UPLS 3. March 2017.

Date 03.03.2017. we sent the following letter to the ministry with a request for clarification:


Dear Sirs,
The mentioned rulebook has caused dilemmas in practical application, and we are addressing you this way in order to eliminate them.

Article 3, item 6 of the Rulebook from the title.

DECK OFFICER  is a member of the ship's crew who has the appropriate professional training to command a ship of certain characteristics and who performs the duties of the ship's captain in shifts.

Article 38, paragraph two. provides that the shipowner to whom the authorization has been issued THE TYPE A, B and C COMMANDERS shall perform the duties of deck officers in shifts.

When replacing the old Ship's Certificates and the Crew List, with new forms by the competent port authorities, data related to the qualifications of deck officers were entered in the provided sections, when a deck officer is necessary as part of the crew for a certain model of navigation. In the practice so far, we have not found a single ship on which a person with the authorization of a TYPE B or C COMMANDER can be embarked as a deck officer, but it is stated everywhere that a TYPE A COMMANDER is required for the position of deck officer.

Please state your opinion on this issue, ie in a form and manner that suits you, in a clear and unambiguous manner, announce on which ships persons who have the authority of the Commander of TYPE B and C can perform the duties of deck officers.

We note that by preventing COMMANDERS B and C from performing the duties of deck officers, according to the existing documents issued by the Harbor Master's Offices, irreversible damage is inflicted on the shipping company. COMMANDERS B and C in practice are navigators who are in the process of collecting sailing experience and experience for taking the professional exam for the title of COMMANDER A. There is a real possibility that in the coming period a new generation of COMMANDERS A will not be able to gain experience and training on high power ships. complex navigation system composition.

Article 38, item 4 KRMAR  policy from the title.

Navigators under the supervision of the commander by ship, towed, pushed, or side formation.
By checking the records on the issued authorizations for qualification and special qualification provided for in Article 40 of the Rulebook, you will see that there is not a sufficient number of persons who hold the title of KRMAR Article 4, item 4.

Please answer the following question: Can persons with the authority of COMMANDER TYPE B and C perform the duties of a helmsman, within the already issued authorization, or must they have the authority of a helmsman and whether the rank of Commander B and C is greater or less than the rank of helmsman. The rank of Commander Type A implies the ability to perform all deck operations without further explanation. It is also necessary, following the example of the old authorizations in inland navigation, to clearly write down all the jobs that the holder of the authorization can perform on which ships.

Article 38, item 9 MACHINE DRIVER policy from the title.

            It manages the engine plant on ships up to 750 kW, in shifts it operates the propulsion plant on ships up to 1030 kW.

The Ordinance on the minimum number of crew members for safe navigation that ships and other vessels of the merchant navy must have Official Gazette of RS 28/15, 99/15 and 3/15 provides TO THE DRIVER as a person who can operate a motor installation as part of a minimum crew in the following cases:

Pusher with a composition greater than 3 thrusters.

Self-propelled vessel with a composition greater than 2 thrusters.

In practice, ships leading such formations have a higher power of the engine plant than 750kw, which is limited to the title of DRIVER. It is necessary for you to harmonize the two valid regulations, ie to define more precisely the title of Train Driver

We hope that you will respond to this request within a reasonable time, so that all interested parties can plan their business activities in a timely manner in accordance with applicable regulations.

Scanned pdf request

Board of Directors of the Association of Professional Boatmen of Serbia