IMO update: Sub-Committee on Implementation of IMO Instruments (III 7)

The 7th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 7) was held remotely from 12 to 16 July 2021. III 7 revised the procedures for port state control and survey guidelines under the harmonized system of survey and certification (HSSC). III 7 further discussed lessons learned and safety issues identified from the analysis of marine safety investigation reports and proposed to look further into accidents involving elevators.

IMO Update: Sub-Committee on implementation of IMO instruments (III 7)

Relevant for ship owners and managers, port state control and flag states.

Meeting highlights

  • Revision of the Procedures for port state control (Resolution A.1138(31)) on the control of operational requirements
  • Revision of the survey guidelines under the harmonized system of survey and certification (HSSC)


The 7th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 7), held remotely from 12 to 16 July 2021, was chaired by Claudia Grant from Jamaica.

The following is a summary of the items discussed during that session assumed to be significant and of interest to the shipping industry. As III 7 is a Sub-Committee, all decisions concerning rules, regulations and dates are subject to further consideration and approval by the Maritime Safety Committee (MSC), Marine Environment Protection Committee (MEPC) or by the Assembly.

Consideration and analysis of reports on alleged inadequacy of port reception facilities (PRF)

Compliance with MARPOL discharge requirements depends largely on the availability of adequate port reception facilities (PRFs). IMO is to be notified by the flag state of the vessel in cases where the PRFs are alleged to be inadequate, and the port state is expected to respond. Statistics for the years 2018, 2019 and 2020 were presented. There has been a decline of the number of reports from 2019 to 2020. At the same time, the response rate from port states has also declined. It should be noted that in some of the reported cases, adequate port reception facilities were actually available, and the problem was experienced due to miscommunication and untimely (too late) requests from the vessel.

Lessons learned and safety issues identified from the analysis of marine safety investigation reports

Learning from accidents to avoid similar events in the future is important. Lessons learned from several accidents were reviewed and released for publishing on the IMO’s website, where they will be available for interested parties.

As there have been several serious accidents involving elevators, a proposal will be forwarded to MSC on establishing a new output to address the design, installation, maintenance, inspection and operation of elevators.

The correspondence group on “Analysis of Marine Safety Investigation Reports” was re-established and will continue its work. Among the tasks which will be addressed are: analysis of accident investigation reports, review of lessons learned, further analysis on man overboard from fishing vessels, pilot ladder-related issues including associated boarding arrangements, occupational accidents, collisions with fishing vessels, and further analysis of the ISM-related concern on the implementation of safety management systems.

Flag state administrations are responsible for investigating casualties and submitting the report to the IMO. There are reports that have not yet been submitted for accidents which happened many years ago. A proposal to introduce a time limit of one year in the Causality Code for submitting the report to the IMO was not agreed. However, it was proposed to provide a status on ongoing investigations when the investigation is not completed within this time frame.

Measures to harmonize port state control (PSC) activities and procedures worldwide

Amendments to the 2019 Procedures for port state control (Resolution A.1138(31)), mainly on the control of operational requirements, were finalized. This will be sent to MSC and MEPC for approval, and for adoption at Assembly 32 in December 2021.

The new PSC guidelines also include endorsement of the cargo electronic 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.

The correspondence group was re-established and will discuss, among other items, suspension of PSC inspection, Statements of Compliance related to Fuel Oil Consumption Reporting under MARPOL Annex VI in cases of change of flag and company, and inclusion of information regarding financial security required under the Maritime Labour Convention (MLC), 2006 in the PSC inspection report.

Updated survey guidelines under the harmonized system of survey and certification (HSSC)

The survey guidelines under HSSC were updated and will be submitted to the relevant committees for approval and for adoption at Assembly 32 in December 2021.

The revised guidelines include requirements 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 system
  • Harmonization of survey periods of cargo ships not subject to the ESP Code
  • Check of two-way VHF using expired primary batteries
  • Electronic record books under MARPOL
  • Helicopter facility foam firefighting appliances

The “List of certificates and documents to carried on board ships” and the “Non-exhaustive List of Obligations under instruments relevant to the IMO Instruments Implementation Code” were also updated according to the newest requirements.

A correspondence group was established and will continue its intersessional work.

IMO Member State Audit Scheme (IMSAS)

The Sub-Committee reviewed consolidated audit summary reports regarding audits of member states related to implementation of IMO instruments. The most frequent root causes contributing to lack of effective implementation were related to lack of national provisions; lack of policies; lack of awareness, understanding or interpretation of the requirements; lack of established written procedures; lack of management system; insufficient human and financial resources; lack of technical capability (trained personnel, hardware/equipment); and insufficient capacity to promulgate national legislation and keep it updated. It was noted that MSC 103 and MEPC 76 have approved a new output on the “development of guidance in relation to IMSAS to assist in the implementation of the III Code by Member States”.


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