War in Ukraine – impact on maritime situation
Updated 21 March 2023
The Black Sea Grain Initiative has been extended for the second time. While the exact details of the extension are still unclear, reports suggest that the initiative's regular activities will continue for at least 60 days more. However, the risk of collateral damage to civilian shipping operating in the war risk area in the northern Black Sea, outside the declared maritime humanitarian corridor, remains high and the threat of drifting mines in the western parts of the Black Sea persists.
29 MAR 2022
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Based on information received from Gard’s local correspondents, other service providers, as well as open sources, the situation in Ukraine, Russia, Sea of Azov, and Black Sea is reported to be as follows:
- The UN Black Sea Grain Initiative (BSGI), originally put in place on 22 July 2022 and scheduled to expire on 19 November 2022, has now been extended for the second time, according to a UN press release of 18 March 2023. However, the exact details of the extension are unclear. The purpose of the agreement is to facilitate the safe navigation for the export of foodstuffs and fertilizers from the Ukrainian ports of Odesa, Chornomorsk and Pivdennyi. A Joint Coordination Centre (JCC) has been established in Istanbul, Turkey, to conduct general oversight and coordination of the initiative and all relevant information, including updates and procedures for ship operators, can be found here: UN Black Sea Grain Initiative JCC.
- Ship operators and masters of vessels engaged in the BSGI are urged to stay in close contact with the JCC and make sure to always follow their latest instructions and procedures.
- Outside the BSGI, Ukrainian ports generally remain closed for commercial operations but the Ukrainian Danube ports are reported to be open and operational. However, it is worth noting that the Ukrainian government has advised the IMO that all its ports are at ISPS Security Level 3.
- The Sea of Azov remains closed to commercial vessels, enforced by Russian naval forces at the Kerch Strait.
- Access to the northern part of the Black Sea west of Crimea is prohibited by the Russian Navy. According to the NATO Shipping Centre (NSC), the threat of collateral damage or direct hits on civilian shipping in this war risk area, see NAVAREA III 0124/2022, of the Black Sea remains high. The restrictions do not apply to vessels entering or leaving under the Black Sea Grain Initiative.
- 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, however also these ports’ ISPS Security Level may be raised. Note that the shipping company Wilhelmsen provides regular and useful updates on the latest port restrictions and updates in the Black Sea region.
Mined areas and drifting mines:
- The NSC reports that drifting mines are still being detected and deactivated by coastal nations’ authorities in the southwest part of the Black Sea.
- Masters of vessels navigating in the western parts of the Black Sea are therefore recommended to make their crews aware of this potential threat, avoiding floating objects, keep the forward area of the vessel clear of crew, and use effective lookouts. All sightings of mine-like objects should be reported to coastal authorities and ships should remain well clear of the hazard.
- Masters are also reminded to monitor the local authorities’ broadcasts for the latest Navigational Warnings, obtain all relevant NAVAREA III warnings in force, and contact the vessel’s local agents for the latest information.
- Some coastal states, such as Romania, have issued 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, and use these routes when recommended to do so by the relevant authorities.
Increased risks when calling at Russian ports:
- Russia has adopted several decrees imposing prohibitions and restrictions on the export of goods from Russia which may increase the risk of vessels with a connection to Western European states being detained and confiscated in Russian ports. In March 2022, the Norwegian Maritime Authority (NMA) recommends that vessel 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 any of the prohibitions in force.
- Masters should note that vessels manned by Ukrainian crew have occasionally experienced additional scrutiny by Russian authorities, and possible interrogation of such crew members, when calling at Russian ports.
We will update this section as and when we receive further updates. However, as the situation may change quickly, we strongly recommend that vessel 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 2023-004 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 2023-05. There are also reports that electronic warfare may be employed. If so, then it may affect electronic systems on vessels.
Vessels may also encounter disruption due to navigational restrictions in this region, e.g. on either side of Bosporus Strait. Vessels waiting at anchor or drifting, 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.
All vessels should continue to receive updated security information from their flag administrations regarding applicable ISPS Code security levels. 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”.
Vessels participating in the UN Black Sea Grain Initiative should follow the procedures posted on the JCC website.
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 vessels: 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 vessel 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.
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 Svertilov Marine Consulting and 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.
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