IMO Update: sub-committee on implementation of IMO instruments - III 8
The 8th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 8) was held remotely from 25 to 29 July 2022. III 8 agreed on the way forward for the development of guidance on the application of remote surveys, audits and verifications. Lessons learned from accidents point to safety concerns related to fall from heights, pilot ladders and fishing vessels.
Relevant for shipowners and managers, port state control and flag states.
Meeting highlights
- Framework for the development of guidance on the application of remote surveys, audits and verifications
- Lessons learned from accidents point to safety concerns related to fall from heights, pilot ladders and fishing vessels
- Port state control and harmonized survey guidelines updated according to the latest requirements
Remote surveys, ISM Code audits and ISPS Code verifications
III 8 agreed on a framework for the development of guidance on the application of remote surveys, audits and verifications:- Part 1: amendments to Survey Guidelines under the Harmonized System of Survey and Certification (HSSC)
- Part 2: amendments to the Revised Guidelines on the implementation of the International Safety Management (ISM) Code by Administrations
- Part 3: development of guidance on assessments and applications of remote surveys, ISM Code audits and International Ship and Port Facility Security (ISPS) Code verifications
Consideration and analysis of reports on alleged inadequacy of port reception facilities (PRF)
III 8 considered difficulties encountered related to port reception facilities (PRF) for exhaust gas cleaning system (EGCS) residues. However, recently MEPC adopted Resolution MEPC.340(77) on “2021 Guidelines for Exhaust Gas Cleaning Systems”, also including a section on EGCS residues; MEPC.1 Circ.900 on “2022 Guidance regarding the delivery of EGCS residues to port reception facilities”; and MEPC.1/Circ.899 on “2022 Guidelines for risk and impact assessments of the discharge water from exhaust gas cleaning systems”. As some of the difficulties reported may have been solved, III 8 encouraged member states and international organizations to submit their best management practices and experienced gained as well as difficulties encountered in implementing this guidance to future sessions.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. III 8 reviewed lessons learned from several accidents, which will be released for publishing on the IMO’s website where they will be available for interested parties. Noting that not all accident investigation reports were of the desired quality, III 8 agreed to a III.3 circular with the aim to improve future accident investigation reports.
Fall from heights was considered as a safety concern, and the development of guidelines for working at height will be proposed as a work output for the IMO. In particular, flag states were encouraged to give attention during external ISM audits to the:
- non-implementation of safety management system procedures for working from height and over the side, and pre-task hazard assessments;
- ineffectiveness of pre-task risk assessments and safety meetings;
- non-use of personal protective equipment (PPE);
- ineffective supervision of seafarers exposed to risk of falls from height; and
- ineffectiveness of on-board training regarding the use of PPE intended to reduce risk of falling from height or over the side.
Issues related to pilot ladder safety were reviewed and referred to MSC 106 for further consideration.
Safety issues related to fishing vessels were discussed, such as fall overboard and collisions. Unsatisfactory implementation of the ISM Code is considered a potential safety issue. These issues will be further considered in a correspondence group reporting to III 9 in 2023.
Measures to harmonize port state control (PSC) activities and procedures
Draft amendments to the “2021 Procedures for Port State Control (Resolution A.1155(32))” were considered by III 8. Due to time constraints, the update of these procedures was not completed and a correspondence group reporting to III 9 in 2023 was established to continue the development. The updated procedures for PSC are expected to be finalized during III 9 and to be submitted for adoption at Assembly 33 in December 2023.
The current draft revision includes the following:
- PSC inspection reports should include information on the financial security certificate required by the 2014 amendments of Maritime Labour Convention, MLC
- Notification to the Administration and Recognized Organisation (RO) in case of detention or suspension of PSC inspection
- Guidelines for detention of ships under MARPOL Annex VI, for example but not limited to:
- Absence of valid International Energy Efficiency Certificate, the Energy Efficiency Design Index (EEDI) Technical File or the Ship Energy Efficiency Management Plan (SEEMP)
- Absence of valid required Statement(s) of Compliance – Fuel Oil Consumption Reporting covering the year 2019 and onwards from 1 June of each following year
- Absence of records confirming that sulphur contents of fuels on board are within limits required by the applicable regulation
- In case of applying equivalent means of SOx compliance: absence of appropriate approval of equivalency and/or equivalent systems installed fail to comply with the requirements of Regulations 14 and 14.4.
It was discussed whether failure to implement the correction action plan, which is a part of the short-term carbon intensity reduction measures for ships rated as D for three consecutive years, or rated as E, should be considered as a detainable deficiency. III 8 agreed that at this stage, there was not sufficient support to regard this as a detainable deficiency and referred the topic back to MEPC 79 for further clarification.
III 8 considered amendments of the terms “re-inspection” and “follow-up inspection” to ensure the follow-up of deficiencies by PSC. This issue will be discussed further in the correspondence group.
The review of “Guidelines for port State control under the BWM Convention (MEPC.252(67))”, the interim “Guidance on control and compliance measures to enhance maritime security (Resolution MSC.159(78))” and the “2022 Guidelines for inspection of anti-fouling systems on ships (resolution MEPC.357(78))” will be carried out by the correspondence group.
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 33 in December 2023. The revised guidelines include requirements related to regulations entering into force before 31 December 2023.
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.
III 8 discussed the format of dates on certificates. There was support for a standardized approach, but agreement could not be reached on what the standard should be. In conclusion, proposals may be submitted for a new output.
A correspondence group was established to continue reviewing the HSSC guidelines.
Recommendations
DNV recommend that customers note the lessons learned from accident investigation reports.
As III 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.
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