Guidance

MGN 637 (M) International code for ships operating in polar waters (Polar Code)

Published 17 January 2022

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Summary

The International Code for Ships Operating in Polar Waters (“the Polar Code” or “the Code”), which was developed in the International Maritime Organization (“IMO”), is mandatory under both the International Convention for the Safety of Life at Sea, 1974 (SOLAS) and the International Convention for the Prevention of Pollution from Ships, 1973 (MARPOL). Through goal-based standards, the Polar Code covers the full range of design, construction, equipment, operational, training, search and rescue and environmental protection matters relevant to ships operating in the inhospitable waters surrounding the two poles.

The Merchant Shipping (Polar Code) (Safety) Regulations 2021 implement the safety requirements of the Polar Code into UK domestic shipping legislation.

This guidance note considers the safety related provisions of the Polar Code. Reference should also be made to the guidance contained in the Polar Code (part I-B), and to the IMO guidelines referenced in the Polar Code. Separate guidance is available in relation to the pollution prevention provisions in the Polar Code (MGN 632 (M+F)).

1. Background

1.1 The safety of ships operating in the harsh, remote and vulnerable polar areas, and the protection of the pristine environments around the two poles, have always been matters of concern for the IMO and many relevant requirements, provisions and recommendations have been developed over the years.

1.2 Trends and forecasts indicate that polar shipping will grow in volume and diversify in nature over the coming years and these challenges need to be met without compromising either safety of life at sea, or the sustainability of the polar environments.

1.3 Ships operating in the Arctic and Antarctic environments are exposed to a number of unique risks. Poor weather conditions and the relative lack of good charts, communication systems and other navigational aids pose challenges for mariners. The remoteness of the areas makes rescue or clean-up operations difficult and costly. Cold temperatures may reduce the effectiveness of numerous components of the ship, ranging from deck machinery and emergency equipment to sea suctions. When ice is present, it can impose additional loads on the hull, propulsion system and appendages.

1.4 The Polar Code covers the full range of design, construction, equipment, operational, training and manning, search and rescue and environmental protection matters relevant to ships operating in the inhospitable waters surrounding the two poles.

1.5 The move to develop a mandatory code followed the adoption by the IMO Assembly, in 2009, of guidelines for ships operating in polar waters (Resolution A.1024(26)), which were intended to address those additional provisions deemed necessary for consideration beyond existing requirements of the SOLAS and MARPOL Conventions, and in order to take into account the climatic conditions of polar waters and to meet appropriate standards of maritime safety and pollution prevention. As the guidelines were only recommendatory, further work was undertaken in the IMO to develop a mandatory regime.

1.6 The Polar Code and related amendments to SOLAS were adopted during the 94th session of the IMO’s Maritime Safety Committee, in November 2014. SOLAS was amended to insert a new Chapter XIV, which incorporated the safety related measures in the Polar Code. The environmental provisions were adopted as amendments to Annexes I, II, IV and V of MARPOL during the 68th session of the Marine Environment Protection Committee (MEPC) in May 2015. The Code came into force internationally on 1st January 2017. The safety provisions of the Polar Code are implemented in the Merchant Shipping (Polar Code) (Safety) Regulations 2021 (“the Polar Code Regulations”).

1.7 Whilst Arctic and Antarctic waters have a number of similarities, there are also significant differences. The Arctic is an ocean surrounded by continents while the Antarctic is a continent surrounded by an ocean. The Antarctic sea ice retreats significantly during the summer season or is dispersed by permanent gyres in the two major seas of the Antarctic: the Weddell and the Ross. Thus, there is relatively little multi-year ice in the Antarctic. Conversely, Arctic sea ice survives many summer seasons and there is a significant amount of multi-year ice. Whilst the marine environments of both polar seas are similarly vulnerable, response to such challenge should duly consider specific features of the legal and political regimes applicable to their respective marine spaces. The Polar Code aims to address these differences by providing a universal set of operating standards for vessels entering polar waters.

2. Ambulatory reference

2.1 The majority of the provisions in Chapter XIV and the Polar Code are cross-referenced in the Polar Code Regulations and the Regulations contain an ambulatory reference provision. This means that future amendments to the referenced provisions of Chapter XIV and the Polar Code in the Polar Code Regulations will automatically become part of UK law when they enter into force internationally. No further legislation will be required to bring amendments into force in the UK unless the change is outside the scope of the matters referenced in the Regulations; this is expected to be rare.

2.2 From a practical perspective, this means that ship owners, shipbuilders, and other interested parties can refer directly to the text of SOLAS Chapter XIV to determine both the UK and international requirements.

3. Definitions

3.1 “Standards” means Standards referenced in this Note and the Polar Code as being acceptable and may include BS (British Standard), EN (European Standard accepted by the European Committee for Standardisation, CEN), IEC (International Electrotechnical Commission), ISO (International Organisation for Standardisation), MED (Marine Equipment Directive), MARPOL (International Convention for the Prevention of Pollution from Ships), SOLAS (International Convention for the Safety of Life at Sea), IMO Fire Test Code, STCW (Standards of Training, Certification and Watchkeeping), the LSA Code (Life Saving Appliances), and includes any standards that amend or replace them.

4. Polar Code Summary

4.1 The Polar Code is intended to cover the full range of shipping-related matters relevant to navigation in waters surrounding the two poles: ship design, construction and equipment, operational and training concerns, search and rescue, and, equally important, the protection of the unique environment and ecosystems of the polar regions.

4.2 The Code includes mandatory measures covering safety (part I-A) and pollution prevention (part II-A) and guidance for both (parts I-B and II-B). Careful consideration should be given to this guidance.

4.3 The Code requires ships intending to operate in the defined waters of the Antarctic and Arctic to have a Polar Ship Certificate. There are three categories of ship that may be provided with a Polar Ship Certificate: Categories A, B and C. Category A covers ships designed for operation in polar waters at least in medium first-year ice, which may include some old ice. Category B ships are those designed for operation in polar waters in at least thin first-year ice, which may also include some old ice. A Category C ship is one which is designed to operate in open water or in ice conditions less severe than those included in Categories A and B. A ship operating, or intending to operate in polar waters, must have a Polar Ship Certificate and which is to be held on board. Failure to comply with either requirement is a criminal offence.

4.4 Before a certificate can be issued, the ship must be assessed in respect of the anticipated range of operating conditions and hazards the vessel might encounter in the polar waters. This operational assessment must be organised by the owner, manager and/or operators of the vessel. The assessment must include information on identified operational limitations and plans or procedures or additional safety equipment necessary to mitigate incidents with potential safety or environmental consequences. Further information on certification is provided in section 7.

4.5 A Polar Water Operational Manual (PWOM) must be carried on board a ship to provide the owner, manager, operator, master and crew with sufficient information regarding the ship’s operational capabilities and limitations in order to support their decision-making process. It is critical that the ship is operated in compliance with the procedures contained in the PWOM and failure to do so is a criminal offence.

4.6 The various chapters in part I-A of the Code each set out goals and functional requirements and include: ship structure, stability and subdivision, watertight and weathertight integrity, machinery installations, operational safety, fire safety/protection, life-saving appliances and arrangements, safety of navigation, communications, voyage planning, and manning and training. Part II-A covers prevention of pollution in polar waters (for further information, see section 6).

5. Impact of the Polar Code on ship safety

5.1 Ships sailing in polar waters must carry equipment capable of clearing melted ice, freezing rain, snow, mist, spray and condensation from the windows on the bridge. All lifeboats must be partially or completely enclosed. There must be adequate thermal protection for all persons on board; on passenger ships, an immersion suit or thermal protective aid for each person must be available. Special ice equipment for ice removal, such as electrical and pneumatic devices, and tools such as axes or wooden clubs must be on board the vessel. Extinguishing equipment, operable in cold temperatures, must be protected from ice. These extinguishers must be suitable for persons wearing bulky and cumbersome cold weather gear.

5.2 With regard to vessel design and construction, there are, as mentioned above, three categories of ship which can operate in polar waters. These are based on whether a ship is equipped for operation in medium first-year ice, thin first-year ice, or ce conditions less severe than the first two categories. Sufficient stability in intact condition when subject to ice accretion is paramount and stability calculations must take into account the icing allowance. Ships intended to operate in low air temperatures must be constructed with materials suitable for operation in such temperatures. In ice strengthened vessels, the structure of the ship must be able to resist both global and local structural loads.

6. Protection of the environment

6.1 Part II-A of the Polar Code sets out the mandatory pollution prevention measures in respect of polar waters. Each chapter of part II-A supplements the obligations in MARPOL Annexes I, II, IV and V (respectively, prevention of pollution by oil, noxious liquid substances in bulk, sewage and garbage) where a ship operates in polar waters. These obligations have been implemented in UK law in merchant shipping regulations implementing Annexes I, II, IV and V of MARPOL [footnote 1]. Guidance is available to supplement the legislation for the implementation of MARPOL Annexes IV and V (MGN 631 (M+F) and MGN 632 (M+F) Amendment 1).

7. Training and manning requirements

7.1 The seafarer training and certification requirements of the Polar Code (Chapter 12) are implemented by regulations 13 and 14 of the Polar Code Regulations.

7.2 Chapter 12 of part 1-A of the Polar Code (manning and training) requires companies to ensure that masters, chief mates and officers in charge of a navigational watch on board ships operating in polar waters have completed appropriate training, taking into account the provisions of the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (‘STCW Convention’) and the Seafarers’ Code for the Standards of Training, Certification and Watchkeeping (‘STCW Code’), which is part of the STCW Convention.

7.3 The minimum requirements for the training and qualifications of masters and deck officers on ships operating in polar waters were adopted by the IMO’s Maritime Safety Committee in November 2016. They became mandatory under the STCW Convention and Code from 1st July 2018. These amendments require compliance with the provisions of chapter 12 of part 1-A of the Polar Code. The requirements are summarised below:

  • All masters, chief mates and officers in charge of a navigational watch on ships operating in polar waters must hold a Certificate of Proficiency (‘CoP’) in Basic Training for Ships Operating in Polar Waters in accordance with STCW Convention Regulation V/4, paragraph 1.
  • A master or chief mate on a ship operating in polar waters must hold a CoP in Advanced Training for Ships Operating in Polar Waters in accordance with STCW Convention Regulation V/4, paragraph 2. [footnote 2]

For use on UK registered vessels, the MCA, along with UK issued CoPs for training in Basic and Advanced Training for Ships Operating in Polar Waters, will also accept a CoP issued by another country if it is from a country from which a Certificate of Competency (‘CoC’) may be accepted towards the issue of a UK Flag State Endorsement (‘FSE’) or Certificate of Equivalent Competency (‘CEC’).

7.4 Further guidance for the training and certification requirements for personnel working on ships operating in polar waters is available in MIN 595(M) (Amendment 1) or any subsequent publication. [footnote 3]

7.5 Ships may allow the use of a person(s) other than the master, chief mate or officer in charge of a navigational watch, to take the place of such crew member where that crew member is unavailable. This means that the replacement crew member will not have the training described in paragraph 7.3, so particular restrictions are imposed. These are:

(a) The person(s) holds a Master or Chief Mate unlimited UK CoC or UK FSE/CEC (see Merchant Shipping Notice 1867(M)) and meets the training requirements set out in the table below (section 7.5);

(b) While operating in polar waters, the ship has sufficient number of persons meeting the appropriate training requirements for polar waters to cover all watches;

(c) The person(s) are subject to the UK’s minimum hours of rest requirements at all times; [footnote 4]

(d) When operating in waters other than open waters or bergy waters,[footnote 5] the master, chief mate and officers in charge of a navigational watch on passenger ships and tankers must meet the applicable basic training requirements noted MIN 595 (Amendment 1);

(e) When operating in waters with ice concentration of more than 2/10, the master, chief mate, and officers in charge of a navigational watch on cargo ships other than tankers must meet the applicable basic training requirements noted in MIN 595 (Amendment 1);

(f) The use of a person other than the officer of the navigational watch to satisfy the requirements for training does not relieve the master, chief mate, or officer of the navigational watch from their duties and obligations for the safety of the ship.

7.6 Table setting out the training requirements for masters and deck officers who are used as replacement crew members in accordance with section 7.5 of this MGN.

Ice Conditions Tankers Passenger ships Other
Ice free Not applicable Not applicable Not applicable
Open Waters Basic training for master, chief mate and officers in charge of a navigational watch Basic training for master, chief mate and officers in charge of a navigational watch Not applicable
Other waters Advanced training for master and chief mate. Basic training for officers in charge of a navigational watch Advanced training for master and chief mate. Basic training for officers in charge of a navigational watch Advanced training for master and chief mate. Basic training for officers in charge of a navigational watch

7.7 Every crew member must be made familiar with the procedures and equipment contained or referenced in the Polar Water Operational Manual (PWOM) [footnote 6] relevant to their assigned duties.

7.8 All requests by UK training providers (noting that a shipping company may be considered a training provider) for MCA approval to deliver Polar Code Training and subsequently issue a Certificate of Proficiency (Basic or Advanced) programmes, should be addressed to the surveyor in charge of their local MCA Marine Office. Overseas course approvals must be directed to the Seafarer Services Branch: stc.courses@mcga.gov.uk. Training providers must meet the requirements set out in regulation 9 of the Polar Code Regulations and in the Annex to this MGN. Training providers must build into their Quality Management System the requirements outlined in MIN 595 (Amendment 1) and this MGN.

8. Voyage Planning in Remote Areas

8.1 In November 2007, the IMO Assembly adopted Resolution A.999(25) - guidelines on voyage planning for passenger ships operating in remote areas. This was in response to the growing popularity of ocean travel for passengers and the desire for exotic destinations, which have led to increasing numbers of passenger ships operating in remote areas. When developing a Polar Water Operations Manual (PWOM) for voyages to remote areas, special consideration should be given to the environmental nature of the area of operation, the limited resources, and navigational information.

8.2 The detailed voyage and passage plan should include the following safety-related factors: safe areas and no-go areas, surveyed marine corridors, if available, and contingency plans for emergencies in the event of limited support being available for assistance in areas remote from search and rescue facilities.

8.3 In addition, the detailed voyage and passage plan for ships operating in Arctic or Antarctic waters should include the following factors: conditions when it is not safe to enter areas containing ice or icebergs because of darkness, swell, fog or pressure ice, safe distance to icebergs, presence of ice and icebergs, and safe speed in such areas.

9. Approvals and Polar Ship Certificate

9.1 The Secretary of State, or anyone authorised by the Secretary of State, may grant an approval in relation to a United Kingdom ship for anything in part 1-A of the Polar Code requiring the consent of a flag State.

9.2 Equipment required under part 1-A of the Polar Code and placed on board a United Kingdom vessel, must be of a type that has been approved under the Merchant Shipping (Marine Equipment) Regulations 2016 (S.I. 2016/1025). The 2016 Regulations contain the approval procedure and testing requirements.

9.3 To apply for a Polar Ship Certificate, a shipowner, or manager or operator, should contact a Certifying Authority. A survey will then be conducted. If satisfied that the ship complies with the requirements for ships operating in polar waters, the Certifying Authority will advise the Foreign, Commonwealth and Development Office (FCDO), which has overall policy responsibility for polar waters, that certification has been granted.

9.4 Owners and operators should ensure that once certification has been obtained that they have the correct permissions from the relevant government(s) in place to operate within polar waters.

More Information

UK Technical Services Ship Standards
Maritime and Coastguard Agency
Bay 2/21
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Tel: +44 (0) 203 817 2450

Email: marinetechnology@mcga.gov.uk

Annex: Approval of Polar Code courses

In accordance with regulation 9 of the Polar Code Regulations, all training providers planning to offer education and training leading to certification under these regulations will need to obtain MCA approval. The requirements for that approval are set out in this Annex. This procedure covers all ‘short’ courses that lead to the issue of a Certificate of Proficiency (CoP) in basic and advanced training for service on ships operating in polar waters.

This Annex sets out the requirements that a potential training provider must meet in order to be approved and, as an approved training provider, continue to meet while such services are provided by them. It also seeks to clarify the expectations the MCA has from a training provider, and what a training provider can expect from the MCA. This Annex includes a requirement for companies to sign a declaration prior to the MCA undertaking a course approval or reapproval.

Training providers must meet the requirements specified in the MCA course criteria guidance. The course criteria ensure the requirements of the STCW Convention and STCW Code are met.

1. Course Approval Introduction

1.1 Definitions

Short Course: Is a generic term used for an MCA approved or recognised course that leads to a Certificate of Proficiency, or attestation that the ‘Documented Evidence of a Standard’ has been met (normally a course completion certificate).

Certificate of Proficiency: A certificate, other than a Certificate of Competency or a Flag State Endorsement (FSE)/Certificate of Equivalent Competency (CEC), issued to a seafarer stating that the relevant requirements of training, competencies, or seagoing service under the STCW Convention, as implemented in the Polar Code Regulations, have been met. Details of the appropriate certificate regulations can be found in the MCA criteria guidance or in Marine Information Note (MIN) 595 (Amendment 1).

MCA Criteria Guidance: This is course specific guidance to show how to meet the applicable STCW Convention and STCW Code requirements.

Online: These are courses taught via an online learning package which would normally be delivered in a classroom environment. This is only normally available for theory-based courses that have no practical requirements.

Peripatetic: This is where a course can be delivered at any site that meets the requirements of the facilities and equipment specifications detailed in section 4.3 of this Annex. Peripatetic delivery of the Basic Polar Code training is only permitted within the UK. Advanced training for the Polar Code must be completed at a fixed location.

Multisite: Where a course can be conducted at different MCA approved fixed locations. [footnote 7] An MCA surveyor would need to inspect each site when approving the course to ensure it is suitable and meets the MCA criteria requirements to deliver the course. Realistically, a training provider should not have more than 2 sites. If more are required, then this should be covered by the peripatetic course delivery requirements. If the training provider is operating from two or more different sites for multiple courses, then it would be standard practice for separate approval to be obtained for each site (from the Marine Office nearest each centre) to ensure the facilities meet, and continue to meet, the MCA criteria requirements.

Onsite Inspection: This is where an MCA surveyor attends and observes a course. Ideally, this will be in person, but there is an option to observe the course remotely. Where remote assessment takes place a training provider must ensure they have adequate:

  • Telecommunications applications and equipment for MCA surveyors to remotely observe a course. This will include access to ‘MCA compatible’ online platforms.
  • If required, self-mounted ‘action’ video camera(s) that can be attached to assessor(s) or temporarily mounted cameras within simulators that can show the delivery of the practical elements required by the MCA course guidance.
  • Permission from the facilities managers and candidates to film in accordance with GDPR or the applicable national data protection laws.

1.2 Further information

Overseas and Online Course approvals must be directed to the Seafarer Services Branch: stc.courses@mcga.gov.uk. Marine Offices must also inform the Seafarer Services Branch of any peripatetic (only to be delivered within the UK requests).

1.3 Mandatory Course Approval

A training provider must meet the requirements specified in the MCA course criteria guidance. The adopted policy gives the training provider the flexibility to design their own courses based upon a common framework that meets the obligations applicable to the STCW Code.

Training providers must have access to the latest course criteria (booklet or online access). Further information on where to obtain this guidance is available from the MCA.

2. The Short Course Approval Process

2.1 Please note that while a training provider must have an effective quality management system (QMS) there is no requirement for it to be certified. A training provider’s QMS must be designed to meet the MCA’s requirements. [footnote 8] The QMS must ensure the conditions detailed in sections (a) – (j) from section 2.3.2 of this Annex are met. A QMS should include details of all desk instructions, procedures, forms, requirements of team meetings and close out of actions, customer feedback, record keeping databases, data retention guides, certificate templates, ongoing monitoring of training and facilities, assessments, staffing responsibilities (including admin, trainers and assessors) and formal reviews. The QMS must be developed to ensure the MCA requirements set out in this Annex and the STCW Code applicable to each course (see MCA Criteria Guidance) are met.

2.2 Where a training provider is proposing an equivalent to a requirement listed in the MCA criteria guidance, they, or an MCA Marine Office, must inform Seafarer Services of the proposal (stc.courses@mcga.gov.uk). Equivalence can only be granted where it is stated that this is an option in the MCA criteria guidance. Seafarer Services will keep a list of accepted equivalences which will be available on request. The Chief Examiner, with assistance from their technical staff, will decide on any new proposals of ‘equivalence’. It is the responsibility of the training provider to ensure Seafarer Services has approved an alternative proposal.

2.3 Initial approval

2.3.1 Desk top submission

  • (a) Training providers must obtain the applicable MCA publication(s);

  • (b) If the training provider is a new overseas provider without previous MCA approval, then the MCA must carry out an initial ‘desk top’ assessment to ensure suitability of the proposal. The training provider should provide the following information:

    • Which course/s they seek approval for;
    • Teaching notes;
    • Photographs or plans of the facilities where the courses will be delivered;
    • CVs for the teachers and staff;
    • Details of the QMS; and
    • The maritime qualifications of the teaching staff.

  • (c) The training provider should contact the local MCA Marine Office (MO) or Seafarer Services when it is ready for assessment – if the course delivery is to be carried out overseas, then the training provider must contact the Seafarer Services Branch: stc.courses@mcga.gov.uk. Training providers must provide a written submission of their proposed course/s including:

    • A mapping to the appropriate MCA criteria guidance ‘outcomes’ and ‘learning objectives’;
    • Methods and media of delivery including teaching notes, presentations, hand-outs, etc.;
    • Lesson plans;
    • Details of the assessment processes;
    • Details of the course duration;
    • Details of the tutors and assessors (including names, qualifications and experience);
    • Details of the training providers Quality Management System (QMS) procedures (see 2.3.2); and
    • Description of the venue and equipment.

2.3.2 The Requirements of the QMS

The desktop assessment is commenced on receipt of the above and aims to ensure that the training centre has a formally documented health and safety management system and a QMS that ensures:

  • (a) A continued satisfactory delivery of the programme to the current standards, reflecting changes of technology and best practice(s);
  • (b) The training programme entry standards are met;
  • (c) Where a written assessment or a practical examination is required, the same person does not carry out the training and assessment of the programme. Where two people are acting as instructors they may alternate between assessor and instructor. QMS procedures should detail how the assessment is quality assured and, if required, how continuous practical assessment is achieved.
  • (d) Only those who complete the training programme and meet any other necessary requirements are issued with certificates/documentary evidence;
  • (e) Certificates are issued in a format that meets the MCA requirements (available in the MCA criteria guidelines);
  • (f) Records of certificates issued are securely maintained until the 70th birthday of the certificate holder or 5 years from the date of issue, whichever is the longer;
  • (g) The record system enables the authenticity of certificates to be verified and replacement certificates to be issued;
  • (h) Where approved for peripatetic delivery, a formal risk assessment (see section 4.3 of this Annex) is carried out to ascertain the suitability of each venue and records of such assessment are retained for 5 years;
  • (i) The approving MCA Marine Office has information about the dates, timing and venues of all courses delivered;
  • (j) Any changes made to the course content, facilities, equipment, training staff or other matters that may affect the delivery of the programme are reported to the approving Marine Office without delay; and
  • (k) Where required, evidence of approved seagoing service must be submitted for the issue of a CoP. The approved training provider will need to store this for a minimum period of 7 years and this must be made available to the MCA on request. Further information on the approved seagoing service requirements are available in MIN 595 (Amendment 1).

Poor submissions [footnote 9] will be returned with only a high-level brief for improvement. The MCA may set a reasonable timeframe before a re-submission can be made, of 3 months, or if rejected for the second time, 6 months. When the MCA is satisfied with the submission a Pilot Approval date for attending the first course will be agreed – the MCA Surveyor will alert the Seafarer Services Branch and request a Pilot Approval number to be forwarded to the training provider.

When the MCA is satisfied with the submission the application will move to the onsite approval stage; the MCA will agree a date with the applicant to attend a pilot course. The course provider can then advertise the pilot course, ensuring that candidates are informed that it is a pilot course and that the provider must meet the MCA approval standard before any CoP or Documentary Evidence of meeting the standard can be issued to candidates. The MCA logo must not be used to advertise a pilot course. Further courses cannot be advertised until full MCA approval has been granted.

2.4 Onsite approval

  • (a) The MCA will attend the course, carry out the approval process against the requirements of the MCA criteria guidance and the requirements in points (a) – (j) of section 2.3.2 of this Annex. If there are non-conformities the MCA may:

    • Assess and (if satisfied) agree non-conformities have been addressed without another visit; the MCA may request evidence such as photographs, updates to desk instructions, new staff CV etc. Where the MCA requests such evidence, a deadline should be agreed for the applicant to provide the evidence requested and that deadline should be recorded on the report.
    • Issue an approval certificate, after which an onsite visit will be required. An approval certificate for a longer term will be issued if the course provider satisfactorily remedies non-conformities. Any such longer approval certificate that is granted will be valid for 5 years from the date that the provisional approval certificate was issued.
  • (b) If there are major non-conformities (see section 2.10 of this Annex) then the MCA may refuse the application for approval.
  • (c) On receipt of a satisfactory ‘Approval Report’ from the MCA Surveyor, Seafarer Services will send out an original approval certificate and letter to the training provider.
  • (d) If the attending MCA surveyor is content that the course meets the MCA criteria guidance, then they can issue an approval letter for an initial period. This would allow the MCA surveyor to complete the audit report and submit to Seafarer Services for issue of a five-year approval.

2.5 Additional requirements

Attention is also drawn to the following additional requirements:

  • (a) Course Intake Limitations: Course documentation should include the maximum number of candidates to be enrolled on each course, taking account of the MCA criteria where appropriate. For monitoring purposes, the number of candidates on each course must be maintained for subsequent validation as part of the training provider’s training records.
  • (b) Staff Requirements: initial approval will require sight of proof of the professional and teaching/assessing qualifications listed for each trainer/assessor. If peripatetic trainers are utilised, more than one visit may be necessary. If equipment is not available at each premises used, appropriate arrangements must be in place for transporting equipment.
  • (c) Facilities and Equipment: the training facilities must be large enough for the number of candidates to be trained, where appropriate allowing for demonstrations and practical exercises included in the MCA criteria guidance. Premises or training rooms must be well lit, ventilated and have adequate heating. There must be access to nearby toilets and hot and cold water.

2.6 Mid-Term

Location UK: A mid-term inspection may take the form of either a desktop assessment or a site inspection or both. The MCA will complete this in accordance with points (a) – (j) of section 2.3.2 of this Annex.

Overseas (non-UK) Courses: An onsite mid-term visit must always take place due to the risk associated with non-UK course approvals. These must be completed by Seafarer Services or under the supervision of Seafarer Services.

  • (a) The MCA will contact the training provider to advise that a mid-term audit is due.
  • (b) The MCA may re-request any course materials for any of the MCA approved or voluntarily recognised courses.
  • (c) The MCA will arrange to visit the provider and complete a mid-term onsite inspection in accordance with points (a) – (j) of section 2.3.2 of this Annex.

  • (d) It is not necessary for the MCA to observe all approved courses, but at least one course should be observed and the QMS reviewed against the criteria set out in points (a) – (j) of section 2.3.2 in this Annex. If there are non-conformities the MCA may:

    • Assess and (if satisfied) agree all non-conformities are addressed without another visit; the MCA may request evidence such as photographs, updates to desk instructions, new staff CV etc. Where the MCA requests such evidence, a deadline should be agreed for the applicant to provide the evidence requested and that deadline should be recorded on the report.
    • Request a follow up onsite visit to ensure the course provider has satisfactorily remedied any non-conformities.

  • (e) If there are major non-conformities (see section 2.10 of this Annex) the MCA can either:

    • Suspend approval of the training provider and advise that the non-conformities be remedied before approval can be reinstated (this decision may be appealed pursuant to regulation 10 of the Polar Code Regulations). This may be subject to the assessment of another onsite visit; or
    • Cancel the approval (which decision may be appealed pursuant to regulation 10 of the Polar Code Regulations) and suggest the training provider makes a new application.

2.7 Re-approval

  • (a) The training provider should notify the MCA in writing that re-approval is due and that the training provider wishes to be considered for re-approval at least 6 months in advance of the expiry of an approval certificates.
  • (b) The MCA may request to be provided with any course materials for any of the MCA approved/recognised courses subject to re-approval.
  • (c) The MCA will arrange an onsite visit to the training provider and complete a re-approval audit.

  • (d) The MCA must observe the courses running and review the QMS against the criteria set out in points (a) – (j) of section 2.3.2 of this Annex. However, where a course has an advanced version, the MCA may only witness the advanced course and carry out a desk top review of the elementary version. If there are non-conformities the MCA may:

    • Assess and (if satisfied) agree that non-conformities have been addressed without another visit; the MCA may request evidence such as photographs, updates to desk instructions, new staff CV etc. Where the MCA requests such evidence a deadline should be agreed for the applicant to provide the evidence requested and that deadline should be recorded on the report.
    • Issue an approval certificate, after which, an onsite visit will be required. This may initially be issued for a limited period of time. An approval certificate for a longer period will be issued if the course provider satisfactorily remedies all non-conformities. Any such approval certificate that is granted will be valid for 5 years from the date that the initial approval certificate was issued.
  • (e) If there are major non-conformities (see section 2.10 of this Annex) the MCA can either cancel or suspend the approval (which decision may be appealed pursuant to regulation 10 of the Polar Code Regulations).
  • (f) On receipt of a satisfactory re-approval report, Seafarer Services will send out an original re-approval certificate and letter to the training provider.
  • (g) If the attending MCA surveyor is content that the course meets the MCA criteria guidance and the requirements of this Notice, they can issue an approval letter for a reduced/limited period. This would allow the MCA surveyor to complete the audit report and submit the documents to Seafarer Services for the issue of the longer (five year) approval certificate.
  • (h) The MCA surveyor will need to complete a sample check for evidence of the approved seagoing service required prior to the issue or revalidation of an Advanced Polar Code Certificate of Proficiency. The seagoing service requirement is the completion of at least 2 months seagoing service as a Deck Officer within the last five years’ service while in polar waters or equivalent.

2.8 Reapproval for Centres with Multiple Courses

Where a training provider has approval for Basic and Advanced Polar Code Training, the MCA does not need to witness both courses. The MCA surveyor must witness the Advanced course; however, they can complete a desk top assessment for reapproval to run the Basic training course. [footnote 10]

2.9 Special audit

A Special Audit is designed to cover any other situations arising where the MCA has concerns that standards are not being met or that the circumstances associated with the delivery of the course have changed. This could include a training provider management takeover, complaint from attendees, change of venue, major changes to the syllabus, concerns raised through whistleblowing, concerns raised by other maritime professionals or auditors etc. This is permitted by the monitoring provisions in regulation 9 of the Polar Code Regulations.

  • (a) Special Audits may be undertaken with or without notice.
  • (b) The MCA Surveyor will inform Seafarer Services of any special audit by email.
  • (c) The MCA must observe the courses running and review the QMS against the criteria set out in points (a) – (j) in section 2.3.2 of this Annex.
  • (d) If there are major non-conformities (see section 2.10 of this Annex) then the MCA can cancel or suspend the approval (which decision may be appealed pursuant to regulation 10 of the Polar Code Regulations).
  • (e) If any non-conformities are found and resolved the MCA will contact Seafarer Services (currently by email) including any relevant evidence and correspondence.

2.10 Major non-conformities

If the MCA identifies major non-conformities, then on consultation with Seafarer Services the course approval may be suspended or cancelled. If a training provider’s approval were cancelled pursuant to regulation 9 of the Polar Code Regulations an appeal may be lodged against the decision within 21 days of that decision (regulation 10 of the Polar Code Regulations). The MCA may delay any other course approvals awaiting the close out of the major non-conformities. Major non-conformities are summarised below:

  • Failure of management to implement a QMS system to ensure the required standards set out in STCW are met prior to the issue of a CoP or the required Documented Evidence of a Standard being met;
  • Teaching of the wrong practices or delivery of incorrect assessments that could endanger the seafarer while training or working at sea;
  • Health and safety issues that could endanger course participants and those delivering the training;
  • Delivery of courses at locations not approved by the MCA; or
  • Fraudulent or illegal activity.

2.11 Online Approved Training Provider (ATP) List

Unless otherwise instructed, the MCA will publish the Approved Training Providers (ATP) details against the course approval(s) they have to the public via www.gov.uk. Seafarer Services aims to update the list with new additions at the end of each month. [footnote 11]

While every effort will be made to provide accurate information, the training provider is responsible for checking its details and notifying the MCA where any corrections are required. If the training provider is not on the ATP list or if its details are incorrect, the training provider should email: stc.courses@mcga.gov.uk.

2.12 Change of a Training Provider’s contact details

Changes in details such as changes to a company’s name, telephone numbers, website addresses, emails etc. should be sent to the Seafarer Services Branch by email (stc.courses@mcga.gov.uk). If required, the Seafarer Services Branch will issue a new approval certificate to the training provider, copying in the local MCA Marine Office. A change of address may lead to a ‘Special Audit’ (see section 2.3.2 in this Annex).

2.13 Extension of Approvals Certificate

Where the MCA has not been able re-approve a course within the specified time scale a 12-month extension to the validity of an approval may be granted. A questionnaire available from the Seafarer Services Branch should be sent to a training provider who must complete and return to the MCA to ensure that the required standards of this Annex are still being maintained. On successful review of the questionnaire, the MCA may issue a formal letter to extend the course validity by up to 12 months. The responsible Marine Office must send a scanned copy of the extension letter to the training provider and Seafarer Services Branch: stc.courses@mcga.gov.uk. Extensions beyond this time must be referred to the Chief Examiner at the MCA, who under exceptional circumstances may grant an extension of an approval for more than 12 months.

Where a course cannot be re-approved within 6 months of the expiry due to the fault of the provider, the course may be cancelled by the MCA and the course provider will be required to seek full MCA approval if they wish to run the course again. On confirmation from the MCA Surveyor, Seafarer Services will issue a termination letter.

3. Who can approve courses and who can be a trainer/assessor

3.1 MCA Course Approvals/Recognition:

These can only be completed by an MCA approved member of staff.

3.2 The Approved Training Providers Trainer/Assessor:

The trainer and assessor must:

  • Have attended and successfully completed the course OR can demonstrate contextual awareness (seafarer’s perspective);
  • Have completed the Train the Trainer course or equivalent/higher;
  • Have relevant qualifications and experience (see applicable guide);
  • Meet the requirements stated in the MCA criteria guidance (where any equivalent is proposed Seafarer Services must approve); and
  • Demonstrate awareness of up-to-date practices by Continued Professional Development (CPD).

If the MCA Surveyor has any questions relating to acceptance, they can email stc.courses@mcga.gov.uk for a decision.

4. Further information

4.1 Management of Course Approvals/Re-Approvals

All MCA approved/recognised training providers are responsible for ensuring that they hold a valid approval for each course they deliver. If there is any doubt as to when an approval is due to expire, training providers should contact their local MCA Marine Office, or if located outside of the UK the Seafarer Services Branch, for advice about when an approval for a course is due to expire.

Once an approval for a course has expired, a course provider must not continue to deliver that course unless a course provider has been granted an extension to the validity of an approval certificate as noted in section 2.10 of this Annex.

4.2 Additional Requirements for Online Courses

In addition to the approval/reapproval requirements, the training provider must also meet the following criteria:

  • Course completion verification – the guarantee that the course is completed by the seafarer applying for the certification.
  • Adequate assessment – the guarantee that the minimum contact hours will be met, and that the assessment is thorough and robust enough to ensure the course outcomes and objectives are met.
  • Any training on board a ship must be completed within the hours of work and rest regulations and a declaration must be signed by the Master of the ship to confirm that the individual undertaking the course complies with this requirement. [footnote 12]

4.3 Additional Requirements Peripatetic Training

Peripatetic training can only be granted for the Basic Polar Code Training within the UK. If a training provider plans to deliver a course peripatetically within the UK, they must apply for peripatetic approval and inform Seafarer Services. The training provider must complete and document a risk assessment for each site it uses. The following additional requirements are:

  • (a) The training provider must carry out and keep a risk assessment of each course it delivers (this must be held on file for 5 years). The risk assessment must cover the suitability of the venue (see sections 2.9 and points (c), (e) and (h) below). They must also ensure that the venue is a safe environment that does not put the candidates or trainers at risk.
  • (b) The training provider must inform the MCA of every course planned to run at least 3 weeks before the course commences. Where this is not possible due to a request at short notice, the training provider must inform the MCA as soon as the request comes in.
  • (c) The training provider must not carry out training in places where the Foreign, Commonwealth and Development Office advises against travel or areas that other Administrations have asked us not to carry out MCA approved training.
  • (d) The training provider must agree to retrospective charging for unannounced inspections.
  • (e) The training provider must ensure that the training is not interrupted or adversely affected by the environment, so the seafarer can dedicate their time and attention to the training and assessment.
  • (f) Course approvals, mid-terms and re-approvals can be carried out at a peripatetic location.
  • (g) Anybody wishing to provide this service peripatetically, must submit a detailed submission for approval. The submission must demonstrate how the course provider will quality assure the course delivery and safeguard the MCA’s reputation. If approved, mutually agreed terms governing the delivery of the course will be set out in an approval letter.
  • (h) Any training carried out on board a ship must be completed within the hours of work and rest regulations and a declaration must be signed by the Master of the ship to confirm that the individual undertaking the course complies with this requirement.[footnote 13]

Upon obtaining full MCA approval or recognition, a training provider may use the MCA’s logo for commercial use providing the following protocol is followed:

  • Logos with the wording ‘MCA approved/accredited/recognised course provider’ can be used on the front page of websites, publications, etc.
  • Logos with the wording ‘Training course recognised by. . .’ and ‘Training course approved by . . .’ can be used next to the course that is approved or recognised by the MCA.
  • You must not use the MCA logo to infer that any publication that you produce is an official MCA publication.
  • You must not use the MCA logo on a marketing stand to infer that you are representing the MCA.
  • Please ensure that you only use the logo(s) whilst your MCA approval or recognition is valid.
  • You should never infer that the MCA is endorsing you as the premium service provider or that you are the sole MCA course provider in a region or for a course.

6. Obligations of the MCA and the Training Provider

By applying for a course approval or re-approval you are agreeing to meet and maintain the MCA criteria.

The UK Department for Transport’s, Maritime and Coastguard Agency (MCA) permits training by external training providers in relation to the training elements required by the STCW Convention and Code for Merchant Navy Seafarers. Through approval and ongoing monitoring, the MCA is responsible for ensuring that approved training providers meet the training, assessment and quality standards set out in STCW Convention Regulation I/6 and I/8 and in accordance with the provisions of section A-I/6 and A-I/8 of the STCW Code (see regulation 9 of the Polar Code Regulations).

The MCA may suspend an approval if major non-conformities are identified (see section 2.10 of this Annex).

It is an expectation that MCA approval or recognition is a sign of quality. Once approval is granted you must continue to maintain the MCA criteria throughout your approval period. The MCA may make unannounced visits to inspect your facilities and/or training. We are here to work with you to maintain and drive forward quality through partnership. This approach will ensure MCA approved training providers can continue to provide the unique selling point of quality.

For each new approval or re-approval, the Company, Owner, Training Manager or relevant representative of the Nautical College is asked to sign the following declaration:

By applying for a course approval or re-approval I comply with the Merchant Shipping (Polar Code) (Safety) Regulations 2021. I can confirm that the surveyor approving the courses does not have any association with the training provider, financial or otherwise:

Signed:

Company Name:

Name:

  1. Annex I of MARPOL is implemented by the Merchant Shipping (Prevention of Oil Pollution) Regulations 2019 (S.I. 2019/42); Annex II of MARPOL is implemented by the Merchant Shipping (Prevention of Pollution from Noxious Liquid Substances in Bulk) Regulations 2018 (S.I. 2018/68); Annex IV is implemented by the Merchant Shipping (Prevention of Pollution by Sewage from Ships) Regulations 2020 (S.I. 2020/620); and Annex V is implemented by the Merchant Shipping (Prevention of Pollution by Garbage from Ships) 2020 (S.I. 2020/621). ↩

  2. Wordings used in section 6.3 and 6.4 are in line with regulation V/4 of STCW Code. To avoid any potential problems during Port State Control inspection, the certificate template for Advanced Training for Service on Ships Operating in Polar Waters will contain references to the Basic and Advanced Training regulations. ↩

  3. https://www.gov.uk/government/publications/min-595-training-requirements-for-those-serving-on-ships-subject-to-international-code-of-safety-for-ships-using-gases-or-other-low-flash-point-fuels ↩

  4. The Merchant Shipping (Hours of Work) Regulations 2002 (S.I. 2002/2125) as amended provide for the maximum rest period. MSN 1877 (Amendment 1) sets out the detailed requirements, including the format for a schedule of hours of work records. Seafarers must be given a copy of their record of hours of work which must be signed by the master or authorised representative and the seafarer: www.gov.uk/government/publications/msn-1877-amendment-1-hours-of-work-and-entitlement-to-leave ↩

  5. Bergy waters is defined as an area of freely navigable water in which ice of land origin is present in concentrations of less than 1/10. There may be sea ice present, although the total concentration of all ice shall not exceed 1/10. ↩

  6. PWOM refers to a manual containing information regarding the ship’s operational capabilities and limitations and procedures to be followed in polar waters in accordance with chapter 2 of part I-A of the Polar Code ↩

  7. This does not include the use of different classrooms (for theory-based teaching - not workshops, pools or firegrounds) owned/operated by an organisation within the same town or city. Clarification on this can be sort from the MCA via stc.courses@mcga.gov.uk. ↩

  8. QMS’ that have been certified by an external awarding body may need to be adapted to ensure they can meet the MCA’s specific requirements. ↩

  9. A poor submission would be where gaps are identified against the requirements of 2.4 (b) of this Annex or the MCA criteria guide. The MCA surveyor should bring this up with the training provider prior to issuing a forced delay and both parties should try and arrange a compromise, i.e. the submission of the required amendments within a reasonable time scale. ↩

  10. Equivalent seagoing service will be considered on a case by case basis based on evidence of familiarity with tasks listed in Section B-V/g of STCW Code. Evidence should be in the format of a company letter detailing; your roles and responsibilities against the guidance listed in Section B-V/g of STCW Code, the vessel(s) you worked on, the area(s) you operated in and the dates that your vessel(s) operated in the equivalent waters. ↩

  11. For further information please see the following link which contains a list of MCA approved training providers: www.gov.uk/guidance/mca-approved-training-providers-atp ↩

  12. As detailed in the Maritime Labour Convention on Hours of Work and Rest and Entitlement to Leave. Please see www.Gov.uk, MSN 1877 (Amendment 1): www.gov.uk/government/publications/msn-1877-amendment-1-hours-of-work-and-entitlement-to-leave ↩

  13. The Merchant Shipping (Hours of Work) Regulations 2002 (S.I. 2002/2125) as amended provide for the maximum rest period. MSN 1877 (M) (Amendment 1) sets out the detailed requirements, including the format for a schedule of hours of work records. Seafarers must be given a copy of their record of hours of work which must be signed by the master or authorised representative and the seafarer: www.gov.uk/government/publications/msn-1877-amendment-1-hours-of-work-and-entitlement-to-leave ↩

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