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Assarmatori, Confitarma and Federagenti ask the government a table for analysis and of I confront with the shipping on emergency COVID-19
In a letter they evidence the main criticalities faced from the field
March 12, 2020
The Italian shipowning organizations Assarmatori and Confitarma (Italian Confederation Shipping) and Federagenti, the national federation of the agents and marine raccomandatari, have asked the urgent activation for a table of confront and analysis with the administrations involved in the activities in order to tackle to the emergency coronavirus, crisis - they have emphasized - than shipping the weevers with extreme worry also for the impact that this situation is having and will continue to having on the Italian socioeconomic system.
Assarmatori, Confitarma and Federagenti have remembered that the Italian armament, the armament enterprises that operate in Italy and the marine agencies until from have quickly been put on, through their representatives, of the national and local authorities in order to contribute to the solution of this sanitary crisis that has hit particularly the Country and that it is discriminating Italy and the Italians in the world. Moreover they have evidenced that the problematic ones that regards the marine transports they are numerous and is urgent to characterize solution adapted to guarantee the operativity of the ships and the regularity of the traffics.
To such fine Assarmatori, Confitarma and Federagenti have sent to the ministers of Infrastructures and the Transports, the Foreign policies and the International cooperation and the Health a letter, that we publish below, in order to illustrate the more important criticalities that the section is finding to operating level until from the adoption of the first extraordinary measures adopted by the government and that in progressing of the crisis they have been made gradually more tightening. In the letter the three associations ask therefore the urgent takeover for an analysis table and of I confront of the field with the involved administrations to which until from hour they guarantee the availability to participate and to supply own support.
Assarmatori
Confitarma (Italian Confederation Shipping)
Federagenti (National Federation Marine Marine and Mediating Raccomandatari Agents)
Rome, 12 March 2020
COVID-19: CRITICALITY YOU TRANSPORT MARINE
Today, together with all national the productive world, shipping the weevers with extreme worry evolving itself of the serious Covid-19 emergency also for the impact that this situation is having and will continue to having on the Italian socioeconomic system.
The Italian armament, the enterprises of armament that operate in Italy and the marine agencies until from are quickly put on, through their representatives, of the national and local Authorities in order to contribute to the solution of this sanitary crisis that has hit particularly our Country and that it is discriminating Italy and the Italians in the world.
Problematic that regards the marine transports are numerous and are urgent to characterize solution adapted to guarantee the operativity of the ships and the regularity of the traffics.
Attached to it anticipates are described the more important criticalities that the section is finding to operating level until from the adoption of the first extraordinary measures adopted by the Government and that in progressing of the crisis they have been made gradually more tightening.
We wish the urgent takeover of an analysis table and of I confront of the field with the involved Administrations.
In so far as, the undersigneds associations guarantee the availability beginning right now to participate to the foretold table and to supply own support to the Administration.
With more faithfully yours.
Stefano Messina (Assarmatori)
Mario Mattioli (Confitarma)
Gian Enzo Duci (Federagenti)
Technical note Covid-19
1. Closing of the ports foreign countries to the Italian ships
Italy is one of the more important marine Countries of the world and moves by sea about the 60°/o of the goods (worked, semifinished and raw materials) in import and export. The news that we are receiving from various Countries - is Third-country who, unfortunately Is of the EU - in which we operate, relative to the interdiction of the ports to the ships that have scaled in last the 15 days Italy, is extremely worrisome.
They are not to risk only our enterprises of navigation, to which it is prevented to operate for the single fact to be Italian, but the entire Country. In fact, in case such provisions had to be adopted from other geopolitically strategic nations, would be most serious repercussions for our economy that, goes remembered, is mainly of transformation.
2. Risk of marginalization of Italy from the world-wide routes and of supplying
There is the concrete risk that the services of transport previewed to scale the Italian ports decide definitively of bypassare our Country in order not to preclude the landing place in other nations.
An increasing number of foreign shipowners refuses transport contracts that preview the disembarkation of goods in the Italian ports putting in serious difficulty the import of raw materials. Between the fields that could be found some soon deprived there are also those essential things to guarantee alimentary supplyings of the Country (industry agricultural and food-, zootechnics, etc).
To emphasize, in this context, the importance of the marine transports in the energetic field, whose interruption or also the single slow down could involve easy imaginable repercussions.
Al fine not to make useless the efforts completed from the shipowners in order to guarantee the continuity in the transport of the passengers and the goods is also important that in the ports an adapted level of operation of all the necessary services is assured: from those of general interest to those for handling and storage until the controls of the authorities. Whereby particular difficulties in such sense had to be recorded, would have to be able to take part also through appropriate exceptions.
Moreover, as a result of the interdittive measures adopted by some Countries, various marine services of line are stopped. The problem is set therefore to characterize the suitable moorings where to make to pause the ships without to bring I hamper to the business activity. To such fine, it is necessary to optimize approaches to it available in all the ports, firstly those falling back within a same Authority of Harbour System.
3. Impossibility to carry out the alternation of the crews
To this it goes added that many units of Italian flag operate constantly abroad and have the necessity to assure the alternation of the boarded Italian staff, is for the normal spins previewed from the contract, but also, for example, in case of accident and disease. From when it is burst the emergency, in many nations it is not more possible to alternate the Italian crews with other Italian staff (we remember that on the ships clappers Italian flag enrolled in the Ordinary Registry the crew it must be entirely Italian/communitarian, while on that enrolled in the International Registry law previews a sure number of communitarian Italian members of the crew/), having they prohibited the income and the transit of the marine Italians; in the concrete, is rejected the tax or visa questions of pre-emptive periods of quarantine required to the arrival. Sussiste the real danger that these ships cannot more operate because not in a position to satisfying the safety table minimal, with the consequent risk of cancellation of contracts of supply of the services. Particularly difficult, in this moment, it is the substitution of the commander for which sussiste the obligation of Italian or communitarian nationality, provided that in possession of the certificate of acquaintance of the Italian legislation, because of the fact whom the examination sessions are suspended, near the Harbour offices, for the release of such attestation.
It is signaled, at last, than also the arrival on board and the repatriation of the operating marine staff on the ships of Italian flag (this last obligatory one according to MLC, 2006) are becoming more and more difficult for via of the cancellation by now generalized of the flights from and towards Italy.
4. Expiration certifications and attestations IMO of the marine Italians
The adopted restrictive provisions from the Government have involved also the relative activities to the obligatory formation of the navigating staff, imposing the closing of the authorized centers of training from the General Command.
Such closing is not allowing with the Italian marine workers to renew own attestations/certifications IMO (Basic Training, MAMS, MABEV, ECDIS, High Voltage, Ship Officer Security, RoRo Pax) let alone the certificates of competence, preventing therefore to the same ones of being able to work. This is determining remarkable difficulties, that they are aggravated from day to day, in the alternation of the crews and consequently in the management of the fleet.
To such care, it is necessary to timely characterize a solution that to warning of writing - it would have to be represented from a delay of such attested certificates/, only granted and exclusively for those in expiration and the period necessary to the overcoming of the sanitary emergency in Al action fine to avoid problems to the ships that operate abroad such delay will have to be necessarily and ready shared, by the Administration, with the IMO and main the MOUs.
To such purpose, the initiative undertaken from Maritime and the Port Authority of Singapore is signaled, which allows with the marine aliens to which the “Certificate of Competence (CoC has expired)” to continue to operate on board of the ships recorded to Singapore, in case the Administration that has released said certifyd some postpones the validity. To the marine singaporeans, instead, the flag allows to extend the validity of the CoC beyond the expiration to which they cannot disembark because of the sanitary emergency (Circular MPA of Singapore n. 3 on February 26, 2020).
An important case is that of the certification ECDIS that on board previews a training aimed on the specific system present of a sure ship. It could be obviated on board to such problematic one with the contemporary presence, for a time of consistent duration, of the certifyd official disembarking for the apparatus in use and of the official embarking (in soprannumero) not certifyd for the ECDIS in use but that it will be trained during the boarding during the turns of guard in navigation.
5. Impossibility to carry out the sanitary visits
While regarding the inspections for the release of the certificates of edge (firstly CGCCP and IT PUT) opportunely has been taken part with the circular n. 4/2020 of the General Command, turn out instead unsolved the serious problems legacies to the sanitary assessments in confront of the marine workers.
In particular:
1 As it is famous, the Italian armament is subjected to an architecture of sanitary visits only the world. In Italy they are in vigor:
- the biennial visit (former. Art. 12, d.lgs n.71/2015), in compliance with the Rule 1/9 of the Stcw convention and to the Maritime Rule 1/2 of the Labour Conventions;
- the pre-emptive visit of boarding, according to art. the 323 of the Navigation code, turns to assess the suitability to the service of the marine worker;
- the pre-emptive and periodic sanitary assessment carried out from Medico Competente face to assess the suitability to the specific duty of the same marine worker, according to art. the 23 of the D.lgs. 271/99.
In no other productive field of our Country the worker is subordinate to such a amount of sanitary assessments.
The imminent expiration of a high number of which released medical certificates is evidenced as a result of it visits biennial (former art. 12 d.lgs. 71/2015) of marine Italians currently on board that, for various reasons, they cannot disembark in ports foreign countries. To such care, in reason of the difficulties to replace such marine ones, let alone to carry out said visits, it is absolutely necessary that the Health ministry clarifies that the extension until three months of the validity of the medical certificate until the port of call where an authorized doctor (previewed from the art.12 is available, codicil 5, of the D.lgs. 71/2015 and ss.mm.ii.), are granted, in relation to the sanitary emergency in existence, in automatic way.
The sanitary emergency is profitable, in many cases, completely impossible the sanitary assessments periodicals of the marine workers on board by the competent doctors (former art. 23 d.lgs n. 271/99) that, already in normal conditions, they are particularly onerous complexes and from effettuare1. To such care, it would be favorable that the Health ministry on board gives indications in topic of sanitary surveillance so that the competent doctor can postpone, also without the physical presence, the validity of the suitability to the specific duty of the marine one.
6. Commission of visit for renew of the certificates
They exist of the remarkable difficulties to constitute the commission of visit for fundamentalally renews of the safety certificates/suitability on the national territory due to the lack of availability by the doctors of the USMAF, evidently engaged in the management of emergency COVID. It can be thought to a solution that it previews to consider the commission of visit also without the presence of the port doctor valid, or the suspension of every type of visit on board (avoiding in such a way also the crowds of the making people head to the various commission) with the consequent concession of delays compulsory, of the validity at least 60/90 days upon maturity of the certificates; or the possibility that I renew/vidimazione of the certificates is made on the escort of the declaration to the aims released from the Agency of Classifies Recognized.
7. Technical-sanitary commission of visit
In relation to the sanitary visits “technical”, necessary for the verification and the certification of the hygiene and safety at the work place on board of the ships, it is being found that in some circumstances, although all the ships have been equipped of procedures for giving punctual execution to the directives given from the Government, come taxes according to prescription of the 271/99 (for example the review of the Plan of Safety within the fixed time of 7 days) that, being a norm who regards the normal activity of the ships and the appraisal of the expectable “operating risks”, it cannot be used for circumstances exceptional of “biological risk” as those in existence, as not the ricomprende.
8. Procedures of boarding on the Italian territory
For how much it concerns the procedures of boarding and disembarkation of the navigating staff, always by virtue of the exceptional situation of emergency and to the aim to avoid crowds in places and public transport, he would be favorable to preview the limitation of the displacements of the crews near the territorial offices of the Harbour offices in order to regulate it embarks and it disembarks. Proposal that is advanced is that to conform for the moment, also here in Italy, how much already happens in various resorts of the world with the single Commander who goes near the turn consulate in order to regulate on described movements that then will be countersigned in second moment from single the marine ones, to the presence of the Commander and of appropriate witnesses.
9. Fleeting ships and freeways of the sea
The Covid-19 emergency is hitting heavy also the services offered from the fleeting ships, of which Italy is primary world-wide supplier is in the section of the cruises that of the ferries. The field, besides to endure heavy economic repercussions due to a zero setting of the reservations and a meaningful phenomenon of cancellation of the reservations already carried out, risk to see compromised the operativity of the ships that assure the territorial continuity and the freeways of the sea.
Because of the number of passengers drastically reduced, as a result of the necessary limitations to the free circulation of the people introduced from the recent governmental provisions, the companies of navigation engaged in the traffic fleeting (typically with ships RoRo Pax) have minimal tables of overdimensioned safety that turn out at the moment as tied to the maximum number of imbarcabili passengers. A temporary reduction of such tables to the aim to allow with the companies to on board contain the number of marine to all advantage of the health and safety of the same ones would be favorable. In this way, in fact, the interpersonal contacts would be limited and therefore the exposure of the staff to useless risks. Obviously, once the normal conditions of circulation of the people restored, the enforced tables immediately would be restored.
10. Cruises, prohibition of disembarkation in the ports
The next day of the 9 DPCM March 2020, the situation for the crocieristico field in the Italian ports is more and more dramatic being the prohibition of disembarkation of the passengers. Such situation has forced the greatest operators than cruises engaged in the Italian market to stop some dedicated ships at the market national.
Abroad, although all the procedures and protocol on board activated of the ships to the aim to for example avoid the boarding of staff and passengers “to risk” (screening of the body temperature and verification of the Countries visited in last the 14 days before the boarding), the cruise ships that Italian nationals embark endure in various Countries drastic restrictions of the rights of landing place and disembarkation with a serious economic damage and of image.
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The Italian shipowning organizations Assarmatori and Confitarma (Italian Confederation Shipping) and Federagenti, the national federation of the agents and marine raccomandatari, have asked the urgent activation for a table of confront and analysis with the administrations involved in the activities in order to tackle to the emergency coronavirus, crisis - they have emphasized - than shipping the weevers with extreme worry also for the impact that this situation is having and will continue to having on the Italian socioeconomic system.
- Via Raffaele Paolucci 17r/19r - 16129 Genoa - ITALY
