UPLS 9. February 2017.

Regarding numerous complaints from members of the Association about the impossibility of certifying our shipping books when boarding ships with a foreign flag, we sent the following letter to the Ministry of Transport:

TO THE MINISTRY OF TRANSPORT AND INFRASTRUCTURE OF THE REPUBLIC OF SERBIA

COMPLAINT ON THE ACTION OF PORT CAPTAINS 'OFFICERS

 

In accordance with the obligations of the Ministry under Article 245 of the Law on Navigation and Ports on Inland Waters, hereinafter the law, we hereby inform you about the following observed shortcomings in the work of port authorities in implementing the provisions of laws and bylaws.
The Law in Article 169, paragraph 5 defines the obligations of port authorities in administrative matters entrusted to them by law and other regulations. Article 136 of the Law defines the rulebook adopted by the Ministry, dated 15.05.2013. RULES ON conditions, method and procedure for issuing and SUBSTITUTE CONTENT AND FORM shipping book or Permission to board, ENTITIES and the authorities competent for storing and OVER DATA, and the content, form and manner of a register of issued shipping booklet and Permission to board (Fig. RS Gazette No. 40/13).
The omission is reflected in the non-compliance with Article 13, paragraph 7 of the Rulebook.
Although the rulebook stipulates a clear obligation of the Harbor Master's Office to verify the embarkation of the holder of the ship's license, in practice we have encountered the position of the Harbor Master's Office that officials refuse to certify embarkation if embarkation is performed on a vessel flying a foreign flag. The next omission is that the holder of the shipping book with such boarding is referred to the certification of boarding, which is important for proving the sailing experience and further advancement in the service, he performs in the diplomatic and consular mission of the country under whose flag he boarded. Further, the story becomes even more complicated, so that in some DCMs, they verify the Serbian shipping book, which is now striving for more serious qualifications that also concern the sovereignty of the Republic of Serbia. For example, what would be the appropriate reaction of the Republic of Germany if our consulate certified the embarkation of a German citizen in a German shipping book.
We are addressing you with the best intentions, and a request to devise a procedure for verifying the embarkation performed as a crew member on a ship flying a foreign flag.

In Novi Sad
08.02.2017

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