1. 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, April 2016
ANNA NATOVA

2. Content VIMSAS AUDIT OF BULGARIA
IMPLEMENTATION MEASURES OF THE ADMINISTRATION

3. 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.

4. 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. „

5. 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 It was established that guidance or interpretation concerning those requirements that are to the satisfaction, discretion or opinion of the Administration, are not provided.“

6. 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.

7. Actions taken by the Administration
Ordinance 54 on maritime equipment – ammendments 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

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

10. Thank you for your attention