IMO IP Code

From the entry into force of the IP Code (1 July 2024) it will not be sufficient. While the non-mandatory Code of Safety for Special Purpose Ships (2008 SPS Code) addresses non-maritime crew workers who are on board due to the special purpose of a ship (seismic, diving, pipe laying, etc), it explicitly restricts SPS vessels from being used for transportation or accommodation of persons not working on board.

Industrial personnel (IP) are persons who are transported or accommodated on board for the purpose of offshore industrial activities performed on board other ships and/or offshore facilities.

Industrial personnel shall have basic knowledge of the ship (IP Code Reg. III/1.5) and shall have received training in safety procedures, personal survival and the handling of the ship’s personal life-saving equipment (IP Code Reg. III/1.3).

The new IP Code is intended to enable the carriage of industrial personnel. Wherever in the new SOLAS Chapter XV, or in the IP Code, the number of industrial personnel appears as a parameter, it shall be the aggregate number of industrial personnel, special personnel (SPS) and passengers carried on board, where the number of passengers shall not exceed 12. 

Hence, in DNV’s understanding, the IP Code certificate would be sufficient to carry special personnel engaged on board the ship even if no IP are carried simultaneously. When solely carrying SPS personnel (and up to 12 passengers) in addition to the crew, the IP Code does not directly apply, but since the number of IP shall include the number of SPS, technically the IP Code could be applied to carry solely the SPS in addition to marine crew. However, we advise in such cases to clarify the necessary certification with the relevant flag administration.

The mandatory new IP Code is based on the non-mandatory Code of Safety for Special Purpose Ships (2008 SPS Code), but with adaptations and provisions also for the training of industrial personnel, safe personnel transfer and carriage of dangerous goods. Ships carrying toxic products, low-flashpoint products and acids as cargo are not allowed to have more than 60 persons on board.

After the entry into force of SOLAS Ch. XV and the IP Code, any ship carrying more than 12 IP internationally must hold an IP Code certificate. Hence an SPS certificate would not be sufficient, as the ship would not be in compliance with SOLAS Ch. XV. 

In DNV’s understanding, however, in such cases it should not be necessary to carry both a non-mandatory Certificate of Safety for Special Purpose Ships in addition to the mandatory IP Safety Certificate. Communication with the relevant flag administration is, however, recommended in the implementation phase of the new code. 

It may be noted that the IMO has agreed to consider if guidance to clarify the interaction between the non-mandatory SPS Code and the mandatory IP Code is necessary.

The decisive factor will be whether more than 12 persons are either carried on board solely for the transport and/or accommodation in order to be transferred over to another installation or vessel where they will work, or also if only one IP is carried and the total sum of IP, SPS and passengers is more than 12. Then the IP Code will come into force and a SPS certificate will not be sufficient. In this instance the stricter requirements of the IP Code come into play.

The new IP Code is based on the 2008 SPS Code. For existing ships already carrying more than 12 industrial personnel, flag administrations may permit the continued carriage of industrial personnel in accordance with other standards meeting an equivalent level of safety acceptable to the administration, as per Resolution MSC.418(97). In other words, a decision from the flag administration is needed on a case- by-case basis or as a general policy decision.

All ships carrying more than 12 industrial personnel on international voyages would be required to carry an IP Code certificate. Voluntary application of the new SOLAS Chapter XV in domestic waters is encouraged, but it is the prerogative of the respective administration. In other words, if the wind turbine installation vessel operates on international voyages and is carrying more than a total of 12 industrial personnel, special personnel and passengers (and is above 500 GT), it will be required to carry an IP Code certificate.

The IP Code is intended as an enabler for the carriage of industrial personnel. It does not come with an obligation to carry industrial personnel. The IP Code could as such provide flexibility for ships looking at carrying both special and industrial personnel. In other words, it could be used to allow the carriage of SPS personnel (without any IP). Acceptance from the flag administration will be necessary.

Wherever in the new SOLAS Chapter XV, or in the IP Code, the number of industrial personnel appears as a parameter, it shall be the aggregate number of industrial personnel, special personnel and passengers carried on board, where the number of passengers shall not exceed 12.