Who may service your lifeboats, and what the paperwork has to prove

Where the requirement comes from

IMO Resolution MSC.402(96) was adopted on 19 May 2016 and took effect on 1 January 2020, when the associated amendments to SOLAS III/3 and III/20 entered into force. Resolution MSC.404(96) is what made it mandatory: it inserted the definition in SOLAS III/3.25 and replaced SOLAS III/20.11.

Resolution MSC.559(108), adopted 23 May 2024, entered into force on 1 January 2026. It changed one thing: paragraph 6.2.3 of MSC.402(96) now adds a tenth item to the annual thorough examination of lifeboats, rescue boats and fast rescue boats, the ventilation system where fitted. Nothing else in MSC.402(96) was touched.

Authorised means two different things at once

This is the point most often stated wrongly. The company is authorised by the flag Administration. The individual technician is certified by the manufacturer, or by an authorised service provider whose own certification programme complies with section 8.

• MSC.402(96) 2.2.1: an authorised service provider is an entity authorised by the Administration under sections 3 and 7. The flag may delegate this to its recognised organisation, 7.4.3.
• MSC.402(96) 8.1: personnel shall be certified by the manufacturer or authorised service provider for each make and type of equipment to be worked on.
• MSC.402(96) 8.3.1: the technician's certificate states the level of qualification and the scope, which makes and types, and which of the 4.2 and 4.3 activities it covers. It expires three years from the date of issue.
• MSC.402(96) 3.2: section 7 applies to manufacturers in the same way when they act as service providers.

Who may do which job

The two 1.1 times tests, which are not the same test

Both are at intervals not exceeding five years and both use a load of 1.1 times, but they test different things and are frequently confused in service reports.

What the service pack has to contain

Section 5 of MSC.402(96) is short and it is the part that decides whether a survey goes smoothly.

• 5.1: every report and checklist is completed and signed by the person who did the work, and countersigned by the Company's representative or the master.
• 5.2: records are updated and filed on board for the service life of the equipment. Not for one survey cycle, for the life of the equipment.
• 5.3: on completion of thorough examination, operational testing, overhaul or repair, a statement confirming the lifeboat arrangements remain fit for purpose is promptly issued, with copies of the valid documents of certification and authorisation included with it.

So the pack is the signed and countersigned checklists, the statement of fitness for purpose, a copy of the service provider's authorisation document, and a copy of the technician's certificate with its scope and expiry date visible. A report without the last two is incomplete.

When the maker no longer exists or no longer supports the equipment

There are two recognised routes and neither of them is improvisation.

• The definition route. MSC.402(96) 2.2.3: manufacturer means the original equipment manufacturer, or any entity which has taken legal and legitimate responsibilities for the equipment when the original manufacturer no longer exists or supports it.
• The Administration route. MSC.402(96) 7.3: where a manufacturer is no longer in business or no longer provides technical support, Administrations may authorise service providers for that equipment on the basis of prior authorisation for the equipment, or long-term experience and demonstrated expertise.

Flags implement 7.3 differently. Liberia operates single-time authorisations under SAF-019 3.3, case by case, where the maker is out of business or where the ship is in a port with no provider authorised for that make. The Marshall Islands, in MN 2-011-37 8.2.5, requires a short-term certificate from the relevant recognised organisation where timely servicing cannot be done by a provider certified for that make and type.

We work a large number of makes, including equipment whose original manufacturer no longer supports it. Where that is the case we obtain the authorisation from the vessel's flag before the examination, and the authorisation goes into the service pack.

What port state control looks at

There is no deficiency code specific to MSC.402(96). Paris MoU and Tokyo MoU use the same harmonised code list, and the ones that get used in this area sit in Area 11.

What an officer is documentarily entitled to look at follows directly from the mandatory text: the maintenance manuals kept up to date by the Company (6.1.2, 6.1.3), the weekly and monthly records and the annual thorough examination report signed and countersigned (5.1), the records filed on board for the service life of the equipment (5.2), the statement of fitness for purpose with the authorisation and certificates attached (5.3), and the date of the last five-yearly overload test and release gear overhaul.

Two things we will not tell you, because they are not established

• MSC.402(96) contains no numbered certification levels. It requires the certificate to state a level of qualification and a scope, but it does not define Level 1, Level 2 or Level 3. The numbered levels come from ISO 23678:2022, Part 3 Level 1 technical training and Part 4 Level 2 in-field competence. What each of those permits in practice is inside a paywalled standard, so anyone publishing a neat table of who may do what by level is guessing.
• MSC.402(96) does not require a class surveyor to attend the five-yearly test. Some flags do. The Marshall Islands requires attendance in MN 2-011-37. Liberia says in SAF-019 that it should be done in the presence of an authorised classification society surveyor. Other flags differ. Check your flag, not a general claim.

Sources

Every figure above was taken from the primary document. These are the documents themselves, not summaries of them.

• Res. MSC.402(96)
• Res. MSC.404(96), SOLAS III/20.11
• Res. MSC.559(108)
• Liberia Marine Notice SAF-019
• Marshall Islands MN 2-011-37
• Paris MoU deficiency codes, 1 July 2025