Orientation
Governing: MI-118 §2.6, §7.1; MI-280; MN 7-038-2 §4.3; IRI Yacht Solutions. Builds on: L2.3, L3.1.
The division of labour
Nothing in the RMI documents makes crew paperwork one person's job. The publications split it roughly like this:
| Party | What the RMI documents expect of them |
|---|---|
| Seafarer | Genuine documents; sign in front of the filing agent; keep the original medical and certificates; hand certificates to the Master on joining; watch the 90-day clock |
| Filing agent (management company, crew agency or captain) | Check completeness; verify identity and photo; check medical; review originals; confirm national CoC validity with the issuing authority; witness signature; submit with fee |
| Master | Sign CRAs to make them valid; receive officers' certificates on joining; act as filing agent for own crew if holding RMI documentation; keep SIRB sea service entries; check crew against the MSMC |
| Owner / operator / designated person | Overall responsibility for proper certification; apply for the MSMC on MI-336Y; request dispensations; report changes affecting manning |
The captain as filing agent
IRI's Master Acting as Filing Agent leaflet is one of the more practical things the RMI has done for yachts. A master holding valid RMI documentation can review and sign crew applications for endorsements and SIRBs for the yacht they command, with no third-party agent. A master who joins on a CRA or UA can take on the role once aboard. Copies of seafarer documents are acceptable for processing.
MI-280 fills in two edges: the Master can sign the MI-273 in place of the filing agent when the seafarer is on board, and the Master cannot act as filing agent for their own application.
TIP — Captains: keep a register If you file for your crew, keep a simple register: name, document, date filed, CRA or MI-273OR expiry, date received. It becomes your evidence when the Yacht Inspector asks.
The management company
Management companies commonly hold filing-agent authority and run applications from the office. Under MI-280 the filing agent is ultimately responsible for making sure applications are complete and correct, and, by reference to the ISM Code, is responsible to the operator for ensuring seafarers are qualified and fit. A company that submits an application containing a wilful misstatement or forged document faces a USD 500 administrative penalty per application and may be barred from further submissions (MI-118 §2.10.3).
The owner
MI-118 §7.1 makes the owner/operator responsible for ensuring the crew hold the right paper, and encourages talking to the yacht's underwriters so the yacht is fully compliant with flag requirements. MN 7-038-2 puts the MSMC application in the hands of the owner or the designated person, and dispensations must be requested by the owner, operator or Master.
The seafarer
You own your own documents. Nobody else can sign your affidavit, sit your medical or make up for a certificate that lapsed while you were on leave.
WARNING — Fraud is personal MI-118 §2.10 is aimed at the applicant first: refusal, forfeited fees, a bar of at least two years, and a USD 500 penalty for anyone who knowingly submits false or altered documents. The agent who helped you is penalised too, but that will not save your career.
At the inspection
MI-290 tells Yacht Inspectors to check the crew list against the MSMC and each person's documents, and to record in Part E of the MSD 252 report anyone without a CoC/CoE, CRA, UA or SIRB (or its application copy). The captain answers those questions; the paperwork trail answers them faster.