CMNT_TITLE

Seafarers' Identity Documents Convention (Revised), 2003, as amended (No. 185) - Pakistan (RATIFICATION: 2006)

Other comments on C185

Direct Request

2019
2012

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Article 2 of the Convention. Issuance of seafarers’ identity documents (SIDs). The Committee notes the Government’s succinct first report on the application of the Convention, which merely refers to the Merchant Shipping Ordinance, 2001, and its provisions on seafarers’ service books but does not indicate how effect is given to the detailed technical standards of the Convention. The Committee recalls, in this connection that, in July 2007, the Office conducted a review of the system of issuance of SIDs and made a number of recommendations to facilitate proper implementation of the Convention. The Office concluded that existing legislation basically reflected the requirements of the Seafarers’ Identity Documents Convention, 1958 (No. 108), and should therefore be revised to provide for the issuance of SIDs in accordance with this Convention. It also identified a number of areas where changes to the SID system and procedures were necessary – to the point that the 4,000 SIDs that had already been issued needed to be reissued – and advised that the Government should arrange for a full external evaluation of the issuance and production system once all outstanding issues had been addressed. The Committee accordingly requests the Government to specify any new legislative provisions that may have been adopted for the implementation of the Convention.

Article 3. Content and form of SIDs. The Committee recalls that, according to the findings of the technical review undertaken by the Office in 2007, the SIDs issued by the National Database and Registration Authority (NADRA) were defective since they were not reliably machine readable and were not compliant with the International Civil Aviation Organization (ICAO) 9303 specifications, as prescribed by Article 3 and Annex I of the Convention. Problems were also identified with the software used which did not appear to be the ILO SID-approved software. The Office had accordingly recommended that after modifications, the new SID should be resent to the ILO for retesting. The Committee requests the Government to indicate any measures taken to follow up on the Office recommendations.

Article 4. National electronic database. The Committee recalls that the Office review had raised a number of points with regard to which the operation of the national electronic database of SIDs kept by NADRA had to be improved to ensure compliance with the requirements of Article 4 and Annex II of the Convention. These improvements included the capability of the database to be promptly updated when a SID is suspended or withdrawn; the availability of the focal point 24 hours per day, seven days a week; the database encryption and appropriate access control mechanisms; and the possibility to record all queries received and processed by the database concerning the authenticity and validity of SIDs. The Committee requests the Government to indicate any action taken to implement these technical recommendations.

Article 5. Quality control and evaluations. The Committee recalls that NADRA started issuing SID cards in September 2005 and that, following the technical review of 2007, the Government was advised to take action with respect to certain deficiencies before it could be deemed to fully meet the requirements of the Convention. In addition, the Office took the view that an independent evaluation of the whole system of SID production and issuance should be arranged and that the evaluation report should be provided to the appropriate organizations of seafarers and shipowners, as required under Article 5 and Annex III of the Convention. The Committee requests the Government to indicate any steps taken or envisaged with a view to: (i) carrying out an independent evaluation of the administration of its system for issuing SIDs; and (ii) ensuring that appropriate organizations of seafarers and shipowners are associated with the implementation of the Convention.