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The Republic of Marshall Islands Amends Yacht Code
Laura Shaughnessy is the former managing editor at Dockwalk.
In May, the Republic of the Marshall Islands Yacht Code was updated and amended to become even more practical and realistic for owners and shipyards to choose RMI as a building standard. Not only does the most recent code update include all previously issued supplements, but there are additional technical and safety updates that address building requirements of modern yachts. This is reportedly the most significant update to the code since it was published in 2013.
“The Republic of the Marshall Islands (RMI) Maritime Administrator has a track record of innovation in the yacht sector,” Marc Verburg, Fleet Operations Manager, Yachts, told Dockwalk . “The 2021 RMI Yacht Code was drafted to encompass all the latest developments in the design, build, and operation of large and small yachts.”
According to their press release on May 11, some of the main changes and updates include:
- New requirements for modern design elements such as underwater glazing for observation lounges and glazed bulwarks.
- Helicopter landing areas (Annex 2 of the Code) revised throughout with alternative standards for firefighting.
- Shipyards now have the possibility to apply for a Helicopter Landing Area Technical Certificate (HLATC) issued by an Aviation Inspection Body (AIB).
- A more practical approach for submersible launching.
- A practical approach to structural fire protection for Category 2 yachts.
- Modified rescue boat requirements to provide a practical alternative standard for yachts under 500 gross tons.
- Updated radio equipment requirements.
- Modified firefighting appliances to provide alternative standards when taking the typical size of the yacht into consideration.
- Safe working practices for working over the side and man-riding cranes were clarified and addressed to meet national requirements.
Due to the sizable changes, many key contributors came together to update the Code. The International Registries, Inc. (IRI) and its affiliates helped organize an RMI Yacht Technical Working Group (YTWG) to make recommendations to the Code. These included yacht managers, naval architects, Classification Societies, surveyors, maritime safety consultants, aviation experts, representatives from the RMI Registry, and the Superyacht Builders Association (SYBAss).
According to Verburg, the 2021 version of the Code lets builders and designers create innovative and safe superyachts to a practical standard.
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Republic of the Marshall Islands Updates its Yacht Code
The Republic of the Marshall Islands (RMI) Yacht Code (the “Code”) has been updated and amended making it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. The Code was first published in 2013 and this is the most significant update to the Code since then. The 2021 Code revisions incorporate all previously issued supplements as well as additional technical and safety updates to address the building requirements of today’s yachts.
Key changes and updates include:
new requirements for modern design elements such as underwater glazing for observation lounges and glazed bulwarks;
helicopter landing areas (Annex 2 of the Code) revised throughout with alternative standards for firefighting;
shipyards now have the possibility to apply for a Helicopter Landing Area Technical Certificate (HLATC) issued by an Aviation Inspection Body (AIB);
a more practical approach for submersible launching;
a practical approach to structural fire protection for Category 2 yachts;
modified rescue boat requirements to provide a practical alternative standard for yachts < 500 gross tons;
updated radio equipment requirements;
modified firefighting appliances to provide alternative standards when taking the typical size of the yacht into consideration; and
safe working practices for working over the side and man-riding cranes were clarified and addressed to meet national requirements. new requirements for modern design elements such as underwater glazing for observation lounges and glazed bulwarks;
safe working practices for working over the side and man-riding cranes were clarified and addressed to meet national requirements.
International Registries, Inc. and its affiliates (IRI), who provide administrative and technical support to the RMI Maritime and Corporate Registries, organized an RMI Yacht Technical Working Group (YTWG) to make recommended amendments to the Code. Marc Verburg, IRI’s Fleet Operations Manager, Yachts, led the YTWG whose members consisted of representatives from the RMI Registry, Classification Societies, yacht managers, naval architects, surveyors, maritime safety consultants, and aviation experts. The Superyacht Builders Association (SYBAss) was also instrumental in the review of the amendments to the Code.
“It was a privilege to work with such a global team of experts. The Registry truly appreciates their assistance with the amendments to the Code which now further reflects the recent changes in the market, from a practical approach to helicopter landing areas and facilities to the use of glass without compromising safety,” said Marc Verburg. “The 2021 version of the Code allows builders and designers to create innovative and safe superyachts to a practical standard,” he continued.
In 2020 SYBAss members were responsible for the construction of almost 60% of 40 meter or more yachts delivered worldwide. “We are an innovative industry which embraces new technologies and materials, so we’re pleased to see this reflected in this forward-looking update of the Code. It takes a practical approach to the requirements of the superyacht industry and is fully aligned with the mission of the International Maritime Organization,” said Lorenzo Pollicardo, Technical and Environmental Director, SYBAss.
“The RMI offers many options for yacht owners in terms of registration and operation through the various chapters of the Code,” said Patrick Bachofner, IRI’s Director, Geneva Office and Worldwide Director, Yachts. “The practical amendments brought forward in this revision to the Code once again set the RMI yacht registry apart from others,” he concluded.
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Republic of the Marshall Islands updates its Yacht Code
The Republic of the Marshall Islands (RMI) Yacht Code (the “Code”) has been updated and amended making it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. The Code was first published in 2013 and this is the most significant update to the Code since then. The 2021 Code revisions incorporate all previously issued supplements as well as additional technical and safety updates to address the building requirements of today’s yachts.
Key changes and updates include:
• new requirements for modern design elements such as underwater glazing for observation lounges and glazed bulwarks;
• helicopter landing areas (Annex 2 of the Code) revised throughout with alternative standards for firefighting;
• shipyards now have the possibility to apply for a Helicopter Landing Area Technical Certificate (HLATC) issued by an Aviation Inspection Body (AIB);
• a more practical approach for submersible launching;
• a practical approach to structural fire protection for Category 2 yachts;
• modified rescue boat requirements to provide a practical alternative standard for yachts < 500 gross tons;
• updated radio equipment requirements;
• modified firefighting appliances to provide alternative standards when taking the typical size of the yacht into consideration; and
• safe working practices for working over the side and man-riding cranes were clarified and addressed to meet national requirements.
International Registries, Inc. and its affiliates (IRI), who provide administrative and technical support to the RMI Maritime and Corporate Registries, organized an RMI Yacht Technical Working Group (YTWG) to make recommended amendments to the Code. Marc Verburg, IRI’s Fleet Operations Manager, Yachts, led the YTWG whose members consisted of representatives from the RMI Registry, Classification Societies, yacht managers, naval architects, surveyors, maritime safety consultants, and aviation experts. The Superyacht Builders Association (SYBAss) was also instrumental in the review of the amendments to the Code.
“It was a privilege to work with such a global team of experts. The Registry truly appreciates their assistance with the amendments to the Code which now further reflects the recent changes in the market, from a practical approach to helicopter landing areas and facilities to
the use of glass without compromising safety,” said Marc Verburg. “The 2021 version of the Code allows builders and designers to create innovative and safe superyachts to a practical standard,” he continued. In 2020 SYBAss members were responsible for the construction of almost 60% of 40 meter or more yachts delivered worldwide. “We are an innovative industry which embraces new technologies and materials, so we’re pleased to see this reflected in this forward-looking update of the Code. It takes a practical approach to the requirements of the superyacht industry and is fully aligned with the mission of the International Maritime Organization,” said Lorenzo Pollicardo, Technical and Environmental Director, SYBAss.
“The RMI offers many options for yacht owners in terms of registration and operation through the various chapters of the Code,” said Patrick Bachofner, IRI’s Director, Geneva Office and Worldwide Director, Yachts. “The practical amendments brought forward in this revision to the Code once again set the RMI yacht registry apart from others,” he concluded.
For further details, please contact:
Bill Lines, Navigate PR Tel: +44 (0)20 3326 8450 Email: [email protected]
Laura Sherman, Director, Marketing & Communications Tel: +1 703 608 0187 Email: [email protected]
For updates from the RMI Maritime Administrator regarding COVID-19 visit https://www.register-iri.com/covid-19/ .
Profile links
Marshall Islands Yacht Registry (International Registries, Inc.)
Source : SuperYacht News, 11 May 2021
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United Maritime Survey
United maritime survey is the largest and most reputable appointed representative (ar) for the republic of the marshall islands (rmi). they specialize in the rmi yacht code and regulatory compliance for large luxury yachts. with a footprint across the globe, ums surveyors are ready to be dispatched at a moment’s notice. their team of experts are strategically positioned worldwide in areas such as the united states, united kingdom, france, spain, australia, st. maarten, and many more. their process of getting you set up with a surveyor or consultant is the simplest and quickest in the industry. ums prides itself on having a seamless process that is quick, easy and straight-forward., united maritime survey and its group of experts can assist in a wide-range of capacities. their highly versatile team of professionals consist of former captains, chief engineers, naval architects, project managers, class surveyors and flag state inspectors. due to these means, ums is the only appointed representative that has the know-how and resources to assign an expert specifically tailored to your request or need. ums also appreciates the complexity that comes with the ever-changing regulatory landscape which is why they offer an assortment of services that address these challenges. these services include pre-registration surveys, commercial yacht (cy) surveys, yachts engaged in trade (yet) surveys, private yachts with limited charter for up to 84 days per year (pylc) surveys, passenger yacht (paxy) surveys, office doc audits and external ism, isps, and mlc audits. on most instances, statutory certification can be issued to a vessel within hours of a survey’s conclusion (contingent on survey findings)., consultancy, united maritime survey also provides consultancy services for owners who need assistance navigating the multilayered environment of the marine industry. most owners, owner’s representatives and captains do not have the expertise nor time to deal with the regulatory hurdles that come their way. that’s where ums comes in their largescale network of professional surveyors can be there to guide you through any process you might encounter. whether the process consists of surveys, audits or inspections, ums and its team of specialists have you covered., 1931 cordova road, suite 132 fort lauderdale, fl 33316, +1 954-630-8775, [email protected].
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Marshall Islands Yacht Code set for revision in 2021
An initiative to update and amend the Republic of the Marshall Islands Yacht Code is currently in progress with the launch of the new revised edition anticipated for the second half of 2021.
The Marshall Islands Yacht Registry is one of the largest in the world. As of May 31, 2020, it included 595 yachts representing 13% by number of the 4,722 vessels listed. The yachts totalled 183,817 GT, which accounted for just 0.10% of the 175.2m GT of the total flag fleet.
The revision work is taking input from across the Registry’s global specialist teams, as well as external experts. A revised version is expected to be ready in the first half of 2021.
“We hope that these amendments to the Code will make it more practical than ever before for owners and yards to choose the Marshall Islands as a building standard,” says Marc Verburg, fleet operations manager yachts for International Registries Inc (IRI) and its affiliates, who is leading the Code revision.
The newly formed Yacht Technical Working Group (YTWG), which includes representatives from classification societies, yacht managers, naval architects, surveyors, maritime safety consultants, and aviation experts from around the world, is focused on updating the Marshall Islands Yacht Code to reflect changes in today’s yacht market, such as helicopter landing areas, structural fire protection measures for yachts under 500 GT, and lifesaving appliances.
The growing trend for helidecks on larger yachts means that the approach to firefighting systems needs to be reviewed. Currently, the rules are based on the UK Civil Aviation Authority’s CAP 437 guidance, which is aimed at offshore platforms. This is not always a practical solution for yachts, and so a goal-based standard is being reviewed.
“The pop-up deck spray nozzles found on rig helipad firefighting systems are not always feasible on a yacht, so we’re looking at alternative means that can perform the task just as well,” Verburg explains.
The Marshall Islands Yacht Code has long been designed to address the practical issues faced by builders, managers, and owners alike; it last had a major update in 2015. For many builders of large yachts, the appeal of the RMI lies in the differentiation in the standards for yachts capable of carrying more than 12 guests.
Large private yachts do not have to be built to the same specifications as are provided in the Code, Chapter III for passenger yachts. The RMI allows, through its national legislation and the Code, the registration of commercial yachts, private yachts, private yachts limited charter (PYLCs), and passenger yachts (PAXYs). It also allows for RMI-flagged private yachts to charter in French and Monégasque waters without the need for commercial registration by requesting a Temporary Certificate of Registry for Yacht Engaged in Trade.
Read the current Marshall Island Yacht Code: Marshall-Islands-Yacht-Code
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RMI makes local yacht building more attractive following Code change
The Republic of the Marshall Islands (RMI) has updated its Yacht Code to make the country more attractive for builders and owners to produce and flag there.
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By SuperyachtNews 12 Jul 2017
A closer look at the REG Code
Will the red ensign group code enable more flexibility within yacht design.
With the recently announced Red Ensign Group (REG) Code, to which the Cayman Islands Shipping Registry is taking the lead in the secretariat role, the group hopes to address certain frustrations associated with superyacht construction within a new regulatory framework for yachts. The new code will consolidate an updated version of the Large Yacht Code (LY3) and the latest version of the Passenger Yacht Code (PYC) and aim to make the code more usable.
This all-encompassing concept will not be a first for yacht coding – the Marshall Islands Shipping Registry’s RMI Code has one document that covers both large yachts and passenger yachts. However, the REG wants to differentiate the new code by including greater flexibility for naval architects, designers and yards. While the REG is developing the new code to match international conventions – and they expect to update the Load Line, SOLAS and STCW requirements to keep up with the steady trickle of updates from the International Maritime Organization (IMO) – the focus is also on giving opportunities to yards and designers to explore unique and innovative ideas that owners want.
“Although the codes will remain mostly the same, we want to ensure that within the prescriptive framework, we have alternative design and arrangement clauses,” says Jo Assael, Cayman’s senior surveyor and yacht codes specialist. “This will enable designers to go a little more off-piste and allow them, through rigorous design and engineering principles, to prove that an alternative standard is just as safe as the prescriptive one. Hopefully, this is going to open the doors to these unique designs that haven’t been allowed by the code in the past.” The REG is expecting publication of the new code in September 2017, which would lead to an application date for vessels with keels laid after 1 January, 2019.
“We are trying to make the codes as easy to understand and use as possible, but we do always have to remember that the underlying regulations or conventions come from the IMO and are designed for the international shipping community, which is inherently more experienced and more professional in their applications of the regulations,” adds Assael. “Designing and building a superyacht isn’t a simple thing and the Large Yacht Code and Passenger Yacht Code are very technical documents – we can’t dumb them down too much because they have to achieve a certain standard that is acceptable to the wider shipping community when we notify the IMO of the codes.”
With the new code, the Red Ensign Group also wants to look at industry best practice: certain construction equivalents have become such standard industry practice over the years and it is intended that these are written into the code. “We want to streamline that and make sure we are regulating how people are building boats today, as opposed to how they were building boats when we first wrote the Large Yacht Code in 1997,” explains Assael.
Examples of such standard practice tend to be on the engineering side of the vessel; for instance, ventilator exhaust and air pipes are required to have weathertight, closure, but on yachts they are generally all hidden in the bulwark or in the headlining. They are in protected locations so either there isn’t ready access to them or their protection from the weather is already afforded in the design, meaning the requirement for weathertight closure is not necessary.
“It is these ‘behind-the-scenes’ tweaks that never actually affect the owner’s enjoyment of a vessel or the aesthetics but define the way that we build the vessels and the way that they are operated today,” advises Assael. “We are trying to get them written into the code so builders can take advantage of them, and reduce the burden on build time and cost when it is something that we are happy for them to do from the start, as long as they follow X, Y and Z.”
To date, the REG has been hosting a number of working groups through which it hopes to ascertain what the industry itself hopes to see change. Various working groups have been created, spanning LY3, PYC, helicopter-landing areas and passenger limits. It is hoped that one of the key factors addressed will be allowing innovation while ensuring safe construction.
Profile links
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- Manning & Crew Requirements
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Crew Requirements – Minimum Safe Manning Certificate (MSMC)
All commercially registered yachts, PYLCs, YETs, and PAXYs are required to have an MSMC on board to ensure that RMI yachts are safely manned and in accordance with international regulations. For commercial yachts, YETs, and PAXYs these manning requirements apply whenever the yacht proceeds to sea. For PYLCs, the manning requirements apply when the yacht proceeds to sea with charter guests on board. RMI manning scales are available in the RMI Yacht Code 2021, as amended through August 2023 (“ MI-103 ” or the “Code”) or Minimum Safe Manning Requirements for Vessels ( MN 7-038-2 ).*
*Please note that these scales are the minimum requirements for motor yachts and alternative certification may be considered acceptable on a case-by-case basis. There may be additional personnel and/or training requirements based on the yacht type, propulsion power, etc. Minimum safe manning requirements may be applicable to private yachts depending on the yacht’s size and location of operation. It is the overriding responsibility of the owner of a private yacht to ensure safe manning.
Application for Minimum Safe Manning Certificate — Yacht ( MI-336Y )
Seafarer’s Identification and Record Book (SIRB) and Identification Card
All masters, officers, and crewmembers are required to possess proof of Standards of Training, Certification and Watchkeeping (STCW) Basic Safety Training (BST) and an RMI SIRB.
Application for Seafarers’ Identification and Record Book and Special Qualifications ( MI-273 )
Master and Officer Licensing and Certification
All masters and officers listed on the MSMC are required to possess a valid Certificate of Competency (CoC) and RMI endorsement.
Application for Endorsement of Officer Certificate of Competence ( MI-105 )
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Master (Yachts) — Unlimited Tonnage CoC
The RMI developed a one of a kind STCW compliant Master (Yachts) Unlimited Tonnage CoC which has broken through the 3,000 gross tons (GT) glass ceiling and allows megayacht captains to further their careers. For preliminary requirements and more information on the Master (Yachts) Unlimited Capstone Course, please contact the Administrator.
Preliminary application requirements for seafarers wishing to apply for the RMI Master (Yachts) — Unlimited Tonnage Certificate of Competence can be found here .
350 GT Master/500 GT Mate’s CoC
This STCW compliant course is intended to prepare the candidate to assume command of an RMI commercial yacht of up to 350 GT and qualify as a Mate on a 500 GT yacht.
Preliminary application requirements for seafarers wishing to apply for the RMI 350 GT Master / 500 GT Mate can be found here .
For further information please contact [email protected] .
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25 May 2021. The updated 2021 Republic of the Marshall Islands (RMI) Yacht Code is now available. This new edition of the Code now makes it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. "The RMI Maritime Administrator has a track record of innovation in the yacht sector ...
THE MARSHALL ISLANDS YACHT CODE 2021 (as amended through August 2023) MARITIME ADMINISTRATOR Aug/2023 MI-103 . Rev. Aug/2023 MI-103 NOTICE The Republic of the Marshall Islands Yacht Code (MI-103) is designed to be read and used as an electronic document. It includes hyperlinks to referenced publications and internal sub-sections.
The RMI Yacht Code (" MI-103 " or the "Code") was first published in 2013. The RMI Yacht Code 2021, as amended through August 2023, is the most significant update to the Code since 2013. The RMI Maritime Administrator revised the Code reflect changes in today's yacht market, not only in terms of the increasing size and complexity of ...
The Marshall Islands have released their new Yacht Code 2021. The RMI Maritime Administrator has further revised the Marshall Islands Yacht Code 2021 to reflect changes in today's yacht market, not only in terms of the increasing size and complexity of yachts being designed and built, but also to cover recent industry developments. The Code was first published in 2013 and this is the most ...
The Code provides a common sense and practical approach to evolving safety and technical issues. This 2021 Code incorporates all Yacht Code Supplements issued as amendments to the previous Code, as well as additional technical and safety updates. These include structural fire protection for yachts of less than 500 gross tonnage (GT) assigned ...
The Republic of the Marshall Islands (RMI) Yacht Code (the "Code") has been updated and amended making it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. The Code was first published in 2013 and this is the most significant update to the Code since then.
February 8, 2019: Liberia surpassed the RMI to again become the world's second largest ship registry. This is correct if only so-called "bluewater" — ocean going — vessels are counted. In gross tonnage, Liberia holds a small lead on the RMI registry, 153.7 million gross tons to 153.1 million gross tons in the bluewater category.
THE MARSHALL ISLANDS . YACHT CODE . 2021 . MARITIME ADMINISTRATOR . May/2021. MI-103 (2021) Rev. May/2021 MI-103 (2021) NOTICE . The Republic of the Marshall Islands Yacht Code (MI-103) is designed to be read and used as an electronic document. It includes hyperlinks to referenced publications and internal sub-sections.
Republic of the Marshall Islands (RMI) Yacht Code (the "Code") has been updated and amended making it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. The Code was first published in 2013 and this is the most significant update to the Code since then. The 2021 Code revisions
"The Republic of the Marshall Islands (RMI) Maritime Administrator has a track record of innovation in the yacht sector," Marc Verburg, Fleet Operations Manager, Yachts, told Dockwalk. "The 2021 RMI Yacht Code was drafted to encompass all the latest developments in the design, build, and operation of large and small yachts."
THE MARSHALL ISLANDS YACHT CODE for Commercial Yachts and Private Yachts Limited Charter OFFICE OF THE MARITIME ADMINISTRATOR 6/13 MI-103 . Rev. 6/13 MI-103 ... c/o Marshall Islands Maritime and Corporate Administrators, Inc. 11495 Commerce Park Drive Reston, Virginia 20191-1506 USA Telephone: +1-703-620-4880 ...
May 12, 2021. 0. 812. (Image Courtesy: The Republic of the Marshall Islands) The Republic of the Marshall Islands (RMI) Yacht Code (the "Code") has been updated and amended making it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. The Code was first published in 2013 and this ...
May 11, 2021. The Republic of the Marshall Islands (RMI) Yacht Code (the "Code") has been updated and amended making it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. The Code was first published in 2013 and this is the most significant update to the Code since then.
About Us. United Maritime Survey is the largest and most reputable Appointed Representative (AR) for the Republic of the Marshall Islands (RMI). They specialize in the RMI Yacht Code and regulatory compliance for large luxury yachts. With a footprint across the globe, UMS surveyors are ready to be dispatched at a moment's notice.
REPUBLIC OF THE MARSHALL ISLANDS - YACHT COMPLIANCE REQUIREMENTS Rev. Nov/2022 5 MI-103A 3.0 Private Yachts Limited Charter For further requirements, refer to the RMI Yacht Code (MI-103) - Chapter IV located on www.register-iri.com. PRIVATE YACHTS LIMITED CHARTER (PYLC) <24 M >24M REFERENCES REMARKS <300GT <400GT ≥400GT
Marshall Islands. Digital Maritime Regulations Marshall Islands. Combines Flag State documentation, IMO Codes, Conventions and Forthcoming Amendments, ILO protocols and Guidelines and EU Legislation. Flag documentation includes: Act (MI-107) Regulation (MI-108) Codes; Notices ...
The Marshall Islands Yacht Code has long been designed to address the practical issues faced by builders, managers, and owners alike; it last had a major update in 2015. For many builders of large yachts, the appeal of the RMI lies in the differentiation in the standards for yachts capable of carrying more than 12 guests.
According to the Republic of the Marshall Islands (RMI) work is underway to update the RMI Yacht Code. Taking input from across the registry's specialist teams, as well as external experts, a revised version of the code is expected to be ready in the first half of 2021. "We hope that these amendments to the Code will make it more practical ...
The Republic of the Marshall Islands (RMI) Yacht Code has been updated and amended making it more pragmatic than ever for modern and innovative owners and shipyards to choose the RMI as a building standard. The Code was first published in 2013 and this is the most significant update since then. The 2021 Code revisions incorporate all previously issued supplements as well as additional ...
RMI makes local yacht building more attractive following Code change. 12 May 2021 • by Nic Robinson. The Republic of the Marshall Islands (RMI) has updated its Yacht Code to make the country more attractive for builders and owners to produce and flag there. To continue reading... you need to register...
The new code will consolidate an updated version of the Large Yacht Code (LY3) and the latest version of the Passenger Yacht Code (PYC) and aim to make the code more usable. This all-encompassing concept will not be a first for yacht coding - the Marshall Islands Shipping Registry's RMI Code has one document that covers both large yachts ...
Commercial Yachts and Passenger Yachts (PAXYs) Dual Use (PYLC & YET) Private Yachts. Private Yachts Revised. RMI Yacht Code 2021. RMI Yacht Code 2021 Revised. Yacht Contacts. Yacht-General Information.
For PYLCs, the manning requirements apply when the yacht proceeds to sea with charter guests on board. RMI manning scales are available in the RMI Yacht Code 2021, as amended through August 2023 (" MI-103 " or the "Code") or Minimum Safe Manning Requirements for Vessels (MN 7-038-2).*. *Please note that these scales are the minimum ...