Maritime Safety Committee (MSC), 100th session, 3-7 December 2018

The Maritime Safety Committee (MSC) completed its landmark 100th session, with progress in the regulatory scoping exercise on maritime autonomous surface ships; approval of revised guidelines on fatigue and further updates on work on goal-based standards, polar shipping and safety issues relating to low-sulphur fuel.

A special session brought in invited speakers who discussed future technologies and the continued role of the seafarer. A new IMO safety video was launched, highlighting the wide spectrum of work the Committee has done over six decades to enhance safety and security at sea, including navigation, cargoes, ship construction, seafarer training, search and rescue and communications and more.

Regulatory scoping exercise on Maritime Autonomous Surface Ships

The process of assessing IMO instruments to see how they may apply to ships with varying degrees of autonomy continued during the Maritime Safety Committee (MSC) 100th session.

Following testing of the methodology by a correspondence group, the MSC approved the framework and methodology for the regulatory scoping exercise on Maritime Autonomous Surface Ships (MASS).

For each instrument related to maritime safety and security, and for each degree of autonomy, provisions will be identified which:

  • apply to MASS and prevent MASS operations; or
  • apply to MASS and do not prevent MASS operations and require no actions; or
  • apply to MASS and do not prevent MASS operations but may need to be amended or clarified, and/or may contain gaps; or
  • have no application to MASS operations.

The degrees of autonomy identified for the purpose of the scoping exercise are:

  • Degree one: Ship with automated processes and decision support: Seafarers are on board to operate and control shipboard systems and functions. Some operations may be automated and at times be unsupervised but with seafarers on board ready to take control.
  • Degree two: Remotely controlled ship with seafarers on board: The ship is controlled and operated from another location. Seafarers are available on board to take control and to operate the shipboard systems and functions.
  • Degree three: Remotely controlled ship without seafarers on board: The ship is controlled and operated from another location. There are no seafarers on board.
  • Degree four: Fully autonomous ship: The operating system of the ship is able to make decisions and determine actions by itself.

Once the first step is completed, a second step will be conducted to analyse and determine the most appropriate way of addressing MASS operations, taking into account, inter alia, human element, technology and operational factors. The analysis will identify the need for:

  • Equivalences as provided for by the instruments or developing interpretations; and/or
  • Amending existing instruments; and/or
  • Developing new instruments; or
  • None of the above as a result of the analysis.

The initial review of instruments under the purview of the Maritime Safety Committee will be conducted during the first half of 2019 by a number of volunteering Member States, with the support of interested international organizations. 

An intersessional MSC working group is expected to meet in September 2019 to move forward with the process with the aim of completing the regulatory scoping exercise in 2020.

The list of instruments to be covered in the MSC’s scoping exercise for MASS includes those covering safety (SOLAS); collision regulations (COLREG); loading and stability (Load Lines); training of seafarers and fishers (STCW, STCW-F); search and rescue (SAR); tonnage measurement (Tonnage Convention); Safe Containers (CSC); and special trade passenger ship instruments (SPACE STP, STP).

Development of guidelines on MASS trials
The MSC noted provisional principles for the development of guidelines on MASS trials, discussed by a working group. The principles include ensuring that such guidelines should be generic and goal-based, and taking a precautionary approach to ensuring the safe, secure and environmentally sound operation of MASS. Interested parties were invited to submit proposals to the next session of the Committee, taking into account these principles.

Goal-based standards and safety level approach

Following the adoption of Goal-based ship construction standards for bulkers and oil tankers (GBS) and the successful initial verification of 12 Recognized Organizations by IMO GBS audit teams at previous sessions, the MSC confirmed that the information submitted concerning the maintenance of verification by those 12 ROs demonstrated continued conformance with the Standards (this covered all IACS member recognized organizations, except for DNV-GL, a classification society formed as the result of a merger between DNV and GL, which would be subject to a re-verification audit of its rules.)

The Committee, having considered the initial verification audit report of a further recognized organization, Türk Loydu, confirmed  that the information provided by Türk Loydu had demonstrated that its ship construction rules conform to the Goal-based Standards.

The experience gained in conducting GBS audits has highlighted the need to update the procedural requirements guiding the audits. The MSC therefore adopted Revised guidelines for verification of conformity with goal-based ship construction standards for bulk carriers and oil tankers, to come into effect one year after adoption (1 January 2020).

The Committee also approved Interim Guidelines for development and application of the IMO goal-based standards safety level approach.

The Committee considered a request from the Sub-Committee on Ship Systems and Equipment (SSE) for advice from the Committee in respect to difficulties encountered in drafting goal-based regulations for onboard lifting appliances and anchor handling winches (OLAW). Following consideration of the request, the MSC agreed to amend the Generic guidelines for developing IMO goal-based standards (MSC.1/Circ.1394/Rev.1) so as to aid their application by the bodies of the Organization. The MSC invited Member States and international organizations to submit proposals in this respect to MSC 101
Revised guidelines on fatigue approved

The MSC approved revised Guidelines on fatigue, which provide comprehensive information on the causes and consequences of fatigue, and the risks it poses to the safety and health of seafarers, operational safety, security and protection of the marine environment. The aim is to assist all stakeholders to contribute to the mitigation and management of fatigue.

IMO has considered the issue of fatigue for several decades, adopting Assembly resolution A.772(18) on Fatigue factors in manning and safety, in 1993. This was followed by the development of comprehensive Guidance on fatigue mitigation and management (MSC/Circ.1014), which was issued in 2001. The guidelines have been thoroughly reviewed and updated by the Sub-Committee on Human Element, Training and Watchkeeping (HTW 5), taking into account the latest research studies.

Safety of ships in polar waters

The Committee discussed how to move forward with developing possible mandatory and/or recommendatory measures for ships operating in polar waters which are not currently covered by the Polar Code. A roadmap was agreed, which could see revisions to SOLAS and/or the Polar Code considered for adoption in 2022..

MSC 99 had already instructed the Sub-Committee on Ship Design and Construction (SDC) to consider recommendatory safety measures for fishing vessels of 24 m in length and over, with a view to alignment with the 2012 Cape Town Agreement; and pleasure yachts above 300 gross tonnage not engaged in trade (in both cases, for those operating in Polar waters). At this session, the Committee considered the wider application of Polar Code chapters 9 (Safety of navigation), 10 (Communication) and 11 (Voyage planning).

Preliminary draft text which would extend the application of the Polar Code to all ships to which SOLAS chapter V (Safety of navigation) applies was agreed, for further consideration. Member States and international organizations were invited to submit information to MSC 101 that will assist to determine the feasibility and consequences of applying the requirements in chapters 9 (safety of navigation) and 11 (voyage planning) of the Polar Code to non-SOLAS ships, in order to progress the work at the next session.

The Committee also agreed that, in the meantime, a resolution could be developed as an interim measure and invited relevant poposals to the next session (MSC 101).

The Polar Code is mandatory for certain categories of ships under the SOLAS and MARPOL Conventions. SOLAS chapter V (safety of navigation) in principle applies to all ships on all voyages (with some specific exceptions) whilethe applicability of SOLAS chapter IV (radiocommunications) also extends to cargo ships of 300 gross tonnage and upwards, as opposed to the general SOLAS application to ships of 500 GT and above. SOLAS does not apply to some specific categories of ships, including cargo ships of less than 500 gross tonnage; pleasure yachts not engaged in trade; ships of war and fishing vessels (sometimes termed “non-SOLAS ships”).

Sulphur 2020 limit – safety issues

The Committee agreed to include in its agenda for MSC 101 a new item on "Development of further measures to enhance the safety of ships relating to the use of fuel oil". This followed the consideration of submissions concerning the potential need for guidance and advice concerning possible safety issues related to the implementation of the 0.50% limit of the sulphur content of fuel oil (outside emission control areas).  At the same time, the Committee endorsed the view that, while fuel safety was a longstanding existing concern which needed to be carefully addressed, this should not affect Member States' commitment to implementing the 2020 sulphur limit from the date of application (i.e. 1 January 2020).

Member States and international organizations were invited to submit concrete proposals to MSC 101 under the new output. The scope of work was agreed as follows: “Based on the review of existing safety provisions for fuel oil and information concerning the safety implications associated with the use of fuel oil, develop further measures to enhance the safety of ships relating to the use of fuel oil”. The target completion date is 2021.

The new 0.50% limit (reduced from 3.50% currently) on the sulphur content of ships' fuel oil, which will enter into force on 1 January 2020 under IMO's MARPOL treaty, will greatly benefit the environment and human health. The Marine Environment Protection Committee (MEPC 73) in October invited the MSC to consider relevant safety issues associated with the use of low-sulphur fuel oil, following the Intersessional Meeting on Consistent implementation of regulation 14.1.3 of MARPOL Annex VI (ISWG-AP 1).

The MSC agreed that a joint-MSC-MEPC circular on ensuring fuel suppliers deliver compliant fuels should be developed by the Sub-Committee on Pollution Prevention and Response (PPR 6), with a view to approval by MEPC 74 and MSC 101.

The MSC also noted the initiative of industry organizations to develop guidance to address potential safety and operational issues related to the supply and use of 0.50% sulphur fuels. This guidance is expected to be submitted to PPR 6 for consideration.

Amendments adopted

The MSC adopted:

  • Amendments to the Code of Safety for Special Purpose Ships (SPS Code), including a revised chapter 8 on life-saving appliances; a requirement for special purpose ships to comply with the provisions of chapter IV of SOLAS; and a revised Form of Safety Certificate for Special Purpose Ships and Record of Equipment for Special Purpose Ship Safety Certificate (Form SPS).
  • Amendments to sections B-V/a, B-V/b, B-V/c, B-V/d, B V/e, B V/f and B-V/g of the STCW Code, which relate to consequential amendments following earlier amendments to the STCW Convention and Code relating to the Polar Code.

Draft amendments to the 2011 ESP Code forwarded to MSC 101

The Committee decided to hold in abeyance the adoption of amendments to update the International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers, 2011 (2011 ESP Code), pending further work on the new consolidated Code by the Sub-Committee on Ship Design and Construction (SDC 6), which is expected to be adopted by the IMO Assembly at its 31st session..

Approval of draft amendments, guidance and guidelines

The MSC:

  • Approved draft amendments to the International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code), with a view to subsequent adoption. The draft amendments include draft revised chapters 17 (Summary of minimum requirements), 18 (List of products to which the Code does not apply), 19 (Index of products carried in bulk) and 21 (Criteria for assigning carriage requirements for products subject to the IBC Code), as well as draft new paragraph 15.15 (Hydrogen sulphide (H2S) detection equipment for bulk liquids). Further amendments are consequential to draft amendments to MARPOL Annex II.  Associated amendments to the BCH Code were approved for adoption in conjunction with the adoption of the above IBC Code amendments.
  • Approved draft amendments to forms C, E and P of the appendix to the International Convention for the Safety of Life at Sea (SOLAS), 1974, for consistency throughout the forms contained in the appendix.
  • Approved draft amendments to the International Life-Saving Appliance (LSA) Code regarding manual launching of a rescue boat (paragraph having a mass not more than 700 kg in fully equipped condition and which is not one of the ship's survival craft, allowing manual hoisting from the stowed position and turning out to the embarkation position by one person so that persons can be safely embarked.
  • Approved draft amendments to the LSA Code regarding a lifeboat with two independent propulsion systems (paragraph providing a flexibility for the requirement of sufficient buoyant oars and their related items to make headway in calm seas.
  • Approved draft amendments to paragraph 2.2 of chapter 15 of the FSS Code, aiming to provide a unified understanding of arrangements for inert gas lines and related indicators and alarms for monitoring the pressure of the inert gas mains.
  • Approved MSC.1/Circ.1430/Rev.1 on the Revised guidelines for the approval of fixed water-based fire-fighting systems for ro-ro spaces and special category spaces (to update the guidelines in MSC.1/Circ.1430). The revision relates in particular to the position of sprinklers or nozzles, to ensure adequate performance, and to reliable control of fixed water-based fire-fighting systems.
  • Instructed relevant sub-committees to consider relevant parts of the draft interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel prepared by CCC 5. The detailed interim guidelines provide requirements for the arrangement, installation, control and monitoring of machinery, equipment and systems using methyl/ethyl alcohol as fuel to minimize the risk to the ship, its crew and the environment, taking into account to the nature of the fuels involved.
  • Approved draft amendments to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code).  
  • Approved interim guidelines on the application of high manganese austenitic steel for cryogenic service. The interim guidelines are aimed at ensuring the safety of ships carrying or fuelled by LNG, by specifying the requirements for the utilization of high manganese austenitic steel in the design and fabrication of cargo and fuel tanks complying with the International Gas Carrier (IGC) and IGF Codes.
  • Approved Interim guidance for conducting the refined MHB (CR) corrosivity test related to draft amendments to section of the IMSBC Code concerning test for metals.
  • Approved new Global Counter Piracy Guidance, updated Gulf of Guinea Guidance, and version 5 of the Best Management Practices (BMP 5), and issued the suite of guidance as a new MSC circular on Revised Industry Counter Piracy Guidance.