EXPERIENCE OF THE BULGARIAN MARITIME ADMINISTRATION Seminar on the Implementation of measures to ensure that safety standards are “to the Satisfaction of the Administration” Istanbul, Turkey, 26-27 April 2016 ANNA NATOVA

Content VIMSAS AUDIT OF BULGARIA IMPLEMENTATION MEASURES OF THE ADMINISTRATION

Voluntary IMO Audit of Bulgaria Audit team Leslie Hemachandra (Audit Team Leader), Maritime Administration of Sri Lanka Kyriacos Aliouris (Auditor), Maritime Administration of Cyprus Tadeusz Jan Wojtasik (Auditor), Maritime Administration of Poland Igor Sibrin (Observer), Ukrainian Registry of Shipping, Ukraine Scope of the Audit The scope of the audit addressed flag, port and coastal State obligations of the maritime administration of the Republic of Bulgaria.

Voluntary IMO Audit of Bulgaria Flag State activities Implementation The mandatory IMO instruments were sampled as to their implementation as follows: 1. Load Lines Convention; 2. SOLAS Convention; 3. MARPOL Convention; 4. Tonnage Convention; 5. STCW Convention; and 6. COLREG Convention. „

Voluntary IMO Audit of Bulgaria Observations ...2 It was established that guidance or interpretation concerning those requirements found in several mandatory IMO instruments that are to the satisfaction, discretion or opinion of the Administration are not provided. Corrective Action A quality procedure will be drafted on interpretation and implementation of the provisions of all relevant mandatory IMO instruments, which grants discretion to the Administration to decide on approvals and exemptions from the application of certain requirements. The deadline for the implementation of this action is 1 September 2009. „8.2.9 One particular area, which is of interest and is also significant in the implementation of mandatory requirements, is paragraph 16.5 of the Code – “to the satisfaction of the Administration”. The audit team has verified during the audit that the Administration interprets this phase on a case- by-case basis. However, the BMA was not able to provide to the audit team relevant applicable guidance for any mandatory IMO Instrument. 8.2.10 It was established that guidance or interpretation concerning those requirements that are to the satisfaction, discretion or opinion of the Administration, are not provided.“

Voluntary IMO Audit of Bulgaria Conclusions of the Report Areas of positive development Areas for further development 11.16 Procedures should be developed to apply the vague expression “to the satisfaction of the Administration” as contained in the various mandatory IMO instruments.

Actions taken by the Administration Ordinance 54 on maritime equipment – ammendments 2009 transposed the Council Directive 96/98/EC on marine equipment - uniform application of the relevant international instruments relating to equipment to be placed on board ships for which safety certificates are issued by or on behalf of Bulgarian maritime administration Annex I EQUIPMENT FOR WHICH DETAILED TESTING STANDARDS ALREADY EXIST IN INTERNATIONAL INSTRUMENT

Annex II EQUIPMENT FOR WHICH NO DETAILED TESTING STANDARDS EXIST IN INTERNATIONAL INSTRUMENTS

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