Ghana introduces COVID-19 vaccination requirements for seafarers *Update*

Update 21 January 2022

Budd Group have provided further clarification on the withdrawal of enforcement of the seafarer vaccine directive in Ghana. The Ghana Health Service advise that although the imposition of fines has been suspended until further notice, Covid-19 vaccinations remain mandatory for all seafarers on vessels calling in Ghana’s ports or carrying out operations at anchorage which require the presence of Ghanaian resident on board.

Budd also informs that if an unvaccinated crew member refuses the mandatory vaccination, his vessel will not be granted free pratique. The vessel may be allowed to transfer the unvaccinated crew member to another vessel at anchorage as long as that vessel is not intending to carry out any operations for which the presence of a Ghanaian resident will be required.

Update 13 January 2022

Sheringham P&I Services have provided an update on the enforcement of the Ghana seafarer vaccine directive. The Ghana Health Service issued a clarification on 10 January 2020 advising that enforcement of the directive has been withdrawn.

06 January 2022

This follows the recent changes to the entry requirements for airline passengers that took effect on 14 December 2021 and the President’s address on 16 December which called for all visitors to Ghana to be fully vaccinated.

The Ghana Port Health Service advised on 20 December 2021 that all crew arriving on vessels at ports in Ghana are to be fully vaccinated. If any of the crew are unable to provide vaccination cards to show they are fully vaccinated, the vessel will not be granted free pratique and can face a financial penalty of US$ 3,500 per unvaccinated person.

Following payment of the fine, the unvaccinated persons will receive a single dose of the Johnson & Johnson vaccine, administered by Ghana Port Health for no extra cost.

It was initially reported Ghana Port Health would allow a grace period up until 15 January 2022, and after this date fines as detailed above may be levied.

However, some local sources and Club correspondent McLeans have since reported that the introduction of this mandatory vaccination programme has been suspended until further notice.

The position taken by port authorities can change at any time, and vessels intending to call at Ghanaian ports should be aware that any such suspension could be lifted, and the requirements strictly enforced, with little notice.

While the efforts of States to assist in the vaccination of seafarers is welcomed by many in the industry, Members with vessels calling at Ghana should be mindful of the potential complications introduced by a mandatory vaccine programme. There may be potential employment law issues that require legal advice, from both the jurisdiction of the crew contracts and Flag State, regarding potential crew changes of unvaccinated crew prior to vessels calling at Ghana and also in relation to attempts to vaccinate unvaccinated crew on the vessel’s arrival.

Note that the crew must complete health declaration forms online 24 hours before arriving at point of entry: https://ghs-hdf.org/index.php

Further information is available in the Ghana Port Health Service notices which can be read here:

• Port Health Letter 1 – Click Here
• Port Health Letter 2 – Click Here

Thanks to:

• The McLean Group: https://mcleangroup.fr/en/home/
• Budd Group: https://www.budd-pni.com/ghana-covid-19-fine-tema-holiday-arrangements/
• OMA Group: https://www.omagroup.com/
• Inchcape Shipping Services: https://www.iss-shipping.com/coronavirus-port-country-implications