IMO Maritime Safety Committee (MSC 104)

The 104th session of the IMO’s Maritime Safety Committee (MSC) was held remotely from 4 to 8 October. The requirements for watertight doors on cargo ships were harmonized, and the Japanese Quasi-Zenith Satellite System was recognized for the provision of position, navigation, and timing services. The MSC also initiated the development of a goal-based instrument for autonomous ships, and the development of guidance for remote surveys and audits.

IMO Maritime Safety Committee

Relevant for shipowners, managers, designers, manufacturers, and flag states.

Meeting highlights

  • Adoption of amendments to harmonize the requirements for watertight doors on cargo ships across several IMO instruments
  • Recognition of the Japanese Quasi-Zenith Satellite System (QZSS)
  • Approval of draft SOLAS amendments to modernize the requirements for the Global Maritime Distress and Safety System
  • Approval of a draft Assembly resolution on comprehensive action to address seafarers’ challenges during the COVID-19 pandemic

Adoption of amendments to mandatory instruments

Watertight doors on cargo ships
MSC 104 adopted amendments to the 1988 Load Lines Protocol and the IGC Code to harmonize the consideration of watertight doors in damage stability calculations with those in SOLAS. The amendments will not have any impact on existing ships.

Similar harmonization amendments to MARPOL Annex I and the IBC Code are subject to approval by MEPC 77 (November 2021).

The amendments will enter into force on 1 January 2024.

Minor correction to the 1988 Load Lines Protocol
MSC 104 adopted an amendment to Regulation 22 to correct an erroneous reference to “inlets” in a table showing acceptable arrangements for scuppers and discharges.

The amendment will enter into force on 1 January 2024.

Ad hoc mid-term amendment cycle
Since 1 January 2020, amendments to SOLAS and related mandatory instruments have followed a four-year cycle of entry into force. All amendments for the 2024 update must be adopted before 1 July 2022.

MSC 104 recognized that the COVID-19 pandemic has caused delays in some ongoing work and agreed to introduce an ad hoc mid-term amendments cycle with an entry-into-force date of 1 January 2026 for amendments adopted before 1 July 2024.

Domestic ferry safety

The global number of accidents and casualties related to domestic ferries has remained high for decades. While domestic operations are outside the scope of the IMO’s responsibilities, MSC 104 approved non-mandatory model regulations on domestic ferry safety.

A draft MSC resolution on the adoption of the model regulations will be considered by MSC 105 (April 2022).

Goal-based new ship construction standards (GBS)

Goal-based new ship construction standards (GBS) for bulk carriers and oil tankers are conceptually IMO’s rules for class rules. Under the GBS standards, IMO auditors use guidelines to verify construction rules for bulk carriers and oil tankers of class societies acting as Recognized Organizations.

GBS verification audits
MSC 104 agreed that the ship construction rules for bulk carriers and oil tankers of DNV and other IACS members continue to conform to the GBS standards. DNV has been out of the audit cycle with the 11 other IACS members due to the merger between DNV and GL in 2013.

MSC 104 also took note of DNV’s name change from 1 March 2021.

Measures to enhance maritime security

Cyber guidelines for ports and port facilities
MSC 104 agreed to reference the first edition of the industry developed “IAPH cybersecurity guidelines for ports and port facilities”, in the next version of the guidelines on maritime cyber risk management (MSC-FAL.1/Circ.3/Rev.1), subject to concurrent agreement by the FAL committee.

Human element, training and watchkeeping

COVID-19 training and certification matters
The COVID-19 pandemic has created problems regarding the renewal of documents, such as certificates of proficiency and health certificates, and many seafarers are having difficulties maintaining their certificates because the necessary courses are not available.

MSC 104 approved a draft “Guidance on Seafarers’ training and certification for issuing Administrations, flag States and port States during the COVID-19 pandemic”, containing the common measures adopted by administrations during the pandemic.

MSC 104 further agreed to develop a new module in the IMO’s online information database GISIS to make information about the various measures available to all stakeholders.

Navigation, communications, search and rescue

The Quasi-Zenith Satellite System (QZSS)
All ships shall carry a receiver for a global navigation satellite system (GNSS) or a terrestrial radio navigation system. This requirement relies on the recognition of systems provided and operated by governments or organizations, for example GPS (USA), Galileo (EU), GLONASS (Russia), BeiDou (China) and IRNSS (India).

MSC 104 approved a safety of navigation (SN) circular recognizing the Japanese Quasi-Zenith Satellite System (QZSS) as a component of the World-Wide Radio Navigation System (WWRNS). Performance standards for receivers for the QZSS were approved by MSC 102.

Modernization of the Global Maritime Distress and Safety System
The Global Maritime Distress and Safety System (GMDSS), adopted in 1988, has been subject to review and modernization with the aim to adapt to modern communication systems and remove carriage requirements for obsolete systems.

MSC 104 approved draft SOLAS amendments to modernize the GMDSS requirements, as well as consequential draft amendments to the High-Speed Craft (HSC), Special Purpose Ships (SPS) and Mobile Offshore Drilling Units (MODU) Codes.

The modernization implies inter alia more generic requirements, independent of specific service providers, and amended equipment requirements for sea areas A1 to A4. The provisions for communication equipment have been moved from SOLAS Chapter III on life-saving appliances to Chapter IV on radio communications, and references to outdated resolutions and circulars will be replaced.

The draft amendments are expected to enter into force on 1 January 2024, subject to adoption by MSC 105 (April 2022).

Performance standards for Voyage Data Recorders (VDR)
MSC 104 approved consequential amendments to the performance standards for simplified VDRs and VDRs, following the adoption of the performance standards for float-free emergency position-indicating radio beacons (EPIRBs) operating on 406 MHz (Resolution MSC.471(101)) in 2019.

Iridium SafetyCast service manual
MSC 104 approved a revision of the Iridium SafetyCast service manual (MSC.1/Circ.1613). The revised manual will become effective on 1 January 2022.

Implementation of IMO instruments

Port state control (PSC) procedures
MSC 104 approved draft procedures for port state control, 2021, intended to revoke the 2019 procedures (Resolution A.1138(31)). The procedures are subject to subsequent approval by MEPC and for adoption by Assembly 32 in December 2021.

The amendments are mainly related to Appendix 7 of the guidelines for control of operational requirements. Also, Appendix 4 includes guidelines on the endorsement of the electronic cargo record book for MARPOL Annex II, by using a stand-alone form or a copy of the surveyor’s report to accompany the electronic record book entry.

Updated HSSC Survey Guidelines
MSC 104 approved the draft Survey Guidelines under the Harmonized System of Survey Certification (HSSC), 2021, to revoke resolution A.1140(31). The revised guidelines include provisions related to:

  • Operational readiness, maintenance and inspections for lifeboats and rescue boats, launching appliances and release gear
  • Means of escape for passenger ships and helicopter facilities
  • System commission testing of ballast water management systems
  • Harmonization of survey periods of cargo ships not subject to the ESP Code
  • Check of two-way VHFs using expired primary batteries
  • Electronic record books under MARPOL
  • Helicopter facility foam firefighting appliances

The updated Survey Guidelines will be submitted to MEPC 77 (November 2021) for concurrent approval and to Assembly 32 (December 2021) for adoption.

RO model agreement
MSC 104 approved amendments to the model agreement for the authorization of Recognized Organizations (ROs). The reporting obligations in Paragraph 6.5.5 have been aligned with the RO Code with respect to the scope of the statutory certification and services.

Work programme

Maritime Safety Committee (MSC)
Maritime Autonomous Surface Ships (MASS)
MSC 104 agreed to develop a new goal-based instrument for maritime autonomous surface ships (MASS). It was also agreed that the ultimate goal would be the preparation of a mandatory instrument to address MASS operations in the IMO regulatory framework. The work will be initiated by the development of a roadmap at MSC 105 (April 2022).

Sub-committee on Implementation of IMO Instruments (III)
Remote surveys, ISM Code audit and ISPS Code verifications
MSC 104 agreed to develop guidance on assessments and applications of remote survey, ISM Code audit and ISPS Code verification.

Any other business

COVID-19-related matters
MSC 104 noted that the return to normal crew change regimes may take a long time. In 2021, the number of seafarers requiring repatriation after finishing their contracts decreased to around 200,000 (April), with a similar number waiting to join ships as part of crew change, but this number is now again increasing due to the impact of new COVID-19 variants.

MSC 104 approved a draft Assembly resolution on “Comprehensive action to address seafarers’ challenges during the COVID-19 pandemic”, subject to adoption by Assembly 32 in December 2021.

The draft Assembly resolution consolidates issues related to crew changes, access to medical care, “key worker” designations, and vaccinations, as highlighted by the following MSC instruments:

  • Resolution MSC.473(ES.2) on “Recommended action to facilitate ship crew change, access to medical care and seafarer travel during the COVID-19 pandemic”
  • MSC.1/Circ.1636/Rev.1 on “Industry recommended framework of protocols for ensuring safe ship crew changes and travel during the coronavirus (COVID-19) pandemic”
  • MSC.490(103) on “Recommended action to prioritize COVID-19 vaccination of seafarers”


Many proposals for new work items were not considered due to time constraints during the remote meeting. DNV recommends that our customers monitor the outcome of future MSC sessions for information on new regulatory initiatives.

Our customers may take note that MSC 105 (April 2022) will be the last session that adopts amendments to the 2024 update of SOLAS and related mandatory codes.


Annex I: Provisional list of resolutions and circulars (see on page 4 in PDF version of this statutory news)


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