Continuous Synopsis Record (CSR) : What It Is And How To Ensure Compliance ?

If I ask you, who is the registered owner of your ship, will you be able to get this information ? I am sure you will !!

You can get this information from the “Certificate of Registry” of the ship.

Now if I ask about the detail of the ship owner from whom the present ship owner bought the ship, will you know it ?

We as a seafarers may not require this information but it is a necessary information for security purposes.

As with all the security concerns related to shipping, this too was talking point during development of ISPS code.

This information along with few others is now required to be in continuous synopsis record.

Let us discuss this in detail.

What is continuous synopsis record (CSR) ?

In short and plain language, the CSR is a record of ship’s history.  It is a record that remains with the ship for its entire service.

When chapter XI-2 (special measures to enhance maritime security) was introduced in SOLAS, a new regulation (regulation 5) concerning CSR was introduced in chapter XI-1 of the SOLAS.

The purpose of the CSR was to avoid the annonimity to the ship’s history and thus enhance the security at sea.

Even if the ownership of the vessel has changed many hands over the years, with CSR it will not be difficult to find who was the owner at what time ?

Same goes with flag of the ship, classification societies and ISM company of the ship. Each change need to reflect on the CSR.

CSR is issued by the vessel’s flag and it must contain at least these 15 point information.

1. Name of the flag state
2. Date on which the ship was registered with the flag
3. The ship’s identification number
4. The name of the ship
5. Port of registry
6. Name of registered owner and their registered address
7. Registered owner’s identification number
8. Name of registered bareboat charterer and their registered address, if applicable
9. Name of company responsible as per ISM code
10. Company identification number
11. Name of vessel’s classification society
12. Name of the organisation that has issued Document of compliance to the company
13. Name of the organisation that has issued SMS certificate to the ship
14. Name of the organisation that has issued ISPS certificate to the ship
15. Date on which the ship ceased to be registered with that state

Company identification number

IMO vide MSC resolution 160 (78) adopted a resolution that requires each ship owner and ISM companies to have a unique identification number.

This number need to be in the appropriate CSR column for the details of Ship owner and ship management company.

These IMO numbers are issued by IHS fairplay on behalf of IMO.

To apply for IMO number for a company, the company need to register with the email on IHS fairplay website.

Once registered, the company then need to fill the online application form for applying to get IMO number.

From this website, it is even possible to check the IMO number of any company. For this after login, we can enter initial few words of the company and then press search.

This will give all the matching results. Click on the company for which you are looking for th information.

This will give the information about that company and their IMO number.

Process of changing information in CSR

Now when a ship is newly built and handed over to the ship owner, the ship will have only one CSR document.

This CSR document will have all the 15 point information filled.

Now say, after two years, the ship was bought by a ship owner. This ship owner prefers different classification society than the vessel currently has.

The ship owner need to change the owner’s detail in the ship’s registry certificate. He would then change the classification society of the ship.

I am not going into details of process of changing the classification society of the ship as this would make us divert from our topic.

Now after this has been done, The owner need to apply for these changes to the flag state of the ship to issue a new CSR.

Different flag state can have different procedure of application for correction to the CSR. Some may require the documents to be emailed to them and they will issue a new CSR based upon that.

Others may require physical copy of the application to be sent to them. But most of the flags have moved to the digital way.

These procedure are usually available on the website of the flag states.

These procedures involve sending following to the flag state

• index page of the Continuous synopsis record and
• the amendment page highlighting the amendments required

Let us see how the amendments of change of owners and change of classification society need to be entered in the amendment page.

Amendments to CSR

The amendment page contains all the information that CSR has. When applying for the amendment to the current CSR, company need to fill the amendment page.

Only the columns that are changed need to filled with new information. The columns that are not affected need to be marked as N/C (not changed).

The document number marked on the amendment page shows to which CSR number these amendments are applied.

Amendment from is sometimes also referred as Form 2 of the CSR.

Index page of the amendments

Whenever amendment page is filled for any CSR, the index page need to be filled as well.

For the sample amendment page that I filled,  this is how index page will look like.

It shows the index of the columns that were affected by the amendment of the CSR document.

So now we have CSR document number 1, which was issued by the flag of the ship when the ship was built.

This CSR had some changes. The changes are shown in the amendment page and index page.

On the basis of this application and the “amendment and Index” page attached to the CSR document 1, flag of the vessel will issue a new CSR which will be marked as CSR document no 2.

Now each time there is any change in the information contained in the Current CSR document, a new CSR document will be issued by the flag state of the vessel.

Index page of a CSR document is sometimes also referred as Form 3 of the CSR.

Click here for a sample blank CSR document with Form 2 and form 3

What Master need to check on CSR documents file ?

Upon joining a ship, master need to check the correctness of the CSR document file. Here is what master need to check

1. Information in the current CSR is correct

First thing that master need to check is if all the information in the Current CSR document is correct. For example, if it mentions the owner’s details, classification society, ISM company name and all other information correctly.

Master need to compare the Owner’s details entered in the current CSR with the ship’s certificate of registry. These two details must match.

2. Current CSR document is on board

If any of the information in the latest CSR document is not current, it may be that there is one more CSR document that is not on board.

In this case, master must ask the company about the document number of latest CSR.

If this CSR is actually the latest CSR document and has some wrong information in it, Master much inform this fact to the company.

Company will then apply for the changes in CSR document.

It may also be the case that the latest CSR document is not yet received from the Flag state of the vessel.

As per IMO circular A.959 (23), Flag is required to issue the updated CSR document within 3 months from the application date. If the latest CSR document is not onboard, Master much check if it is still under 3 months window period and Liaise with the company for receiving this onboard.

During a PSC inspections, 3 months issuance time for the CSR document can be highlighted to avoid deficiencies related to CSR.

3. All the previous CSR documents are on board

Now if the latest CSR document is number 8, all the previous 7 CSR document must be on board. All these CSR documents should be arranged in sequence order.

Master must check if the CSR document numbers 1 to 7 are in the file

4. All Previous CSR documents have amendment page and index page attached

We have already discussed about the amendment page and index page. Each CSR document that was amended must have amendment page and Index page attached to it.

So If there are total 8 CSR documents, 8 being the latest. Then

• Document number 8 will be the latest CSR document with no amendment page (Form 2) and Index page (Form 3) attached to it
• Document number 7 will have the amendment page (Form 2) and index page (Form 3) attached to it. These amendments will be the difference between information in document number 7 and document number 8.
• Same will be the case with other 6 CSR documents

5. Changes as per amendment form and Index pages match with actual changes to the CSR

Amendment form attached to a CSR document reflects the changes made to that CSR document. So for example, let us say as per amendment form attached to CSR document no 6, there is only one change which is change of vessel’s classification society.

This change in classification society must reflect in CSR document no 7.

It is rare to have a mistake from the flag in this case but it may be the case that a wrong amendment form is attached to the CSR document.

Master should detect these errors if any and correct these.

Conclusion

The requirement of “continuous synopsis record” was introduced in SOLAS chapter XI-1 because of the security concerns. The core purpose of the CSR was to be able to get the basic information of people and companies involved with the ship through out its service period.

Not having a CSR or a missing old CSR document can be cause of concern during onboard inspection.

We must ensure that all the CSR documents of the ship are available on board.