Decoupling ships’ IOPP certificates from the Harmonised System of Survey and Certification

2/2/17, 12:35 PM

The Finnish Transport Safety Agency (Trafi) will allow IOPP certificates to be decoupled from the Harmonised System of Survey and Certification to facilitate the implementation of the Ballast Water Management (BWM) Convention on ships.

Current legislation

Once the Ballast Water Management Convention has entered into force on 8 September 2017, all ships engaged on international voyages must be fitted with a ballast water management system. The timetable for installing such a system is determined by IMO resolution A.1088(28). According to the resolution, a ballast water management system must be installed into a ship by the first renewal of its IOPP certificate following the entry into force of the Ballast Water Management Convention.

Ships are inspected and their certificates issued according to IMO resolution A.1104(29) on the Harmonised System of Survey and Certification (HSSC). The IOPP certificate has been included in this harmonised system.

Finnish requirements on the validity of certificates are put into effect by a Trafi regulation on ship surveys (TRAFI/976/

Deviating from the harmonised system

Trafi’s view is that deviating from the harmonised system is possible at this stage for flag states, but a decision must be made for each individual ship as an exception under section 62 of the Act on the Technical Safety and Safe Operation of Ships (Act no. 1686 of 2009). An exception like this enables the ship to deviate from Trafi’s survey regulation. Any exception will be valid until the next renewal following entry into force of the BWM Convention, after which the IOPP certificate will be reintroduced into the harmonised system.

Classification societies are, under EC Regulation 391/2009 on common rules and standards for ship inspection and survey organisations, obliged to follow the harmonised system. Trafi requires that the validity date of an IOPP certificate decoupled from the harmonised system must be linked to the anniversary date specified in Trafi’s survey regulation. Another requirement is that the ship has permission from the classification society to decouple from the harmonised system.

Once decoupling from the harmonised system is over, the ship’s surveys and validity that are the prerequisites for the IOPP certificate and ballast water certificate will be re-harmonised. This will prevent a situation in which a ship would have an unsurveyed ballast water management system. Shipping companies must also take into account that installation of ballast water management systems may result in extra docking or the ship being out of service during the installation.


Further information:
Special Adviser Ville-Veikko Intovuori, tel. +358 (0)29 534 6642, ville-veikko.intovuori(at)
Chief Adviser Anita Mäkinen, tel. +358 (0)29 534 6590, anita.makinen(at)