The Marine Transport Workers' Trade Union of Ukraine received information that the Maritime Administration sent a letter to the International Maritime Organization (IMO) about the alleged "start of an experiment on issuing seafarers qualification documents in electronic format" and also on sending to IMO samples of seafarers' qualification documents containing a QR-code.
MTWTU brings the attention of seafarers and crewing companies to the following:
1. The technical specification of the seafarers' qualification documents forms and their samples are approved by law and do not provide for any QR code or other graphic images.
2. The implementation by the Maritime Administration of any "experiment" without amending the legal acts has signs of Maritime Administration officials exceeding their powers.
3. All seafarers' qualification documents must be produced on blank forms with special security elements. Such documents must be authorized by Harbor Master official, contain the personal signature of the seafarer - the owner of the document and the seal.
4. The functioning of the so-called "Seafarer's Electronic Cabinet" service is carried out without any regulatory support and protection of seafarers' personal data.
5. Dissemination of a letter of the Maritime Administration with an IMO covering letter does not mean that this organization has provided permission to place a QR code or other graphic images on the blanks of qualification documents of Ukrainian seafarers, and also does not give the Maritime Administration the right to use blanks that do not correspond to the requirements of Ukrainian legislation.
6. At the same time, the sending by the Maritime Administration a letter, which contains inaccurate information, to the maritime administrations of other states is a violation of Ukraine's obligations determined by the STCW-78 Convention, as amended.
