The ongoing war in Ukraine has a considerable impact on vessels calling ports in the Black Sea and the Sea of Azov. The situation remains fluid and may change by the hour.
This Alert was last updated on 5 April 2022 at 9.15 hrs BST/10.15 hrs CEST.
According to information received from Gard’s local correspondents, other service suppliers, as well as open sources, the situation in Ukraine, Russia, Sea of Azov, and Black Sea is reported to be as follows:
Recent reports indicate that mines being laid in the north-western part of the Black Sea near Ukrainian shores may have broken loose from their moorings and become adrift, drifting south. According to the NATO Shipping Center (NSC), drifting mines have been detected, one very close to the entrance of the Bosporus Strait,and national authorities are working to find and neutralise any other mines in the region.
Masters of ships navigating in the western parts of the Black Sea arerecommended to make their crews aware of this potential threat, avoiding floating objects, keep the forward area of the ship clear of crew, and use effective look-outs. All detections should be reported to the area authorities.
Masters are also recommended to obtain the relevant NAVAREA III warnings relating to mined areas and drifting mines, and contact the local port authorities and ships agents for the latest information.
Certain states, such as Romania have recommendations on the track that vessels should follow when arriving or departing from ports. Vessels are advised to check with their local agents or port authorities regarding such.
Russia’s recent adoption of several decrees imposing prohibitions and restrictions on the export of goods from Russia may increase the risk for ships with a connection to Western European states being detained and confiscated in Russian ports. In an alert of 25 March 2022, the Norwegian MaritimeAuthority (NMA)reports that ships have already been detained in Russian ports and recommends that ship operators and masters, when planning to call at ports in Russia, consider the content of the Russian decrees, as well as the risk of being selected for a port state control inspection, and possibly detention. At the time of writing, we are not aware of any official English translations of the above-mentioned decrees. We therefore recommend that operators and masters, prior to fixing a cargo, check with their local agents in Russia if the cargo is covered by the prohibitions in force.
Masters should note that vessels manned by Ukrainian crew may experience additional scrutiny by Russian authorities, and possible interrogation of such crew members, when calling at Russian ports.On 28 February 2022, a Gard member reported that armed personnel purporting to be Russian immigration officers had come onboard a vessel berthed at a Russian non-Black Sea port and taken ashore part of the Ukrainian crew for questioning. Russian armed personnel stayed on board and the remaining Ukrainian crews onboard were also questioned. Similar incidents have since been reported by other industry sources as well.
The Sea of Azov is closed to commercial vessels, enforced by Russian naval forces at the Kerch Strait.
Access to the north-western part of the Black Sea, north of 45º 21’ parallel, is prohibited by the Russian Navy.
All Ukrainian ports are reported closed for operation. As per IMO Circular Letter No.4518, the Ukrainian government has advised that all ports are now at MARSEC level 3 and are “closed for entry and exit”.
Combat in or near Ukrainian ports, with strikes against port infrastructure, may occur, with crews and vessels in Ukrainian ports being prone to collateral damage. There are reports ofcommercial vessels that have sustained damage due to shelling.
Operation of all Russian ports based in the Black Sea is continuing in a routine manner, although their ISPS Security Level may have been raised. If cargo operations at Russian ports in the Black Sea are absolutely necessary, it is recommended that a Declaration of Security is first carried out with the Port Facility Security Officer (PFSO).
Commercial operations within the EEZs of Turkey, Georgia, Bulgaria and Romania are reported to continue, howeveralso these ports’ ISPS Security Level may have been raised. Note that the shipping company Wilhelmsen provides regular and useful updates on the latest port restrictions and updates in the Black Sea region.
Transit of crew into port cities may be affected by combat operations; roads may be blocked, and airports and airspace are closed, further limiting transit.
We will update this section as and when we receive further updates. However, as the situation may change quickly, we strongly recommend that ship operators and masters trading to ports in the Black Sea region make frequent checks with local sources of information, e.g. vessel’s agent, Gard’s correspondent, etc., to obtain the most up to date and reliable security information available at any given time.
Other navigation related challenges and precautions
The US Maritime Administration (MARAD) in their Advisory 2022-004 has indicated that vessels may encounter GPS interference, AIS spoofing, and/or other communications jamming when navigating in the Black Sea and the Sea of Azov. Additional guidance for vessels experiencing GPS interference can be found in MARAD Advisory 2022-005. There are also reports that electronic warfare may be employed. If so, then it may affect electronic systems on vessels.
Vessels are also likely to encounter disruption due to navigational restrictions in this region. At the time of writing, AIS data indicates a reduction in traffic since the start of the conflict and decreasing concentrations of vessels. However, there could still be a build-up of vessels either at anchor or drifting, e.g. on either side of Bosporus Strait, and vessels are advised to maintain safe distance from other vessels, keep a sharp lookout and have their engines ready for manoeuvring.
Maritime security advice
The situation remains volatile and changing and we recommend all vessels operating in the relevant areas to carefully assess the situation, exercise caution, and review their relevant contingency plans, including the crisis communication plan, in case of an incident. Owners and managers should ensure that seafarers on vessels heading towards the Black Sea region are aware of the security threats in their specific geographical area of trade.
Vessels may have received security information from their flag administrations regarding the ISPS Code security level. As an example, on 24 February 2022 the NMA raised the security level to MARSEC/ISPS 3 for Norwegian flagged vessels operating in the northern part of the Black Sea and the Sea of Azov. Marshall Island did the same for their vessels trading in the EEZ of Ukraine in their Ship Security Advisory 02-22. If such instructions are not received, it is recommended to pursue this with the vessel’s flag administration. Additional instructions and notices from flag administrations can also be downloaded from the Lloyd’s Register website: Latest information received from Flag States relating to Ukraine. However, we strongly advise operators and masters to maintain contact with their flag administrations in order to receive their most recent instructions available at any given time.
Vessels should ensure they are broadcasting on AIS and clearly state their intentions across VHF, consistent with provisions of SOLAS and their flag administration, and monitor VHF Channel 16. However, pursuant to IMO guidelines, “if the master believes that the continual operation of AIS might compromise the safety or security of his/her ship or where security incidents are imminent, the AIS may be switched off. The date, location and time the AIS is switched off should be recorded in the ship's logbook together with the reason for doing so and the master should restart the AIS as soon as the source of danger has disappeared”.
In the event of any incident or suspicious activity, vessels should notify its flag administration, the area authorities, and the NSC. Any vessels challenged by military vessels should comply fully with their instructions.
It is worth noting that an existing NATO document on the interaction between naval forces and merchant ships: ATP-02.1 Naval Cooperation and Guidance for Shipping (NCAGS), may be relevant in the current situation. While NATO is not a party to the conflict, the publication contains a lot of valuable information about the many factors to consider when navigating in areas of armed conflict or war. Relevant advice may be taken from Appendix A of the Global Counter-Piracy Guidance, which outlines non-piracy threats.
In our topic page “War in Ukraine” we provide an overview of all Gard’s relevant loss prevention material, as well as links to some useful external websites and guidelines, that may assist ship operators, masters, and crews to stay alert and prepare and respond to the ongoing situation in Ukraine and the Black Sea region.
Ukraine and Russian waters added to JWC listed areas
As a result of the war in Ukraine, all ports in Russia and certain sea areas in the Black Sea and the Sea of Azov have been included in the latest revision to the list of Hull War, Piracy, Terrorism and Related Perils Listed Areas (JWLA-030) by the Joint War Committee (JWC) which was last revised on 4 April 2022. Owners are advised to get in touch with their war risk insurers when calling any port falling within the above-mentioned region.
On 31 March 2022, the JWC published circular no. JW2022-009 addressing the threat of mines in the Black Sea. It highlights that the number of mines, their ownership, and how they arrived in the southern parts of the Black Sea is somewhat unclear, but emphasises that “If it transpires that there are significant numbers of live mines that exceed littoral state abilities to contain them, then JWC will move to reassess the Listed Areas.”
The latest version of the JWLA, as well as all the committee’s bulletins/circulars, are available at the JWC website
The Warlike Operations Area Committee (WOAC) comprising of UK Chamber of Shipping, Nautilus International and the RMT union, has declared all Ukrainian, Russian and International Waters north of 44°North in the Black Sea as ‘warlike operations area’.
We thank our correspondents Dias Marine Consulting PC in Ukraine, Novorossiysk Insurance Company Nostra Ltd. in Russia, Vitsan Mümessillik ve Musavirlik A.S. in Turkey, and Kalimbassieris Maritime in Bulgaria and Romania, for their assistance in preparing this alert.