International Maritime Organization is a specialized agency of the United Nations that deals with matters referred to it by its Member Governments. This Organization is mainly involved in the development, on the basis of proposals by Member States, of international regulations, the practical application of which is the responsibility of the maritime Administrations concerned (i.e. the Government of the State whose flag the ship is entitled to fly).
Q1: Can IMO approve a life-saving appliance for compliance with the regulations?
A1: IMO does not approve any type of life-saving appliance, as this is under the responsibility of the national maritime Administrations (i.e. the Government of the State whose flag the ship is entitled to fly). As per SOLAS regulations III/4 and 5, before accepting life-saving appliances and arrangements that have not been previously approved by the Administration, the Administration shall be satisfied that life-saving appliances and arrangements comply with the requirements of this chapter and the LSA Code.
The Administration shall ensure that such life-saving appliances and arrangements are tested, to confirm that they comply with the requirements of chapter III and the LSA Code, in accordance with the recommendations of the Organization (resolution MSC.81(70)).
For those novel life-saving appliances for which there are not clear provisions in SOLAS chapter III:
(1) appliances should provide safety standards at least equivalent to the requirements of chapter III and the LSA Code and have been evaluated and tested based on the guidelines developed by the Organization; or
(2) arrangements should have successfully undergone an engineering analysis, evaluation and approval in accordance with regulation 38.
Q2: I have suggestions to amend life-saving appliances regulations in IMO instruments. Can IMO advise me on my suggestions?
A2: As a rule of thumb, IMO cannot advise whether any amendment would be acceptable before being discussed by the appropriate body. For life-saving appliances, a proposal should be made to the parent body, i.e. the Maritime Safety Committee, after which, the proposal should be referred to the Sub-Committee on Ship Systems and Equipment. The proposals are normally submitted by Member State(s) and/or observers to IMO.