Direct Request (CEACR) - adopted 2019, published 109th ILC session (2021)

Seafarers' Identity Documents Convention (Revised), 2003, as amended (No. 185) - Russian Federation (Ratification: 2010)

Other comments on C185

Direct Request

2019
2012

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The Committee notes the observations of the Trade Unions Federation of Workers of Maritime Transport (FPRMT), received by the Office on 6 November 2014. The Committee recalls that in its general observation adopted in 2015, it noted with satisfaction that, at its 324th Session in June 2015, the Governing Body approved the inclusion of the Russian Federation as the first ratifying Member to be listed as fully meeting the minimum requirements referred to in Article 5(1) of the Convention. The Committee notes that, since then, the Convention was amended. The 2016 amendments to the Annexes of the Convention entered into force for the Russian Federation on 8 June 2017. It recalls that these amendments aim at aligning the technical requirements of the Convention with the latest standards adopted by the International Civil Aviation Organization (ICAO) with respect to the technology for seafarers’ identity documents (SIDs) provided for in the Convention. In particular, they intend to change the biometric template in seafarers’ identity documents from a fingerprint template in a two-dimensional barcode to a facial image stored in a contactless chip as required by ICAO Document 9303. While commending the Government for its efforts to give effect to the previous version of the Convention, the Committee requests the Government to address the issues raised below and to provide information on the measures taken to ensure conformity with the amended version of the Convention.

Article 1. Scope of application. Concerning the definition of seafarers, the Committee refers to its comments made in the framework of the examination of the application by the Russian Federation of Article II(1)(f) of the Maritime Labour Convention, as amended, 2006 (MLC, 2006).

Article 2, paragraph 4. Issuance of SIDs without delay. The Committee notes that the FPRMT expresses concern over the steps taken by the Government, in particular the adoption of Order No. 134 of 27 May 2014 of the Ministry of Transport, which amends Ministerial Order No. 213 of 19 December 2008 on the instructions on the procedure for the identification of seafarers. The FPRMT indicates that under Order No. 134, seafarers applying for an SID shall have any documents issued abroad legalized and present a notarized translation of documents drawn up in a foreign language. According to the FPRMT, these amendments, by complicating the procedures to obtain SIDs and entailing additional expenses for the applicants, do not ensure full compliance with the Convention. Recalling that the Convention requires that SIDs are issued without undue delay (Article 2, paragraph 4), the Committee requests the Government to indicate the measures taken to ensure full compliance with this requirement of the Convention.

Articles 3–5. Seafarers’ identity documents. The Committee notes the Government’s information that it has started preparing for the introduction of new standards for SIDs taking into account the 2016 amendments. Currently, a new form of SID has been developed, which includes a contactless electronic microchip. The new SID is a plastic card of TD1 size. The main software changes envisaged include: new procedures for personalizing the SID; the withdrawal of procedures for registering fingerprints; the use of cryptographic functions; new procedures for monitoring SIDs; and cooperation with the ICAO Public Key Directory (PKD). In this regard, the Government stresses that it is already a member of the ICAO PKD, which facilitates the sharing of electronic certificates with ICAO to verify new SIDs. The Government also indicates that initially, after modernization of the system for issuance of SIDSs, both new and old documents will be issued during a defined period of transition. While the previous documents will still be used, all port administrations will transfer to the issuance of new SID. The Federal Maritime and River Transport Agency is currently preparing a request for the funding required for additional equipment and the introduction of necessary changes to the system for the SIDs issuance. The Government stresses that comprehensive effort and significant time is required for the implementation of the amendments. The Committee welcomes the Government’s efforts to implement the 2016 amendments. It requests the Government to provide information on any developments in this regard, in particular on the adoption of laws and regulations or other means through which the requirements of Articles 3–5 of the Convention and Annexes I–III, as amended in 2016, are implemented.