May 11, 2005
IMO's MSC starts another mega session
Meetings of IMO's Maritime Safety Committee (MSC) are important way-stations on the international maritime regulatory superhighway.
The MSC is meeting in London today for its 80th session, which lasts until May 20, and, as usual, it has an extensive agenda packed with items with the potential to add to the compliance burdens faced by the maritime industry. (Just one example. plucked at random from the list, is a proposal that the Company Identification Number be added to a slew of ISPS documents)
The agenda includes development of goal-based standards for new ship construction, the adoption of revised provisions for subdivision and stability in SOLAS chapter II-1 Construction--Structure, subdivision and stability, machinery and electrical installations, continued work on passenger ship safety and implementation of maritime security measures adopted by IMO.
Goal-based new ship construction standards
The idea that IMO should in any way set ship construction standards tramples all over turf traditionally held by classification societies.
Unfortunately, in the not too distant past, the classification societies allowed construction of a number of ships built with a large content of high-tensile steel and that now turn out to have a limited life expectancy. In a world in which people who buy ships seldom look beyond initial construction cost, the notion surfaced that IMO should develop initial ship construction standards that would permit innovation in design but ensure that ships are constructed in such a manner that, if properly maintained, they could remain safe for their entire economic life. The standards would also have to ensure that all parts of a ship can be easily accessed to permit proper inspection and ease of maintenance.
The IMO Council referred the proposal to the MSC in 2003. Since then, the MSC has reached broad agreement on a five tier system consisting of goals (Tier I), functional requirements (Tier II), verification of compliance criteria (Tier III), technical procedures and guidelines, classification rules and industry standards (Tier IV) and codes of practice and safety and quality systems for shipbuilding, ship operation, maintenance, training, manning, etc. (Tier V).
At this week's meeting, the MSC is expected to re-establish a Working Group on Goal-based New Ship Construction Standards to continue work on the issue, based on the premise that the standards should be broad, over-arching goals against which ship safety should be verified at the design and construction stages and during ship operation.
The Working Group is expected to finalize the basic principles of goal-based standards, the Tier I goals and the Tier II functional requirements for consideration and approval by the Committee. Extensive discussions are expected on functional requirements preliminarily agreed at MSC's last session, concentrating on issues such as design life, environmental conditions, fatigue life, coating life, corrosion addition, structural strength, construction quality, maintenance, transparency, operating conditions, information keeping, actual service life and watertight and weathertight integrity.
Substantial progress is expected on the verification of compliance criteria (Tier III). This includes the question of who should verify the compliance of the classification societies' rules with the goal-based standards and the mechanism and procedure of verification.
Revised SOLAS chapter II-1 set for adoption
The revision of SOLAS chapter II-1 is intended to harmonize the provisions in the chapter on subdivision and damage stability for passenger and cargo ships. The revised provisions will be applicable to new ships.
The draft amendments are based on the "probabilistic" method of determining damage stability. This, in turn, is based on the detailed study of data collected by IMO relating to collisions. Since it is based on statistical evidence of what actually happens when ships collide, the probabilistic concept is believed to be far more realistic than the previously-used "deterministic" method.
Bulk carrier construction standards--interpretations
MSC will consider requests for the preparation of interpretations to the revised SOLAS chapter XII which is expected to enter into force on July 1, 2006. The interpretations concern, in particular, regulation XII/6 addressing side shell failure in bulk carriers. Several submissions to the meeting request the development of an authoritative interpretation of the regulation, applicable to bulk carriers of 150 m in length and upwards, carrying solid bulk cargoes having a density of 1,000 kg/m3 and above, constructed on or after July 1, 2006. If there is general agreement that such interpretation is necessary, MSC will instruct its Sub-Committee on Ship Design and Equipment (DE) to prepare a relevant circular for approval by the Committee at its next session.
Voluntary IMO Member State Audit Scheme and draft Code for the implementation of mandatory IMO instruments
The MSC will review a report on the Voluntary IMO Member State Audit Scheme. The scheme is designed to help promote maritime safety and environmental protection by assessing how effectively Member States implement and enforce relevant IMO Convention standards, and by providing them with feedback and advice on their current performance.
The MSC will also consider the draft Code for the implementation of mandatory IMO instruments, developed by the Sub-Committee on Flag State Implementation (FSI) to be the audit standard under the Audit Scheme. The results of the MSC's consideration of both issues will be reported to the IMO Council in June 2005 with a view to their formal adoption by the IMO Assembly in November 2005.
Other amendments to SOLAS
The MSC will also consider, with a view to adoption, other amendments to SOLAS, including:
Amendments to the ISM Code/ISPS Code
Amendments to the International Management Code for the Safe Operation of Ships and for Pollution Prevention (the ISM Code) and International ship and Port Facility Security (ISPS) Code will be considered. The proposed amendments would add the Company identification number to the Document of Compliance, Interim Document of Compliance, Safety Management Certificate, Interim Safety Management Certificate, International Ship Security Certificate and Interim International Ship Security Certificate.
Amendments to the Guidelines on the enhanced programof inspections during surveys of bulk carriers and oil tankers (resolution A.744(18)), as amended
The proposed draft amendments to the Guidelines on the enhanced program of inspections during surveys of bulk carriers and oil tankers (resolution A.744(18)), as amended, incorporate some elements of the Condition Assessment Scheme (CAS) required for certain single hull tankers under the revised MARPOL regulation I/13G and include re-organization of the guidelines to include a new section on survey guidelines for the inspection of double hull tankers.
Passenger ship safety
The guiding philosophy for work on passenger ship safety is based on the premise that the regulatory framework should place more emphasis on the prevention of a casualty from occurring in the first place and that future passenger ships should be designed for improved survivability so that, in the event of a casualty, persons can stay safely on board as the ship proceeds to port. The MSC has agreed a three-hour "time to remain habitable" to allow for safe and orderly abandonment and ahs agreed to minimum casualty scenarios that a passenger ship must survive and still proceed back to port.
The Sub-Committees on Radiocommunications, Search and Rescue (COMSAR), Ship Design and Equipment (DE), Fire Protection (FP), Flag State Implementation (FSI), Stability, Load Lines and Fishing Vessel Safety (SLF) will report to the MSC on their work in meeting the objectives and tasks set by the MSC. These include the preparation of guidelines, standards and proposed draft amendments to the SOLAS convention relating to passenger ship safety, such as standards relating to alternative designs and arrangements; proposed SOLAS regulations and standards for provision of personal life saving appliances for infants and large adults; standards for essential systems and equipment on passenger ships for safe return to port after a casualty and functional requirements for a safe area(s), where people could be accommodated in the event of a fire aboard a passenger ship.
Other issues under consideration in relation to large passenger ship safety, which have been considered by the Sub-Committees, include development of draft circulars or guidelines on reports on marine casualties and incidents, on recommended conditions for extending the period of validity of a certificate, on the transfer of class-related matters between recognized organizations and on interpretations of the date of completion of the survey and verification on which the certificates are based. Also relevant is the development of amendments to survey guidelines under the harmonized system of surveys and certification for MARPOL Annex VI Prevention of Air Pollution from Ships.
The aim is to complete the work on passenger ship safety by 2006.
The MSC is also expected to consider a possible role for the World Maritime University in co-ordinating search and rescue research projects related to passenger ships.
Measures to enhance maritime security
The MSC is expected to consider issues relating to the implementation of the special measures to enhance maritime security which were adopted by the Organization in 2002 and entered into force on July 1, 2004.
Proposed Mandatory training and certification requirements for persons to be designated as ship security officers (SSOs), endorsed by the Sub-Committee on Standards of Training and Watchkeeping (STW) will be reviewed. Proposed draft amendments to the STCW Convention and to parts A and B of the STCW Code require candidates for a certificate of proficiency as a ship security officer to demonstrate they have the knowledge to complete a range of tasks, duties and responsibilities, including: maintenance and supervision of the implementation of a ship security plan; assessment of security risk, threat, and vulnerability; undertaking regular inspections of the ship to ensure that appropriate security measures are implemented and maintained; ensuring that security equipment and systems, if any, are properly operated, tested and calibrated; and encouraging security awareness and vigilance.
Long-range identification and tracking of ships
The Committee will consider proposed draft amendments to SOLAS chapter XI-2 Special measures to enhance maritime security to include a new regulation on Long-range identification and tracking of ships. The proposed draft regulation would require ships to transmit information automatically to enable the identification and tracking of the ship by SOLAS Contracting Governments.
Formal safety assessment
A Joint MSC/MEPC Working Group on Formal Safety Assessment (FSA) is to be established to continue the review of the FSA process. The MSC has agreed on the need to improve the process so that, in the future, the Organization could have, as part of its decision-making process, a single, internationally recognized tool upon which to base its decisions and recommendations.
The MSC and the Working Group are expected to discuss the possible establishment of a group of experts which would be entrusted to provide expert judgement in relation to specific FSA studies.
The report of a Correspondence Group on FSA will also be discussed. The report includes proposed draft amendments to the Guidelines for Formal Safety Assessment (FSA) for use in the IMO rule-making process (MSC/Circ.1023 -MEPC/Circ.392).
Implementation of the revised STCW Convention
The list of Parties deemed to be giving full and complete effect to the provisions of the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), 1978, as amended, is expected to be updated when IMO Secretary-General Mitropoulos submits his report on those countries whose reports of independent evaluations have been completed since the previous MSC meeting.