Future & New IMO Amendments

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IMO future and new amendments

Adopted IMO and ILO requirements coming into force in the future

This part includes requirements that have been adopted and have an entry into force date which has been established by the IMO or ILO but not yet reached.

1 January 2020

Amendments to SOLAS II-1/1 and II-1/8-1.3 requiring the provision of computerised stability support for the master in case of flooding

Background: Amendments to SOLAS chapter II-1 to require the provision on existing passenger ships of a computer able to carry out damage stability calculations are considered to be necessary.

Summary: The application regulations of SOLAS chapter II-1/1 make it clear which regulations are applicable to “new” and “existing” ships. Regulation II-1/8-1 has been amended to include a requirement for existing passenger ships to have either onboard or onshore the capability to assess stability after damage. New passenger ships (keels laid on or after 1 January 2014) are already required to provide this.

Implication: Existing passenger ships will have to provide suitable stability support. Obtaining the data needed for developing the hull model could be challenging and owners are recommended to start considering what is needed at the earliest opportunity.

Application: Passenger ships constructed before 1 January 2014 of 120 m or more in length or with three or more main fire zones from the first renewal survey after 1 January 2025.

Amendments to SOLAS regulation II-1/3-12 – Application of the Code on Noise Levels on Board Ships

Background: It was noticed that there was a discrepancy in the application of the Code on Noise Levels on Board Ships. i.e. ships for which the building contract is placed before 1 July 2014, the keels of which are laid or which are at a similar stage of construction on or after 1 January 2015 and the delivery of which is before 1 July 2018, do not fall either under paragraph 1 or under paragraph 2 of SOLAS regulation II-1/3-12.

Summary: The necessary amendment has been made through a minor modification, deleting the words “but before 1 January 2015” in paragraph 2.1 of regulation II-1/3-12.

Implication: This is a minor amendment which clarifies the application of the Code on Noise Levels on Board Ships.

Application: The SOLAS amendments will enter into force on 1 January 2020. As an interim measure MSC.1/Circ.1547 applies. This circular will be revoked once the amendments enter into force.

Amendments to SOLAS Chapter II-1 on damage stability

Background: Amendments to SOLAS Chapter II-1 to harmonize cargo ship and passenger ship damage stability have been in force since 1 January 2009. These amendments made probabilistic damage stability the main method for calculating damage stability for passenger ships and general cargo ships. Since the amendments have entered into force the need for a number of revisions has become apparent. A major review of the subdivision and damage stability requirements contained in Chapter II-1 of SOLAS has been undertaken.

Summary: Significant changes have been made to the following regulations in parts A, B, B-1, B-2, B-4 and C:

  • Regulation 4, making the alternative compliance part of the text rather than a footnote.
  • Regulation 5-1, requiring limiting stability information to include trim.
  • Regulation 6, modifying the required subdivision index, R, for passenger ships.
  • Regulation 7-2, amending the calculation for s.
  • Regulation 9, providing limits on the distance from the keel line which small wells should be unless a damage stability check is made and introducing a minimum limit for the vertical damage extent.
  • Regulation 12, permitting a butterfly valve at the collision bulkhead on cargo ships.
  • Regulation 16, to require testing of watertight hatches.
  • Regulation 17, requiring air pipes which terminate in a superstructure to be considered unprotected openings unless fitted with a watertight means of closure.
  • Regulation 22, removing the possibility of leaving watertight doors open.

Ship Designers: These are significant changes to the damage stability regulations that should be taken into consideration at an early stage.

Application: The amendments will be applicable for ships where the contract for construction is signed on or after 1 January 2020, or the keel is laid on or after 1 July 2020 or delivered on or after 1 January 2024.

Amendments to SOLAS II-1/19, III/30 and III/37 concerning damage control drills on passenger ships

Background: The IMO agreed that damage control drills would help improve the safety of passenger ships and that appropriate amendments to SOLAS should be developed together with associated guidance.

Summary: Amendments to SOLAS chapter II-1 regulation 19 and chapter III regulations 30 and 37 to mandate damage control drills were adopted. The requirements are operational in nature with drills required at regular intervals for all passenger ships. The drills will have to involve crew members who have damage control responsibilities. Additionally, drills will have to be recorded and should cover different damage scenarios.

Implication: Additional drills will need to be included in the ships’ normal operations.

Application: Applicable to all passenger ships.

Amendments to SOLAS regulation II-2/3.56 – Definition of a vehicle carrier

Background: It had been highlighted that the definition of vehicle carrier in SOLAS regulation II-2/3.56, as amended by resolution MSC.365(93), was unclear when considering the application of SOLAS regulation II-2/20-1.

Summary: It was agreed that only “pure car and truck carriers” should comply with SOLAS regulation II-2/20-1 and, therefore, the definition provided in SOLAS regulation II-2/3.56 was amended accordingly.

Implication: Revision of the definition in SOLAS regulation II-2/3.56 clarifies that the requirements in SOLAS regulation II-2/20-1, are intended for cargo ships which only carry cargo in ro-ro spaces or vehicle spaces, and which are designed for the carriage of unoccupied motor vehicles without cargo, as cargo.

Application: The amendment will enter into force on 1 January 2020 and will clarify the application of safety requirements in SOLAS II-2/20-1 to vehicle carriers as per the revised definition for SOLAS regulation II-2/3.56.

Amendments to SOLAS regulation II-2/ – Clarifying the requirements for the fire integrity of windows on passenger ships

Background: A possible error in SOLAS regulation II-2/ was identified. The regulation applied to all passenger ships, but referred to table 9.1 of SOLAS regulation II-2/9 which was only applicable to passenger ships carrying more than 36 passengers.

Summary: Amendments to SOLAS regulation II-2/ were drafted to clarify the requirements for the fire integrity of windows on passenger ships carrying not more than 36 passengers and more than 36 passengers respectively.

Implication: The amendments, through the additions of paragraph to under regulation II-2/ ensure a fire integrity at least equal to “A-0” class for passenger ships.

Application: The amendments will enter into force on 1 January 2020 and will be applicable to new passenger ships, or when existing windows are replaced on existing ships.

Amendments to SOLAS Chapter II-2/10.5 for the fire protection of domestic boilers

Background: A proposal was considered to amend the existing SOLAS regulation II-2/ regarding the arrangement of 135 litre foam-type extinguishers in boiler rooms.

Summary: The text of regulation II-2/ has been amended. Prior to the amendment domestic boilers of less than 175kW were not required to carry an approved 135l foam-type fire extinguisher. The 135l foam extinguishers are now not required for boilers that are protected by a fixed local water-based firefighting system.

Implication: Ships fitted with boilers that are protected by a water-based local application fire-extinguishing system, are no longer required to provide the approved foam-type extinguisher of 135l capacity.

Application: The amendments will enter into force on 1 January 2020 and will apply to new and existing ships. It should be noted that the Application requirements for existing ships in Chapter II-2 applies to ships constructed on or after 1 July 2012, however these amendments also apply to ships constructed before 1 July 2012.

Amendments to SOLAS II-2/13 to make evacuation analysis mandatory

Background: As technology has advanced it is now relatively simple to analyse the way a passenger ship can be evacuated. These amendments to SOLAS will make evacuation analysis early in the design process mandatory.

Summary: Existing paragraph II-2/13.7.4 is deleted. New paragraphs II-2/ and II-2/ have been introduced which require escape routes to be evaluated to demonstrate that the ship can be evacuated in the required time. The evacuation simulation will be used to identify and eliminate congestion which may develop during abandonment and demonstrate that escape arrangements are sufficiently flexible to provide for the possibility that certain routes/areas may not be available as a result of a casualty.

Implication: An evacuation analysis will be required for applicable ships. It should be noted that ro-ro passenger ships already have to undertake such an analysis under the requirements of SOLAS II-2/13.7.4.

Application: All passenger ships constructed on or after 1 January 2020 which carry more than 36 passengers. The existing mandatory requirement for conducting evacuation analysis on ro-ro passenger ships will continue to be applicable.

Amendments to SOLAS Regulation II-2/18.5 concerning helicopter landing areas on new ships and the FSS Code Chapter 17 – Helicopter Facility Foam Firefighting Appliances

Background: It was proposed that the relevant IMO instruments for helicopters be brought into line with the provisions of other UN agencies. As a result of this proposal, new requirements for the provision of foam application systems for helicopter landing areas were agreed. It was also agreed that the guidelines in the annex to MSC.1/Circ.1431 should be redrafted as a new chapter to the International Code for Fire Safety Systems (FSS Code).

Summary: Amendments to SOLAS II-2/18 add a new paragraph 2.3 to require a foam application system that complies with the new chapter 17 of the FSS Code. The new Chapter 17 of the FSS Code details the specifications for foam firefighting appliances for the protection of helidecks and helicopter landing areas as required by chapter II-2 of SOLAS.

Manufacturers / Designers / Shipbuilders / Shipowners should be aware of the new FSS Code specifications for foam firefighting appliances for the protection of helicopter facilities, as required by Chapter II-2 of SOLAS.

Application: The new chapter 17 and consequential SOLAS amendments enter into force 1 January 2020. It should however be noted that MSC.1/Circ.1523 allows Flag Administrations to implement the requirements earlier at their discretion. The requirements are applicable to new ships having a helicopter landing area, i.e. an area on a ship designated for occasional or emergency landing and not designed for routine helicopter operations.

Amendments to SOLAS II-2/20 and II-2/20-1 concerning fire protection for spaces in which vehicles are carried

Background: There is confusion in the industry regarding the fire protection requirements which are applicable to cargo spaces which contain vehicles. There are occasions when “ordinary” cargo spaces, i.e. those which are not special category, ro-ro or vehicle spaces as defined by SOLAS II-2/3, will carry vehicles as cargo. Ordinary cargo spaces have fire protection which meets the requirements of SOLAS II-2/19, and when vehicles are carried in them they should also comply with the Dangerous Goods Code and the associated Special Provisions.

Summary: SOLAS II-2/20 will be amended to include a statement to clarify that when vehicles are carried in spaces which do not need to meet the requirement of the regulation, then they can be carried in spaces which meet the requirements of SOLAS II-2/19 as long as they are carried in accordance with the IMDG Code.

Implication: This amendment will clarify the existing situation to make clear the relationship between SOLAS and the IMDG Code.

Application: Applicable to all ships (new and existing) with an entry into force date of 1 January 2020.

Amendments to SOLAS Regulations III/3 and III/20 on Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear

Background: Lifeboats and their fittings require maintaining and servicing to ensure their fitness to function in an emergency. This is done by service providers who can either be associated with a specific manufacturer or can be independent. Previously the requirements for the recognition of such service suppliers were given in non-mandatory instruments, (i.e., MSC.1/Circ.1206/Rev.1 (and MSC.1/Circ.1277))

Summary: The SOLAS amendments and associated MSC Resolution (MSC.402(96)) include explicit mandatory text clarifying the requirements for the qualification, authorisation and certification of service suppliers, procedures for maintenance and testing, and what should be carried out at each stage of testing (weekly, monthly, annually, and 5-yearly).

Shipowners and Ship Managers: This should have little effect for Lloyd’s Register shipowners/ship managers as we already apply these requirements.

It was agreed that the ship’s crew could not carry out the 5 year overhaul and tests and that a service provider could be an entity owned by the company owning the ship.

Manufacturers will need to find out how their flag Administration intends to authorise them as service suppliers and make appropriate arrangements for authorisation as necessary although they will not need any accreditation or certification when performing servicing, maintenance or testing on their own manufactured equipment. LR already imposes this standard through the LR ‘Procedures for the Approval of Service Suppliers’, so this should not have a significant impact to LR’s clients.

Flag Administrations and their ROs will need to authorise their lifeboat service suppliers. A list of approved service suppliers will have to be provided to the IMO.

Application: Applicable to SOLAS ships and service suppliers maintaining their lifeboats, rescue boats, launching appliances and release gear. Entry into force is 1 January 2020.

Amendments to SOLAS Chapter IV and Appendix to accommodate additional mobile satellite systems providers recognised for use in the GMDSS

Background: These amendments to SOLAS chapter IV and other related IMO instruments accommodate new mobile satellite systems recognised for use in the GMDSS.

Summary: The amendments are necessary because SOLAS chapter IV currently recognises only Inmarsat as a GMDSS satellite service provider. As other systems are now recognised as GMDSS satellite service providers, it is necessary to replace references to Inmarsat with a generic term.

Implication: It should be noted that MSC 99 also adopted consequential amendments to the HSC Code (1994 & 2000); the SPS Code and Certificates: Forms P, R and C.

Application: The changes enter into force on 1 January 2020 and are applicable to all ships which are subject to the requirements of the GMDSS.

Amendments to SOLAS forms E, C and P to include multi-system shipborne radionavigation receivers

Background: Resolution MSC.401(95) amends the ‘Performance standards for multi-system shipborne radionavigation receivers’. As a consequence, the SOLAS forms E, C and P also need to be amended to include the option of multi-system shipborne radionavigation receivers.

Summary: The current version of SOLAS form E, part 3, item 3.1, and forms C and P, part 5, item 3.1, allows for the selection of a “receiver for a global navigation satellite system” or a “receiver for a terrestrial radionavigation system”, but not a multi-system receiver. This amendment adds “multi-system shipborne radionavigation receiver” to the options.

Implication: The multi-system shipborne navigation receiver performance standards allow the combined use of current and future radionavigation systems as well as the augmentation of systems for the provision of position, velocity and time (PNT) data within the maritime navigation system. This amendment to the forms takes account of this equipment.

Application: MSC.401(95) as amended applies to multi-system shipborne radionavigation receivers installed on or after 31 December 2017. The consequential amendments to Forms E, C and P will enter into force 1 Jan 2020.

Amendments to Part A of the International Code on Intact Stability, 2008 (2008 IS Code) under the 1974 SOLAS Convention and the 2008 Load Line Protocol

Background: Concern had been expressed that by including references to stability criteria in Part B of the 2008 IS Code (non-mandatory) in the main text of Part A of the 2008 IS Code (mandatory) this would in turn make them mandatory. A set of amendments has been agreed which include making some footnotes part of the main text where the content was intended to be mandatory, and moving some text into a footnote where it will be non-mandatory.

Summary: The changes are extensive covering the following:

  • The definition of freeboard deck for open hold container ships and the clarification that fishing vessels are not included in the definition of a “ship engaged in lifting operation” are moved from footnotes to the main text
  • The footnote in Part A to the title of chapter 2 is deleted.
  • The application of Part A to Offshore Supply Vessels and Special Purpose Ships is included in the main text
  • References to Part B are moved from the main text to footnotes
  • The definition of φf is included in the main text
  • The footnote concerning the angle of roll is moved to the main text
  • The reference to MSC.1/Circ.1200 is moved to a footnote

Implication: The changes are principally editorial in nature and will have no impact on ship design and construction.

Application: To ships with keel laid on or after 1 January 2020.

Amendments to the IBC, BCH, IGC, GC and EGC Codes – Certificate of Fitness

Background: It was noted that the changes to the Certificate of Fitness introduced to require a means of confirming that any specific loading condition complies with damage stability requirements (see item 255 Demonstration of compliance with damage stability requirements for tankers above) required further modification to make it clear that an approved stability manual is still required.

Summary: Amendments to the Certificate of Fitness will include a new paragraph 6 stating that the loading and stability information has been provided and a paragraph which states “that the ship must be loaded in accordance with the loading conditions provided in the approved loading and stability information booklet referred to in 6 above;” in paragraph 7.

Implication: When the Certificate of Fitness is reissued it will include the statement relating to an approved stability manual. There will be no significant impact on ships.

Application: to ships for which the IGC and IBC Codes and earlier versions are applicable.

Amendments to the FSS Code, Chapter 8 – Automatic Sprinkler, Fire Detection and Fire Alarm Systems

Background: Following a report to the IMO that detailed several automatic sprinkler system failures on passenger ships it was agreed that MSC.1/Circ.1432 would be amended and a related amendment to Chapter 8 of the International Code for Fire Safety Systems (FSS Code) would also be required.

Summary: The Circular MSC.1/Circ.1432 (as amended by MSC.1/Circ.1516) includes a new provision for water quality testing for automatic sprinkler systems and new flow charts for the testing and replacement of sprinkler heads and water mist nozzles. The related amendment to Chapter 8 of the FSS Code adds requirements for taking precautions against freezing where sprinkler systems are subjected to freezing temperatures and special attention to be paid to the specification of water quality (in line with the system manufacturers’ recommendations) to prevent internal corrosion and clogging of the sprinklers.

Manufacturers / Shipbuilders / Shipowners to note the new requirements for taking precautions against freezing where sprinkler systems are subjected to freezing temperatures and paying special attention to the water quality of the system and the inspection and maintenance regime of automatic sprinkler and water mist systems.

Application: All new ships constructed (keel laid) on or after 1 January 2020, which use sprinklers, e.g. passenger ships fitted with such systems.

Amendments to the IGC Code – Applicable fire integrity of wheelhouse windows.

Background: Inconsistencies were noted between SOLAS regulation II-2/ and the International Code for the Construction and Equipment of Ships carrying Liquefied Gases in Bulk (IGC Code) paragraph 3.2.5 (resolution MSC.370(93)) with respect to the applicable fire integrity of wheelhouse windows.

Summary: The IGC code has been revised to align with the requirements given in SOLAS regulation II-2/ The amendments remove the requirement for A-0 fire-rated wheelhouse windows.

Because discussions on this matter had been extended beyond the 1 July 2016 entry into force date of the IGC Code, as amended by MSC.370(93), it was considered urgent that an associated circular (MSC.1/Circ.1549) should be issued. The circular notifies Administrations of the corrections to the text pending formal entry into force on 1 January 2020.

Implication: In essence, this is a relaxation of the requirements without which compliance with the current requirements to provide A-0 wheelhouse windows included in MSC.370(93) might be difficult. For ships constructed on or after 1 July 2016 but before the entry into force date, it is recommended to retain a copy of MSC.1/Circ.1549 on board to avoid any potential issues that may arise at a Port State control inspection.

Application: New gas tankers that carry liquefied gas or other products listed in the IGC Code in bulk. Formal entry into force is 1 January 2020, however noting that it will be difficult to comply with the current requirements to provide A-0 wheelhouse windows included in MSC.370(93), the Flag Administrations concerned should be consulted early in the design/construction process.

Amendments to the IGF Code – Applicable fire integrity of wheelhouse windows

Background: As a consequence of amendments to paragraph 3.2.5 of the International Code of the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) (resolution. MSC.411(97) – see item 304) inconsistencies were noted with respect to the applicable fire integrity of wheelhouse windows, within the International Code for the Safety of Ships using Gases or other Low-flashpoint Fuels (IGF Code). It was agreed to align the fire integrity requirements for navigation bridge windows specified in paragraph 11.3.2 of the IGF Code with the amendment to paragraph 3.2.5 of the IGC Code, as adopted by resolution MSC.411(97) and those in SOLAS Chapter II-2.

Summary: The amendments remove the requirement for A-0 fire-rated wheelhouse windows.

Implication: In essence this is a relaxation of the requirements without which compliance with the current requirements included in MSC.391(95) might be difficult.

Application: Ships using low-flashpoint fuels. Formal entry into force is 1 January 2020, however noting that it will be difficult to comply with the current requirements to provide A-0 wheelhouse windows included in MSC.391(95), the Flag Administrations concerned should be consulted early in the design/construction process, noting that MSC.1/Circ.1568 has been published to allow for potential early implementation.

Amendment to the LSA Code and Amendments to the Revised Recommendations on testing of life-saving appliances Resolution MSC.81(70) on winches and winch brakes

Background: A discrepancy has been identified between Chapter 6 of the Life-Saving Appliances (LSA) Code and the pre-installation testing requirements for winches and winch brakes in resolution MSC.81(70) as amended.

Summary: It was agreed to modify the texts of paragraph of the LSA Code and paragraph 8.1.1 of part 1 of the annex to MSC.81(70) and to delete the word ‘brakes’ and to add ‘including winch structural components’ to paragraph of the LSA Code.

Implication: Since only winch brakes are designed to have sufficient strength and be prototype tested to withstand a static proof load of not less than 1.5 times the maximum working load, the text “except the winch” in paragraph 6.1.1 of part 2 of the annex to resolution MSC.81(70) should be read as “For lifeboats other than free-fall lifeboats, davits and launching appliances, except winches, should be subjected to a static proof load of 2.2 times their maximum working load.” While manufacturers and surveyors need to be aware of the correction this should have a limited impact on the prototype testing of LSA equipment.

Application: Pre-installation testing of equipment fitted on new ships and new equipment installed on existing ships after 1 January 2020.

Amendments to the 2008 Intact Stability Code related to anchor handling, towing or lifting operations

Background: New intact stability criteria to cover anchor handling, towing and lifting operations have been developed following the loss of the “Bourbon Dolphin”. As not all ships undertake these duties the criteria have been included in the non-mandatory part of the 2008 Intact Stability (IS) Code (Part B). The Introduction and Part A of the 2008 IS Code have been amended to include new definitions and clarification about the new criteria.

Summary: The new criteria require an assessment of the ship’s intact stability when undertaking anchor handling, towing or lifting duties.
For anchor handling it will be necessary to know the following to carry out the assessment; displacement of a loading condition, vertical and horizontal angle of the tow wire and the location of the anchor point with respect to the centre of the propulsive force, the stern of the vessel and the ship centreline. It will also be necessary to know some limiting information such as the bollard pull of the vessel, the design maximum wire tension and the permissible tension (the wire tension which can be applied to the vessel as loaded whilst working through a specified tow pin set). An additional heeling moment will then be added to the intact stability GZ curve. There are limits on the area between the heeling moment curve and the GZ curve, the residual righting lever between the heeling moment curve and the GZ curve, the angle of first intercept between the two curves and a minimum freeboard.

The new criteria in Part B also require an assessment of the ship’s intact stability when undertaking towing and lifting operations. It will be necessary to know the following to carry out the assessment:

For towing: displacement of a loading condition, the bollard pull, horizontal transverse force, the distances between the towing point and the vertical centreline of the propulsion unit and between the centre of the propeller to the point at which the tow force is applied, angle of heel in the loading condition, lateral projected area of the underwater hull.

For lifting: the magnitude of the maximum load which can be lifted, the distance between the point the load is applied to the ship and the centreline of the ship, the vertical height of the load.

Additional constructional matters are included in the amendments to part B of the 2008 IS Code covering the provision of a loading instrument, access to the machinery space, location of freeing ports, winch systems and on deck markings.

The amendments to the introduction and Part A are to include new definitions for “ship engaged in anchor handling operations”, “ship engaged in harbour towing”, “ship engaged in coastal or ocean-going towing”, “ship engaged in lifting operation” and “ship engaged in escort operation” for which the new criteria will be applicable.

Implication: Where a ship is expected to carry out anchor handling, towing or lifting duties the necessary calculations should be carried out and the stability criteria satisfied. This will provide standard additional calculations to be assessed and approved where mandated by the Flag Administration. Approval would be carried out by the relevant Flag Administration or Recognised Organisation where the assessment is delegated. Additionally operational guidance for the crew will be required.

Application: Vessels engaged in anchor handling, towing or lifting duties.

Amendments to the 1994 and 2000 HSC Codes

Background: It has been agreed that clarification was needed regarding the application of the paragraphs to of the 1994 and 2000 High-Speed Craft (HSC) Codes, which concern the exemption from the requirement to carry a rescue boat for high-speed craft of less than 30m (2000 HSC Code) and 20m (1994 HSC Code).

Summary: New text to chapter 8 – Life Saving Appliances and Arrangements allows for High-speed craft of less than 30m (2000 HSC Code) and 20m (1994 HSC Code) in length to be exempted from carrying a rescue boat, provided that the requirements in the sub-paragraphs of are fulfilled and provided a person can be rescued from the water in a horizontal or near-horizontal body position (MSC.1/Circ.1185/Rev.1).

This revision of the text means the retroactive application of the requirements for HSC craft under 20m (1994 Code) and under 30m (2000 Code). HSC Code craft dating back to 1996 that have been exempted from the rescue boat requirement will need to be checked to ensure that they either have a suitable arrangement or have added equipment to demonstrate that they can rescue a helpless person from the water in a horizontal or near-horizontal body position.

Ship Designers, Shipbuilders and Shipowners should ensure that they have sufficient arrangements/equipment in place to satisfy the requirement which allows a helpless person to be recovered from the water in a horizontal or near-horizontal body position. If in doubt they should discuss the matter with their Administration.

Application: The requirement will apply to existing ships on international voyages constructed on or after 1 Jan 1996 (1994 HSC Code) and also ships with the keel laid on or after 1 July 2002 (2000 HSC Code).

Amendments to the IMDG Code (Amendment 39-18)

Background: The IMDG Code is regularly reviewed to take into account new requirements for existing substances or new substances. The previous amendment to the IMDG Code was Amendment 38-16 which entered into force on 1 January 2018.

Summary: Further to the regular updates to classification, segregation, packing and marking of dangerous goods, Amendment 39-18 includes:

  • New provisions for the transport of samples and the transport of wastes
  • New special provisions applicable to lithium batteries and vehicles powered by a fuel cell engine
  • Inclusion of new ISO standards for gas cylinders of all types
  • A new paragraph regarding the transport to or from offshore oil platforms, mobile offshore drilling units and other offshore installations
  • A new stowage code (SW30 ) for special stowage provisions is introduced

Implication: Shipowners and ship managers of ships carrying dangerous goods must be familiar with the developments on the IMDG Code, including amendments 39-18 The IMDG Code comprises operational requirements relating to packing, labelling, stowage, segregation and handling, and emergency response action, aimed at shippers and ship operators. The amendments to the Code will therefore not affect the dangerous goods certification issued by Lloyd’s Register, which is related to the requirements for ships’ safety equipment and fire protection contained in SOLAS regulation II-2/19.

Application: Owners and operators of ships intending to carry packaged dangerous goods cargoes will have to implement the new requirements from 1 January 2020 and are encouraged to consider their early implementation from 1 January 2019.

1 March 2020

Amendments to MARPOL Annex VI to prohibit the carriage of non-compliant fuel and other issues relating to MARPOL Annex VI regulation 14

Background: The use of 0.50% (or below) sulphur fuel oil outside of emission control areas (ECAs) from 1 January 2020 was introduced in the 2008 amendments to the MARPOL Convention contained in MEPC.176(58). This further amendment supplements the 2008 amendments by also prohibiting the carriage of fuel oil with a sulphur content higher than 0.50%, unless the ship is fitted with a functioning scrubber, as an approved equivalent arrangement for complying with the Annex VI requirements.

Summary: Amendments have been adopted to MARPOL Annex VI Regulation 14 to prohibit ships from carrying fuel oil with a sulphur content higher than 0.50% on board, unless the ship has an approved equivalent arrangement in place, such as an exhaust gas treatment system. Corresponding amendments were also made to the supplement to the International Air Pollution Prevention Certificate.

Implication: Shipowners & managers need to consider de-bunkering of any high sulphur fuel that has not been consumed before 1 January 2020.

Application: This carriage prohibition will enter into force on 1 March 2020 and affects all ships.

1 October 2020

Amendments to MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008 – Use of electronic record books

Background: IMO periodically reviews the administrative provisions of mandatory requirements and considers ways to make these more efficient.

Summary: Amendments to MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008 have been adopted which allow the use of electronic record books as an alternative to hard copy record books when complying with the record keeping requirements of MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008.

To be used as an alternative, the electronic recording system is required to be approved by the Administration and electronic records generated and retained by the system should be presented so that the records match the format defined in the relevant MARPOL Annexes.

Any electronic system considered to conform to the criteria for approval should be provided with a written declaration from the Administration. The declaration should be carried on board the ship for the purpose of statutory surveys or inspections.

Existing electronic recording systems for rechargeable systems containing ozone depleting substances shall only be considered an electronic record book if the system is approved by the Administration on or before the first IAPP renewal survey carried out on or after 1 October 2020, but not later than 1 October 2025.

Implication: Companies have the option to use electronic recording systems approved by the Administration to comply with the record keeping requirements of MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008. Whilst the electronic records generated and retained by the system are currently required to be presented in the form of records required by the MARPOL Annexes, this may be reviewed in the future.

Application: All ships using electronic record books to comply with the record-keeping requirements of MARPOL Annexes I, II, V and VI and the NOx Technical Code 2008.

Amendments to MARPOL Annex VI regulations 2.42 and 19.3 concerning EEDI regulations for ice-strengthened ships

Background: This amendment to Annex VI clarifies which ships are not required to meet the attained EEDI due to their disadvantageous hull shape and construction for icebreaking purposes.

Summary: Regulation 19.3 of MARPOL Annex VI has been amended to refer to ships with ice-breaking capabilities as “category A ships as defined in the Polar Code”, instead of “cargo ships having ice breaking capability”. The definition of “Polar Code” has also been included in Regulation 2 for reference.

Implication: This clarifies the exclusion clause.

Application: This applies to:

  1. Each new ship;
  2. Each new ship which has undergone a major conversion; and
  3. Each new or existing ship which has undergone a major conversion that is so extensive that the ship is regarded by the Administration as a newly constructed ship.

The requirement is for category A ships designed for operation as polar ships.

Amendments to the NOx Technical Code 2008 (Certification Requirements for SCR Systems)
MEPC Resolution on Amendments to the 2017 Guidelines Addressing Additional Aspects of the NOx Technical Code 2008 with regard to Particular Requirements Related to Marine Diesel Engines Fitted with Selective Catalytic Reduction (SCR) Systems

Background: The NOx Technical Code provides two certification schemes: scheme A, where an engine and SCR are tested together; and scheme B, where it is certified separately before installation onboard and then a final (simplified) testing is undertaken. Currently, the NOx Technical Code stipulates scheme B can be used only when the alternate scheme cannot be undertaken due to “practical and technical” reasons.

Summary: This amendment removes such restrictions and indicates scheme A and scheme B of the 2017 Guidelines Addressing Additional Aspects of the NOx Technical Code 2008 with regard to Particular Requirements Related to Marine Diesel Engines Fitted with Selective Catalytic Reduction (SCR) Systems (Resolution MEPC.291(71)), as amended, apply equally. The amendments addressed by the resolution MEPC.313(74) also require the NOx-reducing device to be included within the EIAPP certification and its presence recorded in the engine’s “Technical File”.

Implication: This will help if a main engine and SCR are manufactured in different locations and pre-certified separately, to be later installed together on board.

Application: Applicable for marine diesel engines to be installed onboard a ship constructed on or after 1 October 2020, as confirmed by Resolution MEPC.317(74).

1 January 2021

Amendments to the 2011 Enhanced Survey Programme Code for bulk carriers and oil tankers

Background: The Enhanced Survey Programme (ESP) Code is a mandatory survey requirement for oil tankers and bulk carriers as required by SOLAS Regulation XI-1/2. The Code was adopted as A.1049(27) which superseded the previous ESP programme (A.744(18)). The ESP Code is amended to reflect changes in the IACS UR Z10 series.

Summary: Extensive changes have been made to the text:

  • To ensure the text used is mandatory,
  • To update the figures,
  • To introduce consistency between the different parts of the Code, in particular including definitions and figures for edge corrosion, grooving corrosion and pitting corrosion intensity
  • To clarify requirements concerning updates to the Ship Construction File
  • To include new sections on the number and locations of thickness measurements for ships constructed to IACS CSR
  • To include new sections on the acceptance criteria for corrosion

In light of the extent of the changes made a new consolidated text has been issued incorporating all amendments made since the 2011 ESP Code was issued.

Implication: These amendments will help ensure harmonisation between the IMO and IACS requirements. There is no significant impact on LR classed vessels.

Application: Survey requirements for bulk carriers and oil tankers.

Amendments to the IMSBC Code (Amendment 05-19)

Background: The IMSBC Code is regularly reviewed to take into account new requirements for existing substances or new substances. Amendment 05-19 has been issued as a consolidated version of the IMSBC Code which is a full replacement of the existing Code.

Summary: Amendment 05-19 includes new and amended schedules which will provide specific requirements for solid bulk cargoes intended to be carried under the IMSBC Code and specifically:

On bauxite cargoes:

  • Draft new test procedure for determining the transportable moisture limit (TML) for bauxite cargoes (Modified Proctor/Fagerberg test procedure for bauxite) included in Appendix 2
  • Draft individual schedule for bauxite as a group A cargo (liable to liquefy)
  • Draft amendments to the existing individual schedule of bauxite as Group C cargo

On seed cake cargoes:

  • New draft individual schedules for seed cakes as Group C and Group B (MHB(SH)) addressing oxygen depletion issues.
  • Draft amendments to the individual schedules for seed cake UN 1386 (a), seed cake UN 1386 (b) and seed cake UN 2217
  • On metal sulphide concentrates:
  • New draft individual schedule for metal sulphide concentrates, self-heating UN 3190 as a group A and B cargo.
  • Ammonium nitrate-based fertiliser (non-hazardous) remains classified as Group C with a footnote reference to the information contained in CCC.1/Circ.4 on Carriage of Ammonium Nitrate Based Fertilizer (non-hazardous). Discussions on the hazards of ammonium nitrate-based fertiliser are continuing.

Implication: Shipowners and operators should be aware of the changes and advise their masters accordingly.

Application: All ships carrying solid bulk cargoes, other than grain, will be required to apply the amendments from 1 January 2021; administrations may apply the requirements voluntarily from 1 January 2020

Amendments to MARPOL Annex II and the associated draft amendments to Chapter 16 of the IBC Code and Chapter V of the BCH Code related to the discharge of cargo residues and tank washings of high-viscosity, solidifying and persistent floating products

Background: This is the follow up to a recent amendment which covered tank washings of high viscosity (but not harmful) oils which were washed ashore in the English Channel.

Summary: The new amendment to MARPOL Annex II requires a pre-wash for cargoes of persistent floating substances with high viscosity and includes cargoes such as vegetable oils and paraffins when the vessel is in one of the defined special areas. In this regard a new special area “North Western European Water” has been included.

Consequential amendments to the IBC Code and the BCH Code as follows:
IBC Code:

  • New paragraph 16.2.7, referring to the new prewash requirements in MARPOL Annex II;
  • The addition of 16.2.7 in column O of the entries in the revised chapter 17 corresponding to priority substances to which the new MARPOL Annex II prewash requirements should be applied as a first step; and
  • New paragraph 21.6.5, specifying the criteria that trigger the inclusion of 16.2.7 in column O of chapter 17.
  • Corresponding to a new paragraph 16.2.7 of the IBC Code.

Implication: The impact is in general limited as the pre-wash requirements apply only to the North Sea (new special area). However, it should be noted that short sea trade vessels solely operating in this area could be significantly impacted.

Application: Being an operational requirement, this applies to all new and existing ships upon entry into force. The amendment will enter into force on 1 January 2021.

1 January 2024

Amendments to the FSS Code – Chapter 15, paragraphs, and concerning inert gas flow and revision of the term ‘forward of’ to ‘downstream of’.

Background: The term ‘forward of’ is used in paragraphs, and of chapter 15 of the FSS Code which is in contradiction with MSC.1/Circ.1582 (Unified interpretations of chapter 15 of the FSS Code).

Summary: In these amendments to the FSS Code the term ‘forward of’ is amended to read ‘downstream of’ considering that normally the inert gas generator is located in the aft part of the ship; the cargo tanks are located in the forward part of the ship; and the inert gas flows from the inert gas generator to the cargo tanks.

Implication: This amendment stems from the unified interpretation and has not changed the regulation but instead it clarifies the text.

Application: This amendment will enter into force 1 January 2024 and is applicable to all ships which have inert gas systems. This clarification was originally published in MSC.1/Circ.1582/Rev.1 Unified Interpretations of Chapter 15 of the FSS Code effective from December 2018.

Amendments to LSA Code Paragraph concerning the exemption of the requirement for buoyant oars in lifeboats with two independent propulsion systems

Background: Paragraph of the LSA Code provides that, except for free-fall lifeboats, sufficient buoyant oars to make headway in calm seas should be provided. These requirements were originally intended for standard lifeboats with a single engine rather than lifeboats with two independent propulsion systems.

Summary: The amended text allows that for lifeboats equipped with two independent propulsion systems no such buoyant oars are necessary.

Implication: This amendment incorporates MSC.1/Circ.1597 into the LSA Code. It is unlikely that both propulsion systems will fail at the same time so for lifeboats with two independent propulsion systems there is now no requirement for buoyant oars.

Application: This amendment is only applicable to lifeboats with two independent propulsion systems and revokes MSC.1/Circ.1597. It will enter into force 1 January 2024.

Amendments to the LSA Code paragraph – to allow the use of hand-operated mechanisms for the launching of rescue boats

Background: Paragraph of the LSA Code requires that a launching appliance ‘shall not depend on any means other than gravity or stored mechanical power which is independent of the ship’s power supplies to launch the survival craft or rescue boat’.

IMO has considered amendments to this paragraph to allow hand-operated mechanisms for launching rescue boats. It has been suggested that the use of hand-operated mechanisms simplifies davit construction and improves the reliability substantially but concerns over potential safety hazards have also been expressed.

Summary: The amendments allow hand-operated mechanisms for launching rescue boats and includes the means of embarkation for the crew and an additional requirement for means to bring the rescue boat against the ship’s side and holding it alongside so that persons can be safely embarked.

Implication: This amendment will only be applicable to rescue boats that are not one of the ship’s survival craft. It should be noted that SOLAS Chapter III has different requirements for cargo and passenger ships in this respect.

Application: The amendment enters into force 1 January 2024 and will apply to rescue boats installed on board cargo ships on or after 1 January 2024.

Amendments to the IGF Code (Various – Definitions, probability index fv, loading limit, fuel distribution, internal combustion engines, fuel containment system, type C tanks etc.)

Background: While the original intention of revising the IGF Code was to consider the use of low-flashpoint fuels other than LNG, matters related to LNG where there are opportunities to reflect lessons learned and make necessary improvements and additions have also considered

Summary: The amendments to parts A and A-1 of the IGF Code amend:

• the definition of the probability index fv in order to align it with SOLAS;
• the conditions for allowing fuel tank loading limits higher than calculated based on the tank insulation and the probability of an external fire heating the tank contents up;
• requirements for fuel distribution outside of machinery spaces including secondary enclosures for gas fuel pipes;
• explosion relief systems and designed accommodation of overpressure for internal combustion engines; and
• fire protection requirements for the separation of fuel containment systems from other spaces, and for type C fuel storage hold spaces;

Implication: These amendments improve the application of the IGF Code by taking account of lessons learned so far. Design requirements will not be applied retrospectively to existing ships.

Application: Applicable to ships constructed or converted to use gas as fuel on or after 1 January 2024.

IMO and ILO requirements currently under development

This part currently covers legislation that is currently under discussion and has not been adopted; therefore, no fixed entry into force date has been agreed. It also covers legislation that has been adopted but has no certain entry into force date because the conditions have not been met. This section is subject to change as discussions progress.

Expected 26 December 2020

ILO Maritime Labour Convention (MLC 2006) – 2018 Amendments

Background and Summary: These amendments to the Maritime Labour Convention introduce a change that mean a Seafarer’s Employment Agreement (SEA), including payment of wages, continues to have effect while a seafarer is held captive on or off the ship as a result of piracy or armed robbery against the ship, until they are repatriated or die in captivity. This is the case regardless of whether the expiry date of the SEA has passed or if notice has been given to suspend or terminate it.

Implication: Shipowners and ship managers will need to comply from the entry into force date.

Application: All ships to which the Maritime Labour Convention applies.

Expected 1 October 2021

Draft amendments to regulation 2 and 14 and appendix VI of MARPOL Annex VI with regard to the onboard sampling points

Background: MEPC had previously concluded sampling guidelines for fuel in use (MEPC.1/Circ.864), but without specifying the actual requirements for a ship to have such a sampling point in MARPOL. The new work programme on the new additional sampling point (in addition to the sampling point for fuel that the ship is receiving,) for fuel in use was agreed at MEPC 71.

Summary: The draft amendments consist of the following parts:

  • MARPOL Annex VI regulation 2; a new definition in regulation 2 on low flashpoint fuel, for which sampling points will be exempted.
  • MARPOL Annex VI regulation 14; Requirements on sampling points. This applies to both new ships (constructed after entry into force) and existing ships (first renewal survey 12 months or later, after entry into force). Reference is made to the Guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships (Circular MEPC.1/Circ.864)
  • IAPP certificate supplement; New check boxes for indicating the presence of sampling points are to be added.

Implication: These amendments introduce requirements for “in-use” sampling points and “onboard” sampling. Whilst the former is the original work introduced in the above, the latter is for fuels delivered but not used yet. The supporting guidelines for the “onboard” sampling will be developed in future sessions.

Application: All new and existing ships.

Existing ships shall be required to comply at the first renewal survey of the IAPP certificate that will take place on or after 1 October 2022 (12 months or more from EIF date).

Draft amendments to the MARPOL Convention in relation to analysis of sulphur content

Background: In order to accommodate “fuel-in use”, a sampling analysis procedure was reviewed, and a package of amendments were made to MARPOL.

Summary: Draft new paragraphs 8 and 9 are added for ‘In-use and on board fuel oil sampling and testing’. The verification procedure part 2 is to be followed in the new Verification procedures of Appendix VI of MARPOL Annex VI. For the test results, 95% confidence will be allowed (limit X +0.59R) and the acceptable sulphur limits are extended to 0.11% and 0.53% for 0.10% and 0.50% respectively. The laboratory is to be accredited to ISO17025:2017.

Implication: Introduction of 95% confidence level is understood as a possible chance of nominal exceedance. This should be clearly understood by the authority.

Application: Sampling of fuel used on board all ships from the date of entry into force of the amendment.

Expected 3 October 2021

Draft amendment to the AFS Convention – Control of AFS containing Cybutryne

Background: Evidence of environmental risks from the use of anti-fouling paints that contain cybutryne was submitted to the IMO in February 2019. The evidence was accompanied by a proposal to establish controls on anti-fouling systems (AFS) containing cybutryne.

Summary: Amendments to annex 1 of the AFS Convention have been drafted to apply control measures to AFS containing cybutryne, plus associated amendments to the form of the International AFS Certificate. These amendments were due to be approved at MEPC 74 in June 2019. However, following concerns raised regarding the consequential effects of blasting and the availability of sealer coats the amendments were referred to PPR 7 for further consideration.

Implication: The draft amendments would mean that AFS containing cybutryne shall not be applied or reapplied to ships on or after 3 October 2021. AFS containing cybutryne shall be removed or covered with a sealer coat no later than 3 October 2026.

Shipowners and ship managers should expect to be required by Administrations to apply for a survey for the issuances of an International AFS Certificate no later than 3 October 2023. Such a survey should not affect the time available to shipowners and ship managers to comply with the new control measures in annex 1 to the AFS Convention.

Application: All AFS containing cybutryne and all ships (except fixed and floating platforms, FSUs, and FPSOs that have been constructed prior to 3 October 2021 and that have not been in dry-dock on or after 3 October 2021).

Expected 1 March 2022

Draft amendments to MARPOL Annexes I, IV and VI concerning the exemption of UNSP barges from survey and certification requirements

Background: The draft amendments to MARPOL Annexes I, IV, and VI regarding the exemption of UNSP barges from the survey and certification requirements together with an associated draft MEPC.1 Circular ‘Guidelines for the exemption of unmanned non-self-propelled (UNSP) barges from the survey and certification requirements under the MARPOL Convention’ have been finalised although not yet adopted.

Summary: The draft amendments to MARPOL Annexes I, IV and VI include individual definitions of a UNSP barge under each Annex together with the draft exemption certificates.

The exemption will be granted after an initial survey to ensure there is no source of pollution on board the barge and the exemption certificates issued for a period not exceeding 5 years.

Implication: It should be noted that a condition of the exemption certificate will be an obligation on the shipowner or operator to notify the flag Administration and port State if the UNSP barge becomes non-compliant. Any such exemption certificate will cease to be valid whenever the UNSP barge does not continue to meet the definition of a UNSP barge as contained in the three annexes regardless of whether the owner or operator informs the Administration and the port State.

Application: A UNSP barge is defined as a barge that:

  • Is not propelled by mechanical means;
  • Has neither persons or living animals on board during navigation;
  • Carries no oil ; has no fuel oil tank, lubricating oil and bilge oil residues tank and has no machinery fitted that may use oil or generate oil residues (Annex 1)
  • Is not used for holding sewage during transport or have any arrangements that could produce sewage (Annex IV)
  • Has no system, equipment and/or machinery fitted that may generate emissions (Annex VI)

Draft amendments to Regulation 21 of MARPOL Annex VI – amendments to EEDI Phase 3

Background: MEPC 74 approved changes to the time period and the reduction rates for EEDI phase 3 requirements for certain ship types as shown in the table below.

Summary: Table 1 of Regulation 21 will be amended to reflect these changes. In relation to an identified problem facing larger bulk carriers in implementing the future EEDI requirements, Table 2 of Regulation 21 is also amended for bulk carriers to show that the parameter b is the same for ships with DWT less than, equal to or more than 279,000.

Shipbuilders and Designers: Potential change to ship/machinery design to reduce GHG emissions, now shall happen at a different date than indicated previously in the Table 1 of Regulation 21 MARPOL Annex VI for some vessel types. This requires planning within the design process as some reduction dates are moving earlier to 1 Jan 2022, as indicated in the red highlighted sections of the copy of Table 1 below for easy reference. There are several ways to achieve this, such as:

  • Increase ship size: engine power ratio
  • Reduce lightship weight
  • Innovative solutions (air bubble – friction reduction)
  • Optimise propeller efficiency
  • Hydrodynamics improvement
  • Speed reduction
  • Use of renewal power source (wind, solar power)
  • Low carbon fuels (e.g., LNG)
  • Energy saving devices (e.g., WHR, shaft generators)

Shipowners and Ship Managers: There are a number of technical and operational measures that can be considered to reduce GHG emissions.

Application: Applies to all new ships of the types or sizes shown in the table below with a change from the previous requirements.


Expected 1 January 2024

Draft amendments to SOLAS regulation II-1/3-8 to cover mooring arrangements

Background: As a result of a number of incidents on board ships involving the failure of mooring lines causing serious injury or death, the IMO has developed new requirements covering the provision and maintenance of mooring lines.

Summary: Four new paragraphs will be added to the current regulation II-1/3-8, to address:

Design requirements: New ships will have to be designed, and their mooring equipment (including ropes/wire) selected to ensure occupational safety and safe mooring of ships. Ship specific information will need to be included in the Towing and Mooring Arrangement Plan described in the new design guidelines given below. Approval of the plan by the flag Administration is not required.

Inspection and maintenance: For all ships, regardless of size and date of construction, mooring equipment including lines will be subject to inspection and maintenance requirements.

Three sets of supporting guidance covering design, maintenance and the strength of mooring equipment have also been produced.

Implication: The design of mooring arrangements may have to change significantly to demonstrate compliance with the new requirements. Reasons for non-compliance will have to be documented.

Application: The new requirements that affect the design of ships apply only to new ships of 3000GT and above with building contract on or after 1 January 2024, keel laid on or after 1 July 2024 or delivered on or after 1 January 2028. New ships less than 3000GT are encouraged to comply. The requirements for inspection and maintenance will affect existing ships.

Draft amendments to SOLAS chapter II-1 concerning doors, hatches and valves which pierce watertight boundaries

Background: The amendments to SOLAS chapter II-1 part B and B-1 (MSC.216(82) and MSC.421(98)) introduced inconsistencies with parts B-2 to B-4. These arose from the different philosophies behind the probabilistic damage stability assessment and the assumptions made for the regulations in parts B-2 to B-4. The probabilistic method does not rely on a single deck (the bulkhead deck) to provide the uppermost watertight boundary, instead the upper boundary of the buoyant volume may be used. In theory this does not need to be a single horizontal surface. The watertight integrity requirements contained in parts B-2 to B-4, however, continue to make reference to the bulkhead deck.

Summary: After considerable discussion amendments to the following regulations were agreed:

  • 7-2.5 to remove the inconsistency with regulation 17 regarding the treatment of doors in watertight bulkheads.
  • 12.6.1 to simplify the requirements for any valve which is installed at the collision bulkhead. The draft amendment does not specify the type of valve (e.g. screw-down or butterfly) but instead provides a number of functional requirements:

“The valve shall be a remotely controlled valve capable of being operated from above the bulkhead deck of passenger ships and the freeboard deck of cargo ships. The valve shall be normally closed. If the remote control system should fail during operation of the valve, the valve shall close automatically or be capable of being closed manually from a position above the bulkhead deck of passenger ships and the freeboard deck of cargo ships.”

  • 13 to restructure and clarify the requirements particularly with regard to the safety centre and location of the central operating console on passenger ships.
  • Various regulations regarding doors and hatches above the bulkhead deck that might be allowed to be open during navigation have been changed to standardise requirements.

In addition appropriate clauses concerning the application of the amended regulations were agreed.

Implication: There will be more choice available for valve type at the collision bulkhead and other requirements will be clear.

Application: It is anticipated that these amendments will be applicable to ships constructed on or after 1 January 2024.

Comprehensive review of SOLAS Chapter IV (Review of the requirements)

Background: The current SOLAS chapter IV (GMDSS) requirements were adopted in 1988 based upon technologies developed in the 1970s. Noting development in technologies and changes in the status of INMARSAT, a comprehensive review of the requirements is under way.

Summary: As well as amendments to SOLAS Chapters III and IV and related and consequential amendments to other IMO instruments, the following are the notable changes currently under discussion:

  • Provision of GMDSS satellite services and redefinition of Sea Area 3
  • VHF Data Exchange System (VDES)
  • NAVDAT (Proposed to be used in addition to NAVTEX or as an alternative where the NAVDAT service is available. It should be noted that the performance standards for NAVDAT are not expected to be approved before 2021)
  • Routing of distress alerts and related information
  • Search and rescue technologies
  • HF communications
  • False alerts
  • Training

Implication: It should be noted that the carriage requirements are not expected to change. The intention at this time is that most equipment will remain valid in order to reduce necessary additional investment in both ship equipment and shore side services.

Application: Expected to apply to all ships of 300 GT and above to which the requirements of the GMDSS apply, including new and existing ships.

Draft amendments to IGC code Paragraph & IGF Code paragraph on the use of materials such as aluminium alloys – Welding procedure tests for cargo tanks and process pressure vessels (consequential change in accepting high manganese austenitic steel)

Background: Following the development of the interim guidelines on the application of high manganese austenitic steel for cryogenic service, the relevant paragraphs in the IGC and IGF Code needed to be made more general in their application.

Summary: Paragraph of the IGC Code and paragraph of the IGF Code are amended to read “…For materials such as aluminium alloys, reference shall be made…”

Implication: These relatively minor amendments enable alternative materials to be used and make it clear that the requirements for welding and non-destructive testing are met.

Application: The amendments are expected to enter into force on 1 January 2024 and will apply to those ships which use high manganese steel in the construction of tanks carrying low temperature cargo or fuel.

Draft amendments to the revised recommendation on testing of life-saving appliance (MSC.81(70))

Background: These proposed draft amendments to MSC.81(70) as amended are intended to update the references to ISO Standards in Part 1: Prototype tests for life-saving appliances.

Summary: Proposed amendments will be made to Part 1 – Prototype tests for life-saving appliances paragraph (Test for porosity); paragraph (Oil resistance) and paragraph (Test for surface resistance to oil)

Implication: Those carrying out prototype tests will need to note the updated references to the appropriate ISO standards on publication of the amendments.

Application: These are considered to be minor amendments correcting some outdated references.

Expected Date Unknown

Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009

Adopted by the 2009 SR Conference – SR/CONF/45

Background & Summary: In 2009, the International Convention for the Safe and Environmentally Sound Recycling of Ships was signed by 67 Member States of the IMO. This internationally binding Convention has been adopted due to concerns about standards of ship recycling. It affects both recycling facilities and shipowners.

The Convention will enter into force 24 months after it has been ratified by 15 States, representing 40% of the world fleet, and with an annual ship recycling capacity of 3% of that fleet. As of 24 September 2019, thirteen States have become party to the Convention, representing 29.4% of world tonnage.

The Convention requires that, within five years of the entry into force date (or before the ship goes for recycling, if that is earlier), ships must have on board an ‘Inventory of Hazardous Materials’ (IHM). This requirement will apply to new ships as soon as the Convention enters into force.

Overall, the Convention can be described as a response to the lack of regulation and standards in the ship breaking industry; especially where safety, environmental and quality standards are concerned. It covers the entire ship life cycle; from design and construction, through in-service operation to dismantling and requires:

  • Ships to have an IHM (previously known as ‘the ‘Green Passport’);
  • New builds to exclude certain hazardous materials;
  • Ship recycling facilities to be authorised by the national authority;
  • Ship recycling facilities to provide an approved ‘Ship Recycling Plan’ detailing how the ship will be recycled;
  • Ships flying the flag of parties to the Convention to be recycled only in authorised recycling facilities; and
  • Ship recycling facilities which are located in parties to the Convention to recycle only ships which they are authorised to recycle.

At the final survey before the ship is taken out of service, the IHM will be completed for items such as operational stores and bunkers. The approved Ship Recycling Plan will then be checked against the IHM to ensure it properly reflects the information it contains.

Various guidelines have been developed for the implementation of the Convention.

Shipowners and Ship Managers:

  • to provide an Inventory of Hazardous Materials for their ship
  • to inform the flag State before a final survey takes place
  • to arrange the final survey before the ship is taken out of service for the completion of IHM for items such as operational stores and bunkers

Recycling facilities:

  • to obtain “Document of Authorization for Ship Recycling” from the competent authority of the recycling State
  • to inform their authorities should they wish to recycle a ship
  • to prepare a specific ‘Ship Recycling Plan’, based on the IHM which the owner provides
  • to report when recycling is finished

National authority of States with recycling facilities:

  • to authorise ship recycling facilities
  • to approve Ship Recycling Plans

Application: Once the Convention enters into force it will apply to all ships and MODUs, high-speed craft, FSUs/FPSOs and barges. For new builds it will enter into force 24 months after the ratification criteria are met. Existing ships will have up to five years after the criteria are met.

International Convention for the Safety of Fishing Vessels (Torremolinos Convention) Cape Town Agreement

Background: The Torremolinos Convention and its 1993 Protocol have not yet entered into force as the entry into force requirements (15 flag States with an aggregated fleet of 14,000 ships) have not been met. There have also been some problems with the technical requirements. In order to address these issues an agreement has been reached which changes the entry into force requirements to 22 flag states and 3,600 fishing vessels which operate on the high seas and modifies some of the technical provisions.

Summary: The diplomatic conference in Cape Town, South Africa, in October 2012 agreed that the entry into force criteria should be 22 flag states which between them have at least 3,600 fishing vessels of 24 metres in length and over operating on the high seas. The survey and certification requirements were amended to the five year cycle. A phased-in application for some parts of the requirements for existing fishing vessels was also agreed.

A procedure for confirming the number of fishing vessels each signatory has was agreed by MSC 92. Signatories will be expected to provide the number of fishing vessels which are registered with them at the same time they advise the IMO of their signing of the Cape Town Agreement. If numbers are not provided then the IMO will follow various routes to obtain accurate information.

Shipowners and Ship Managers:

The Protocol has requirements covering the following areas:

  • construction, watertight integrity and equipment;
  • stability and associated seaworthiness;
  • machinery and electrical installations and periodically unattended machinery spaces;
  • fire protection, detection, extinction and firefighting;
  • protection of crew;
  • life-saving appliances and arrangements;
  • emergency procedures, musters and drills;
  • radiocommunications; and
  • shipborne navigational equipment and arrangements.

When it enters into force these safety items will need to be provided on board fishing vessels. Some of the requirements are applicable to existing fishing vessels as well as to new construction.

It should be noted that some flag Administrations have already enacted the Torremolinos Convention and Protocol, so fishing vessels flagged with these Administrations will find that nothing will change following these amendments.

Shipbuilders / Designers of fishing vessels will need to ensure that the regulations are complied with. This may require additional or different safety equipment to be provided.

Flag Administrations and their Recognised Organisations will have to survey new and existing fishing vessels to the extent required and issue appropriate certification.

Application: The Torremolinos Convention and Protocol is, in general, applicable to fishing vessels of 24 metres in length and over.

Although the majority of the requirements are applicable only to new ships, the following are also applicable to existing ships:

  • Life-saving appliances and arrangements – only regulation 13 ‘Radio life-saving appliances’ and regulation 14 ‘Radar transponders’;
  • Emergency procedures, musters and drills;
  • Radiocommunications; and
  • Shipborne navigational equipment and arrangements.

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