In demonstrating its ongoing commitment to support the work of the International Maritime Organization (IMO), and within its remit as the Organization’s principal technical advisor; IACS will actively participate in the forthcoming 101st session of the IMO’s Maritime Safety Committee (MSC 101), which will meet from Wednesday, 5 to Friday, 14 June 2019.
Noting the work its Members undertake in verifying the global and consistent implementation of IMO agreed requirements on behalf of the IMO Member States (in their capacities as Recognized Organizations), and to facilitate clarity for all industry stakeholders, IACS has submitted, or co-sponsored, papers on the following issues to MSC 101:
- Amendments to the IGF Code. Paper MSC 101/3/9 provides proposals to clarify the draft amendments to paragraph 11.3.3bis of the International Code of Safety for Ship Using Gases or Other Low-flashpoint Fuels (IGF Code). In particular, the paper opines three is a need to clarify that two conditions need to be met for the fuel storage hold space to be considered as a cofferdam e. the type C tank is not to be located directly above machinery spaces of category A or other rooms with high fire risk; and compliance with the specified minimum distance to the A-60 boundary. Paper MSC 101/3/10 proposes additional text to paragraph 9.5.6 of the Code in order to clarify that leakage detection for secondary enclosures is required around all liquefied fuel pipes.
- Goal-based new ship construction standards (GBS) for bulk carriers and oil tankers. Paper MSC 101/INF.13 provides updated reports on the status of the work to address the observations, in relation to Rules that are ‘common’ to all IACS Members, that were raised as a result of both the initial verification and the first maintenance of verification audit.
- Development of further measures to enhance the safety of ships relating to the use of fuel oil. Paper MSC 101/8 proposes a method of work, and items to be taken into account, when developing measures to enhance the safety of ships relating to the use of fuel oil. For issues that cannot be addressed by operational measures, IACS is of the view that some additional measures should be adopted to minimize the risks associated with the use of fuels onboard ships, especially in relation to fuel oil blends. The paper also proposes that a structured and evidence-based approach should be taken in order to justify any need to take regulatory action. Paper MSC 101/8/1 provides further clarification on IACS Unified Interpretation (UI) SC 123, which addresses the arrangements and capacities of fuel oil service tanks as per SOLAS regulation II-1/26.11. In particular, the paper clarifies that this UI was developed to clarify emergency changeover arrangements for different types of fuel oil service tank arrangements for vessels trading in Emission Control Areas (ECAs).
- Draft revised Model Agreement. Paper MSC 101/10/2 proposes amendments to both the draft revised Model Agreement (between an Administration and a Recognized Organization (RO)) and the associated draft MSC-MEPC.5 circular. The paper identifies that some of the terminology and provisions in the draft revised Agreement, which is before MSC 101 for its consideration, exceed the remit of ROs and could be detrimental to the conclusion of such Agreements. The paper also proposes that the issuance of this new circular should not affect the validity of extant Agreements that have either been concluded based on, or that refer to, MSC/Circ.710 and MEPC/Circ.307; or that have been already updated to refer to the Code for Recognized Organizations (RO Code).
- Procedure for identifying safety issues. Paper MSC 101/10/3 provides comments on the Procedure for identifying safety issues that was agreed at the last session of the Sub-Committee on Implementation of IMO Instruments (III 5). The paper proposes that the Procedure should be reviewed by the IMO Experts Group on Formal Safety Assessment. It is proposed that this analysis by experts, who have significant knowledge and experience in undertaking risk assessments, should particularly consider the risk assessment and acceptance criteria in the Procedure.
- Revised Guidance on shipboard towing and mooring equipment. Paper MSC 101/12/4 proposes modifications to the draft revised Guidance regarding the marking of the safe towing load (TOW) on equipment; and that the designer should consider verifying the adequacy of the strength of the ship’s tow line.
- Unified interpretations on ventilation system openings. Paper MSC 101/12/5 notes that, as currently drafted, the revised unified interpretation, which is before the Committee with a view to its approval, only pertains to “unprotected openings”. This ordinarily means openings that are not required to be fitted with closure devices. Therefore, openings that are fitted with closure devices would not be covered by this draft revised interpretation. However, for operational reasons, ventilators that must remain open to ventilate certain spaces should be evaluated as unprotected openings, even if fitted with closure devices. Consequently, the paper proposes the deletion of the word “unprotected” from the term “Unprotected openings” in the draft revised unified interpretation.
- Manual launching of rescue boats (paragraph 188.8.131.52 of the LSA Code). Paper MSC 101/14/5 proposes a simple, but important, editorial clarification to the draft amendment to the LSA Code that is before the Committee for finalisation. The proposal aims to avoid an internal conflict between the provisions in paragraph 184.108.40.206 of the LSA Code, i.e. between the "existing" and the draft "new" provisions.
- Unified Interpretation of SOLAS regulations II-1/28, II-1/29 and II-1/30 (steering systems). Paper MSC 101/14/6 proposes an amendment to the proposed application date (June 2019) of this draft unified interpretation, which is before the Committee for approval. The paper opines that designers, manufacturers and shipyards need to be properly informed in advance of the date of application of the unified interpretation so they are able to take due account of these new provisions. Consequently, the paper proposes an alternative application date of 1 January 2020.
- Equipment used in the simulated launching of free-fall lifeboats. Paper MSC 101/21/10 proposes a new output to develop design and prototype test requirements for the arrangements used in the operational testing of free-fall lifeboat release systems without launching the lifeboat (equipment used in the simulated launching of free-fall lifeboats).
- Harmonisation of mandatory requirements related to watertight doors on cargo ships. Paper MSC 101/21/16 proposes a new output to review the mandatory requirements in the SOLAS, MARPOL and Load Line Conventions and the IBC and IGC Codes regarding watertight doors on cargo ships, to address the inconsistencies that currently exist.
Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at firstname.lastname@example.org