thus charterer ask owner to conduct in-transit fumigation by ship's crew. 

Fumigation is risky operation which can cause fatality incident, it must be very careful if crew conduct in-transit fumigation.  We introduce some notes for in-transit fumigation by crew.

1．Ship's crew is permitted to carry out in-transit fumigation?
Is there any restriction to carry out in-transit fumigation by ship's crew?
IMSBC CODE 3.6 states that fumigation shall be performed based on the recommendation by IMO, MSC.1/Circ.1264. In this recommendation, it is said that ship’s personnel should not handle fumigants and such operations should be carried out only by qualified operators. 
However, sometimes flag states permit in-transit fumigation by ship's crew under specific conditions.

IMO-Recommendations 1264.pdf

2. Authorization by Flag States
As mentioned above, IMSBC CODE do not allow ship's crew to carry out in-transit fumigation, but because fumigators face difficulties for international travel due to COVID-19, flag states may permit fumigation by crew under specific conditions.
For example, Panama flag  issued authorization letter  for crew's fumigation after confirmation crew's necessary training, supplying PPEs and explaining the reason of difficulties of in-transit fumigation by fumigator.  

3. Agreement with P&I club
It is recommended to check with P&I club about coverage of the insurance, in case the crew suffers health damage due to fumigation work. From our experience, most of the P&I club covers crew's health damage due to fumigation work, terms of the coverage may be different by each P&I clubs.

4. Permission by loading port administration
Owners do not arrange this permission usually, it is recommended to check with charterer if the permission is granted. sometimes flag states ask owners this permission for above No.2- flag states authorization.   

5．Training for crew
Necessary training for crew should be performed.

6. Supply arrangement
PPEs, gas detectors and other necessary items should be supplied.

7. PSC inspection at discharging port
PSC inspector at discharging port might consider that crew's fumigation work is violation of international regulation, then they might point it out as observation. It may be good idea to prepare below items/documents for proper explanation by crew to prevent such case.

• Evidence of flag state permission (such as authorization letter)
• Record of crew's fumigation work training
• Necessary items (such as PPEs, gas detectors etc.)
• Check Lists for before/in middle/after fumigation work
• Writing in ship's log book based on requirement of IMSBC CODE 3.6.

Please refer below circular issued by UK P&I

https://www.ukpandi.com/media/files/imports/13108/bulletins/3843---bulletin-683.pdf