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 MEPC 72:
- MEPC 72/3/7 (co-sponsored with Community of European Shipyards’ Associations – CESA) provides proposed modifications to the draft amendments to regulation 21 of MARPOL Annex VI (Required EEDI for ro-ro cargo and ro-ro passenger ships) with a view to clarifying the scope of application of the amended regulation.
- MEPC 72/3/9/Rev.1 (co-sponsored with Bahamas, Jamaica, Liberia and the Netherlands) provides suggested amendments to the draft regulation D-3 of the BWM Convention to clarify the application dates of the different revisions of the Guidelines for approval of ballast water management systems (G8) (i.e. Guidelines (G8) and the 2016 Guidelines (G8)) and the Ballast Water Management Systems Code. In particular, the paper opines that that the application criteria, due to their importance, should not be included in the resolutions but in the text of the Convention or Code in order to improve their visibility and facilitate the uniform and unambiguous implementation of the applicable requirements.
- MEPC 72/4/4 seeks the Committee’s views on amending the Ballast Water Management Plan (BWMP) to accommodate the elements introduced by BWM.2/Circ.62 on Guidance on contingency measures under the BWM Convention.
- MEPC 72/4/11 invites the Committee to consider whether detailed aspects of the validation of the compliance of individual Ballast Water Management Systems with regulation D-2 of the BWM Convention at the time of their commissioning, need to be addressed. In particular, IACS asks the Committee to consider what the scope should be of the sampling and analysis to be carried out prior to completion of the initial survey. In the view of IACS, this issue needs to be addressed by the development and finalization, as soon as is practicable, of relevant amendments to the BWMS Code.
- MEPC 72/6/2 provides a sample form of the confirmation of compliance for Part II of the Ship Energy Efficiency Management Plan (SEEMP) pursuant to regulation 5.4.5 of MARPOL Annex VI, which requires confirmation that the SEEMP complies with regulation 22.2 is provided to, and retained on board, the ship. It is proposed that this form will be issued following verification that the SEEMP includes a description of the methodology that will be used to collect the data required by regulation 22A.1 and the processes that will be used to report the data to the ship’s Administration.
Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at permsec@iacs.org.uk