Rev. 0

REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

San Marino Policy Letter
SMPL – 2022-TEC-005
06 October 2022
San Marino Ship Register SMSR
Principles of Minimum Safe Manning

TO: Recognised Organisations, Shipowners, Managers, Masters, Seafarers, SMSR partners, SMSR
brokers, Surveyors, and the general public.

REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

Rev. nDate

Changes

Initials

0061022n/anc

2REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

Principles of Minimum Safe Manning
1. Introduction
The Administration applies the provisions of IMO res. A.1047(27) “Principles of Minimum Safe
Manning” to all ships flying the San Marino Flag, to which article III of the 1978 STCW Convention,as amended, and chapter XI-2 of the 1974 SOLAS Convention, as amended, apply.
These Guidelines complement the provisions set forth in the San Marino Small Yacht Safety Codeand Large Yacht Safety Code.
The Company shall propose to the Administration Minimum Safe Manning Documents in line withthe provisions of this Policy Letter, as well as SMPL Hours of work and rest.
2. Principles of Safe Manning
San Marino-flagged vessels shall be sufficiently, effectively, and efficiently manned to provide safety
and security, safe navigation and operations at sea, safe operations in port, prevention of human
injury or loss of life, the avoidance of damage to the marine environment and to property, and toensure the welfare and health of seafarers through the avoidance of fatigue.
The following principles should be observed in determining the minimum safe manning of a ship.
2.1 The ship shall have the capability to:a) Maintain safe navigational, port, engineering, and radio watches in accordance withregulation VIII/2 of the 1978 STCW Convention, as amended, and also maintain generalsurveillance of the ship.
b) moor and unmoor the ship safely.
c) manage the safety functions of the ship when employed in a stationary or near-stationarymode at sea.
d) perform operations, as appropriate, for the prevention of damage to the marine environmente) maintain the safety arrangements and the cleanliness of all accessible spaces to minimize
the risk of fire.
f)provide for medical care on board ship.

3

REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.smg) ensure safe carriage of cargo during transit.
h) inspect and maintain, as appropriate, the structural integrity of the ship; andi)operate in accordance with the approved Ship's Security Plan.

2.2 The ship shall have the ability to:a) operate all watertight closing arrangements and maintain them in effective condition, andalso deploy a competent damage control party.
b) operate all onboard fire-fighting and emergency equipment and life-saving appliances, carryout such maintenance of this equipment as is required to be done at sea, and muster anddisembark all persons on board; andc) operate the main propulsion and auxiliary machinery including pollution prevention
equipment and maintain them in a safe condition to enable the ship to overcome theforeseeable perils of the voyage.
2.3 Ongoing training shall be scheduled regularly for all personnel, including the operation anduse of fire-fighting and emergency equipment, life-saving appliances, and watertight closing
arrangements. Specialized training requirements shall be taken into consideration for specifictypes of ships and in instances where crew members are engaged in shipboard tasks thatcross departmental boundaries. New entrant seafarer training shall be scheduled to gain thenecessary skills and experience.
2.4 In addition, provisions shall be made for the following requirements:a) Proper food and drinking water supply.
b) Assignment of emergency duties and responsibilities.

3. Guidelines for the determination of safe manning
3.1 The minimum safe manning of a ship should be established taking into account all relevant
factors, including but not limited toa) size and type of shipb) number, size, and type of main propulsion units and auxiliaries

4

REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.smc) level of ship automationd) construction and equipment of the shipe) method of maintenance usedf)cargo to be carriedg) frequency of port calls, length, and nature of voyages to be undertakenh) trading area(s), waters, and operations in which the ship is involvedi)the extent to which training activities are conducted on boardj)degree of shoreside support provided to the ship by the companyk) applicable working hours limits and/or rest requirementsl)the provisions of the approved Ship's Security Plan

3.2 The determination of the minimum safe manning of a ship should be based on theperformance of functions at the appropriate level(s) of responsibility, as specified in the
STCW Code, including the followinga) navigation, comprising the tasks, duties and responsibilities required to:-plan and conduct safe navigation-

maintain a safe navigational watch in accordance with the requirements of the STCW Code-maneuver and handle the ship in all conditions-

moor and unmoor the ship safelyb) cargo handling and stowage, comprising the tasks, duties and responsibilities required toplan, monitor and ensure safe loading, stowage, securing, care during the voyage andunloading of cargo to be carried on the ship.
c) Operation of the ship and care for persons on board, comprising the tasks, duties, andresponsibilities required to:-maintain the safety and security of all persons on board and keep life-saving, fire-fighting andother safety systems in operational condition-

operate and maintain all watertight closing arrangements-

perform operations, as appropriate, to muster and disembark all persons on board

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm-

perform operations, as appropriate, to ensure protection of the marine environment-

provide for medical care on board the ship-

undertake administrative tasks required for the safe operation and the security of the shipd) marine engineering, comprising the tasks, duties and responsibilities required to:-operate and monitor the ship's main propulsion and auxiliary machinery and evaluate theperformance of such machinery-

maintain a safe engineering watch in accordance with the requirements of the STCW Code-manage and perform fuel and ballast operations-

maintain safety of the ship's engine equipment, systems and servicese) electrical, electronic, and control engineering, comprising the tasks, duties andresponsibilities required to-operate the ship's electrical and electronic equipment-

maintain the safety of the ship's electrical and electronic systems

f)radiocommunications, comprising the tasks, duties and responsibilities required to-transmit and receive information using the radio equipment of the ship-

maintain a safe radio watch in accordance with the requirements of the ITU Radio
Regulations and the 1974 SOLAS Convention, as amended-

provide radio services in emergenciesg) maintenance and repair, comprising the tasks, duties and responsibilities required to carryout maintenance and repair work to the ship and its machinery, equipment and systems, as
appropriate to the method of maintenance and repair used.
3.3 In addition to the factors and functions listed above, the determination of the minimum safemanning should also take into account:a) the capability of the master and the ship's complement to coordinate the activities necessary
for the safe operation and for the security of the ship and for the protection of the marine
environment.

6

REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.smb) the number of qualified and other personnel required to meet peak workload situations andconditions, with due regard to the number of hours of shipboard duties and rest periods
assigned to seafarers.
c) except in ships of limited size, the provision of qualified deck officers to ensure that it is notnecessary for the master to keep regular watches by adopting a three-watch system; inparticular, except for ships of 3,000 GT or less, the Master should not keep a regularnavigation or engineering watch.
d) except in ships of limited propulsion power or operating under provisions for unattended
machinery spaces, the provision of qualified engineer officers to ensure that it is notnecessary for the chief engineer to keep regular watches by adopting a three-watch system;in particular, except for ships of less than 3,000 kW the Chief Engineer should not keep aregular navigation or engineering watch.
e) Except in ships of 3,000 GT or less or 3,000 kW or less, as applicable, or vessels on limited
voyages or engaged in special occupations, a three-watch system should be adopted forboth navigational and engine room watches (unless the vessel is certified for unattended
machinery operations).
f)

the maintenance of applicable occupational health and hygiene standards on board.

g) the provision of proper food and drinking water requirements for all persons on board.
h) Training schedules and the provision of appropriate training opportunities to seafarers.

4. Additional Considerations
4.1 Unattended Machinery Spaces (UMS)
Specifications on the vessel’s mode of operation, whether in UMS mode or with a manned engine
room, shall be contained in the Minimum Safe Manning Document issued by the Administration.
To operate in UMS mode, the vessel must be certified for periodically unattended engine room
operation in accordance with the vessel’s Classification Society requirements.

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

In vessels certified for unattended or periodically unattended machinery operations, a sufficientnumber of qualified personnel must be carried to provide manual control of machinery in an
emergency, to enable the vessel to reach port.
In the event of a failure of the UMS system, the Company shall inform the Administration
immediately. The Administration may require amendments in the number of engine room personnel
if deemed inadequate.
Following the assessment, there may be a requirement for additional engine room personnel and ashort term minimum safe manning document will be issued reflecting this increase in personnel.
This will state the vessel is operating with a manned engine room. When the engine room is being
operated in a non-UMS mode the engine room should be manned by at least 2 persons.

4.2 Cook
A qualified ship’s cook is required for vessels operating with a prescribed manning of 10 or moreseafarers on voyages of more than 3 days or more than 36 hours from a safe port.

4.3 ISPS CodeOn board all ships to which the ISPS Code applies, seafarers’ security duties at all security levels
must be taken into account. A ship security officer must be nominated, who is qualified in accordancewith STCW Reg. VI/5. and all seafarers must be qualified in accordance with STCW Reg. VI/6.
4.4 GMDSS
Every person performing radio duties on a ship which operates with a GMDSS radio system shallhold an appropriate certificate for GMDSS radio operators.
If there is no duplication of the GMDSS equipment on board and no shore-based maintenanceemployed by the vessel owner/operator, a dedicated radio maintainer must be on board who holds
either a GMDSS-1st Class or GMDSS-2nd Class Radio Electronic Operator and Maintainer Certificate
and is designated as having primary responsibility for radio communications during distressincidents.

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

For vessels sailing without a radio maintainer on board, at least two deck officers are required tohold the GMDSS-General Operator Certificate. One (1) of the operators shall be designated ashaving primary responsibility for radio communications during distress incidents. Under thesecircumstances, there shall be duplicate GMDSS equipment on board, and shorebased maintenanceservice of the equipment contracted by the vessel owner/operator.
4.5 ECDIS
Officers involved in navigation on ECDIS-equipped vessels shall be certified as meeting training
requirements as identified in STCW Table A-II/1. The type specific ECDIS familiarization training
shall be included in the officers’ onboard training record.
4.6 Electro technical officers or ratings
The Minimum Safe Manning Certificate may include Electro-Technical Officers STCW III/6 and/orElectro-Technical Ratings STCW III/7 if the company has assigned duties to satisfy the requirementsof:-The maintenance of a safe engineering watch,-

Emergency as specified in the Muster List, and/or-

The maintenance of the ship’s electrical, electronic, and control systems.

After 1 January 2017, Engineering Officers, and Electro Technical Officers serving on board vessels
with power plants rated over 1000 volts must show completion of a high voltage course, or national
certification indicating compliance with the high voltage training requirements.
4.7 Frequent STS operation
In the case of ships engaged in frequent ship-to-ship cargo transfer operations, particular attention
must be paid to the factor of bridge watch during cargo operations. Special consideration must be
given to the employment of additional dedicated personnel for cargo operation, who are not involved
in ship maneuvering and bridge watch.
4.8 Lifeboat operationa) Two survival craft/rescue boat crewmen are required for each lifeboat on ships in accordancewith SOLAS chapter III, reg. 10. One person shall be designated the person -in-charge andanother designated the second-in-command. In addition to the certified survival craft/rescue

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

boat crewmen assigned to each motor lifeboat, there shall be a certified engineer or rating
capable of starting the lifeboat engine and troubleshooting minor engine problems.
b) A survival craft/rescue boat crewman shall be carried for each liferaft on board a vessel, andone additional certified survival craft/rescue boat crewman shall be assigned to each davitlaunched liferaft and rescue chute boarding station to supervise the launching and boarding
activities.
c) Fast rescue boats shall be crewed by at least two survival craft/rescue boat crewmen
specially trained and additionally certified in accordance with STCW Code Section A-VI/2,“Proficiency in Fast Rescue Boats.”

4.9 Lifeboat operation on passenger shipsa) On passenger ships, survival craft/rescue boat crewmen are required for lifeboats inaccordance with the scale given below as a standard for general guidance. Where more than
two survival craft/rescue boat crewmen are required for a motor lifeboat, one of the survival
craft/rescue boat crewmen may be the required certified engineer or engine rating capableof starting the lifeboat engine and troubleshooting minor engine problems.

Complements of

Number of

Other

Lifeboat survival

certifiedassigned

Craftsmen

Crewmembers

40 or less persons

2-

41 to 61 persons

3-

62 to 85 persons

3

2

86 or more persons

34b) On passenger ships, the other assigned crewmembers who are not certified survival
craft/rescue boat crewmen should be selected on the basis of their ability to remain calm,
help others during a period of stress, and follow the directions of the certified survival

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

craft/rescue boat crewman in charge of the lifeboat. Their documented training should include
at least:-

the proper way to put on the Personal Floatation Devices (PFDs) and how to instruct others.

-

where applicable, how to put on Thermal Protective Aids (TPAs) and how to instruct others.

-

where the fire extinguisher is and how to use it.

-where the pyrotechnics are and how to use them.

-where the provisions are and how to open them.

-where the bailers, buckets and bilge pump are and how to use them.

-where the first aid kit is.

-

how to load and seat people safely in the boat-

how to safely embark and disembark disabled persons and persons in need of assistance.

-

where the muster list is located and how to use it.

c) Personnel serving on passenger ships, trained in accordance with Regulation V/2.3, Section
A-V/2, paragraph 1, of STCW 1978, as amended, are required to be nominated on the muster
list in sufficient number to assist the total number of passengers who may be on board at any
one time in emergency situations and shall be included in the ship's Minimum Safe Manningcomplement.

4.10

Committees and representatives

When determining the minimum safe manning of a ship, particular attention should be given to themanning requirement for safety committees, safety representatives, and safety officers.

5. Procedures for determining Minimum Safe Manning
5.1 Submission of a proposal by the Company
The Administration may require the Company to prepare and submit a proposal for the minimum
safe manning of a ship, as per Annex II to this Policy Letter.

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

In preparing a proposal for the minimum safe manning of a ship, the Company should apply theprinciples, recommendations, and guidelines contained in IMO res. A.1047(27), Principles of Safe
Manning.
The proposed ship's complement shall contain the number and grades/capacities of personnel tofulfil the tasks, duties, and responsibilities required for the safe operation of the ship, for its security,
for protection of the marine environment and for dealing with emergency situations.
The master, officers, and other members of the ship's complement should not be required to work
more hours than is safe in relation to the performance of their duties and the safety of the ship. The
requirements for work and rest hours, in accordance with applicable national regulations, shall becomplied with.
In proposing the ship’s complement, the Company will take proper account of existing IMO, ILO, ITU
and WHO instruments in force which deal with:-watchkeeping-

hours of work or rest-

safety management-

certification of seafarers-

training of seafarers-

occupational health, safety, and hygiene-crew accommodation and food-security-

radiocommunications

5.2 Approval by the Administration
The Administration will require a company to amend a proposal for the minimum safe manning of aship if, after evaluation of the original proposal submitted by the company, the Administration isunable to approve the proposed composition of the ship's complement.

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

The Administration shall only approve a proposal for the minimum safe manning of a ship and issue
a minimum safe manning document if it is fully satisfied that the proposed ship's complement isestablished in accordance with the principles, recommendations, and guidelines contained in thisPolicy Letter, and is adequate in all respects for the safe operation and the security of the ship andfor the protection of the marine environment.
The Administration will consider the circumstances very carefully before allowing a minimum safemanning document to contain provisions for less than three qualified officers in charge of anavigational watch, while taking into account all the principles for establishing safe manning.
The Administration shall approve the submission of the Company against relevant national andinternational regulatory requirements and guidelines. Having evaluated and approved the proposal
this Administration shall issue a minimum safe manning document including special requirements
and conditions.
The following information will be included in the minimum safe manning document issued by the
Administration specifying the minimum safe manning:-a clear statement of the ship's name, port of registry, distinctive number or letters, IMO
number, gross tonnage, main propulsion power, type and trading area, whether or not themachinery space is unattended and company as defined in the ISM Code.

-a table showing the number and grades/capacities of the personnel required to be carried,
together with any special conditions or other remarks.

-

a formal statement by the Administration that, in accordance with the principles andguidelines set out in this Policy Letter, the ship named in the document is considered to besafely manned if, whenever it proceeds to sea, it carries not less than the number andgrades/capacities of personnel shown in the document, subject to any special conditions
stated therein.

-a statement as to any limitations on the validity of the document by reference to particularsof the individual ship and the nature of service upon which it is engaged.

-

the date of issue and any expiry date as applicable of the document together with a signatureof the Administration

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm

The Minimum Safe Manning Document language will be English.
The minimum safe manning document may be issued with an unlimited or limited trading area. The
Administration may consider a different minimum safe manning level according to the nature of thevessel’s voyages. A vessel which operates part of the time within a limited operational area and partof the time on more extensive voyages may be eligible for more than one minimum safe manningdocument. Similarly, passenger ships which have the capability to operate in more than one mode
may have a separate minimum safe manning document for each mode.
5.3 Monitoring by the Flag StateThe Company shall notify the Administration of any changes affecting the minimum safe manning of
the vessel, and in such circumstances prepare and submit a new proposal taking into account theprovisions of this Policy Letter.
This Administration may periodically review the minimum safe manning arrangements.
The Administration may withdraw the minimum safe manning document of a ship ifa) the company fails to submit a new proposal for the ship's minimum safe manning whenchanges in trading area, construction, machinery, equipment, or operation and maintenanceof the ship have taken place which affect the minimum safe manning.
b) The ship persistently fails to be in compliance with work or rest hours requirements.
c) There are issues concerning construction, machinery, equipment, or operation andmaintenance that have taken place which affect the minimum safe manning leveld) there are clear grounds for believing that the standards or the ability of the seafarers of theship to maintain watchkeeping standards as required by STCW 1978, as amended, are notbeing maintained because of any of the following having occurred-

the ship has been involved in a collision, grounding, or stranding.

-there has been a discharge of substances from the ship when underway, at anchor, or at
berth which is illegal under any international convention.

-

the ship is otherwise being operated in such a manner as to pose a danger to persons,property.

-

the environment or the ship’s security has been compromised.

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REPUBLIC of SAN MARINO
MARITIME AUTHORITY
MAIN CONTACT: SAN MARINO SHIP REGISTER
PH: +378 (0549) 960075| FAX: +378 (0549) 941305| EMAIL: registration@smsr.sm-

the safety inspection and audit record for the vessel indicates that the manning level is not
sufficient.

In addition, Regulation I/4 of SCTW 1978, as amended, enables Port State authorities to verify
conditions on any ship, particularly to the qualifications and ability of personnel on board. In
accordance with section A-I/4 of the STCW Code, Port State authorities may also assess the abilityof the seafarers of the vessel to maintain watchkeeping standards as required by STCW 1978, as
amended, if there are clear grounds for believing that such standards are not being maintained.
6. Temporary dispensation
In exceptional circumstances, the Administration must be contacted to request permission for a
vessel to sail with fewer seafarers than stated on the minimum safe manning document. Wheneverthis circumstance arises, the Administration will make an assessment of the vessel’s manning levels
and a temporary dispensation may be issued to the vessel to sail for limited time as prescribed withfewer persons than stated on the minimum safe manning document.

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REPUBLIC of SAN MARINO
MARITIME AUTHORITYMINIMUM SAFE MANNING STANDARD FOR GENERAL GUIDANCE– ANNEX I

Standards for General Guidance only. Minimum safe manning will be assessed on a ship-by-ship basis upon application to the Administration.
Entry-level ratings (junior ordinary seafarer, wiper, or General Purpose Trainee (GPT) or cadet) are not part of the basic minimum safe manning watch standing complement.

REPUBLIC of SAN MARINO
MARITIME AUTHORITYMINIMUM SAFE MANNING STANDARD FOR GENERAL GUIDANCE– ANNEX I

REPUBLIC of SAN MARINO
MARITIME AUTHORITY

ANNEX II – APPLICATION FOR THE MINIMUM SAFE MANNING CERTIFICATEFOR SHIPS WHICH MUST COMPLY WITH THE STCW REQUIREMENTS

CLASS SOCIETY:

Owners should feel free to attach whatever additional information owner feels supports his proposal for reduced Manning.
Catering Department personnel are not included in minimum safe manning unless they are trained general purpose
personnel. Application will be reviewed by San Marino Maritime Authority and a Minimum Safe Manning Certificate
will be issued, provided all necessary information requested of owner has been provided to this Administration to ensurecompliance with IMO resolution A.1047(27).

MAIL APPLICATION TO: SAN MARINO SHIP REGISTER : flagstate@smsr.sm

Every Company applying for a MSM with a manning different from the standard provided in the Policy Letter “Minimum
Safe Manning” must provide written justification (via email) to support the revised MSM and shall include the following
set of documents:
the general arrangement plan, with details of the navigational bridge, engine rooms and accommodations details;
the safety plan;
the muster list;
the navigation and engineering watch lists,
the table showing the working /rest hours for the crewa Description of tasks conducted by other groups to support the crew, such as riding crews for maintenanceand cargo teams to manage the loading and unloading of the ship.
Evaluation by the Administration: The Administration will evaluate the submission of the company against relevant
national and international regulatory requirements using the guidelines found in the Policy Letter “Minimum Safe
Manning”.