Original Seafarer Qualifications to be on board at all times

Dear DPA and Yacht Management Personnel,

It has come to our attention that some vessels may be allowing their seafarers to send their original crew certificates to the relevant issuing Administration in order to re-validate or apply for new Certificate of Competencies (CoCs) whilst being signed on.  Traditionally seafarers have completed this task when they are on leave to ensure compliance with STCW Reg I/2.11 which states:

“11. Subject to the provisions of Regulation I/10, paragraph 5, any certificate required by the Convention must be kept in its original form onboard the ship on which the holder is serving.”

Please will you ensure that your vessels are reminded of this formal requirement since we unfortunately had a yacht detained in Italy recently due to one of the seafarers not having their original certification on board.  The attending PSCO did not accept this situation even though the seafarer provided verification from the issuing Administration that they were processing their renewal application.
It should be noted that the vessel remained detained until either the original CoC was placed back on board or another suitably qualified seafarer was made available.  The vessel was also required to undergo an External ISM audit before departure.

Noting the above requirements, and that under Cayman Islands law the Company and Master are liable for fines and up to 12 months imprisonment (!) if original qualifications are not on board, we are obviously aware that we need to work together to find a workable solution.

We therefore kindly request that you consult with us before any certificates are sent off the vessel explaining the exceptional necessity of why the certificates are required to be removed.  We will review each request on a case by case basis and if deemed acceptable will issue a formal letter of no objections.  Please be advised that this letter will not provide a guarantee of acceptance by all local authorities.