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An enhanced focus on machinery failure incident investigations in Shanghai waters, combined with China’s strict COVID-19 quarantine requirements for shore personnel attending onboard ships, could lead to time-consuming and expensive class surveys and audits, warns major classification society. 

As mentioned in our recent articles “Legal risks following quarantine of Yangtze River pilots” of 6 January and “Handling of COVID-19 positive crew cases in China” of 7 January 2022, China’s zero-tolerance policy towards COVID-19 has turned out to be highly stressful for ships’ crews - and challenging and costly for both ship operators and charterers. Now, in its Class News 01/2022, Lloyds Register (LR) warns that it is currently also very difficult to arrange for class surveyors’ attendance onboard ships while in ports and anchorages in China.

The backdrop

In December 2020, a serious collision resulting in the death of eight seafarers occurred in the deep-water fairway at Changjiangkou (CJK) off Shanghai. The accident, which was reportedly caused by a failure to a ship’s steering gear system, prompted the Shanghai Maritime Safety Administration (MSA) to implement a strict process for carrying out investigations after any incident of machinery failure in Shanghai’s territorial waterway as a means to avoid similar accidents in the future. It also notified the industry that any serious deficiencies identified during an investigation would give rise to detentions. Please refer to Shanghai MSA’s Safety Notice 01/2021 for details.

Onboard investigations during the pandemic

According to LR, a temporary process for carrying out investigations after any incident of machinery failure in Shanghai’s territorial waterway has now been implemented as part of the local authorities’ COVID-19 control measures. This means that, after a machinery failure incident, the ship’s Recognized Organization (RO) will be requested to attend onboard to carry out a root cause investigation and any occasional survey or additional audit as needed, and the Shanghai MSA will then check the RO’s report. However, due to the strict quarantine requirements for shore personnel attending onboard ships in ports and anchorages in China, RO surveyor attendance is expected to be extremely difficult, time consuming and expensive, warns LR.


In order to avoid machinery failures in heavy traffic waterways, such as Shanghai’s territorial waterway, and the subsequent need for a class surveyor’s attendance onboard, LR recommends ship operators to:

  • implement effective safety management systems to ensure that the maintenance of the ship’s machinery is carried out and properly recorded,
  • pre-check and test propulsion, steering and navigational systems before entering Shanghai’s territorial waterway, 
  • ensure adequate time for crews to change over to low sulphur fuel before entering one of China’s domestic Emission Control Areas, and
  • in case of any malfunctions, report immediately to local authorities, flag administrations and classification societies.

Members and clients trading to China, and Shanghai port in particular, are advised to take note of the above recommendations and to get in touch with their own classification society to discuss any survey needs in China. According to local sources of information, the Shanghai MSA may accept that ROs carry out some of the required inspections by utilising their remote survey tools. However, this depends on the specific circumstances and seriousness of the deficiency and must therefore be agreed up front on a case-by case basis.