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IACS PARTICIPATION AT MEPC 80

In demonstrating its ongoing commitment to supporting 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 80th session of the IMO’s Marine Environment Protection Committee (MEPC 80), which will meet at the IMO Headquarters in London, from Monday 3 to Friday 7 July 2023.

Noting the work IACS Members perform as Recognized Organizations of IMO Member States, verifying compliance of ships with IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following papers:

MEPC 80/4/12 discusses concerns about the temporary storage of treated sewage and grey water in the ballast tanks and provides a draft technical and operational guidance for temporarily storing treated sewage and/or grey water in ballast tanks. The intent of the guidance is to establish a uniform procedure for minimizing the impact on the environment.

MEPC 80/5/4 proposes an amendment to regulation 18.4 of MARPOL Annex VI related to gaseous and low-flashpoint fuels.

MEPC 80/6/1 proposes a revision of MEPC.1/Circ.795/Rev.6 on Unified Interpretations to MARPOL Annex VI to clarify the reporting of boil-off gas (BOG) consumed on board ships in the IMO Data Collection System (IMO DCS).

MEPC 80/6/8 seeks clarification of the term “filling rate for gas fuel tanks” used in paragraph 2.2.1 for fDFgas of the 2022 Guidelines on the method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships (resolution MEPC.364(79)). Noting that the footnote in the table of paragraph 4.2.3.2 of the 2022 Guidelines on the survey and certification of the Energy Efficiency Design Index (EEDI) (resolution MEPC.365(79)) leaves room for interpretation, this document proposes a revision of the footnote.

MEPC 80/14/1 proposes a new output to amend the 2017 Guidelines addressing additional aspects of the NOx Technical Code 2008 with regard to particular requirements related to marine diesel engines fitted with Selective Catalytic Reduction (SCR) systems (resolution MEPC.291(71) as amended by resolution MEPC.313(74)) (the 2017 SCR Guidelines), with a view to facilitating the consistent and global implementation of the requirements.

MEPC 80/16/1 proposes action on a minor issue relevant to the EGCS Electronic Record Book (ERB) appearing in paragraphs 4.4.9 and 5.7.1 of 2021 Guidelines for exhaust gas cleaning systems (MEPC.340(77)), to introduce a footnote referring to Guidelines for the use of electronic record books under MARPOL (resolution MEPC.312(74)) with a view to facilitating uniform and universal implementation.

MEPC 80/INF.5 contains a copy of the 2022 Industry guidelines for calculation and verification of the Energy Efficiency Design Index (EEDI) and the role of the verifier in conducting the verification of EEDI.

MEPC 80/INF.20 informs of the publication of IACS Recommendation No.175 on the “SEEMP/CII implementation guidelines” following the adoption of resolutions MEPC.346(78), MEPC.347(78), MEPC.352(78), MEPC.353(78), MEPC.338(76), MEPC.354(78) and MEPC.355(78).

IACS will also support the initiation of the work on carbon capture and storage (CCS) to be discussed under agenda item 7 (Reduction of GHG emissions from ships).

Any enquiries on the above should be sent to Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT MSC 107

In demonstrating its ongoing commitment to supporting 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 107th session of the Maritime Safety Committee (MSC 107), which will meet from Wednesday, 31 May to Friday, 9 June 2023.

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted and co-sponsored the following papers:

MSC 107/12/2 provides comments on paragraph 2.14 of document MSC 107/12 and proposes amendments to the application statement contained in the cover note of resolution MSC.188(79)/Rev.1, with a view towards uniform and universal implementation.

MSC 107/14/1 provides comments on paragraph 2.33 of document MSC 107/14 regarding application date of the draft unified interpretation of SOLAS regulation II-1/26.2 for single essential propulsion components as set out in annex 16 to document SSE 9/20. IACS recommends to the Committee the date of application to be 1 January 2024.

MSC 107/14/2 provides comments on paragraph 2.10 of document MSC 107/14 relating to the draft amendments to SOLAS regulation II-2/20 contained in annex 5 to document SSE 9/20. IACS identified inconsistencies and ambiguities in the draft amendments to SOLAS and proposes further modifications to the text to address these findings.

MSC 107/14/3 provides comments on paragraph 2.22 of document MSC 107/14 and proposed modifications to the amendments of the draft MSC circular on the Revised unified interpretations of SOLAS chapter II-2 and the FSS and FTP Codes (MSC.1/Circ.1456) to bring them in line with the corresponding draft amendments to SOLAS regulation II-2/7.5.5, contained in annexes 11 and 5 to document SSE 9/20.

MSC 107/14/5 provides comments on paragraph 2.6 of document MSC 107/14 regarding draft amendments of paragraph 6.1.2.10 of chapter VI of the LSA Code, and proposes editorial improvements and consequential changes, as well as raising technical concerns for future work.

MSC 107/17/3 proposes to include a new output in the strategic plan of the Organization and on the provisional agenda of the SDC Sub-Committee to amend the Revised guidance on shipboard towing and mooring equipment (MSC.1/Circ.1175/Rev.1) to update the technical guidance provided by the circular.

MSC 107/17/4 proposes a new output to amend paragraph 2.1.2.5 of chapter 5 of the International Code for Fire Safety Systems (FSS Code), as amended by resolution MSC.206(81), so as to align the construction requirement for gaskets used in discharge piping for fixed gas fire-extinguishing systems located within protected spaces with requirements for gaskets in piping systems addressed in other IMO instruments.

MSC 107/17/6 proposes to include a new output in the Strategic Plan of the Organization and on the provisional agenda for CCC Sub-Committee to permit lashing software as a supplement to the container stowage and securing plan by revising circular MSC.1/Circ.1353/Rev.2.

MSC 107/17/10 proposes a new output for the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR) to develop requirements for software maintenance of shipboard navigation and communication equipment and systems, to ensure that software maintenance carried out on such equipment is conducted in a controlled, safe and secure manner.

MSC 107/17/21 proposes a new output to undertake a regulatory assessment of safety aspects associated with reducing GHG emissions from ships in line with the Organization’s strategy (resolution MEPC.304(72), as revised) and to develop a road map to support the safe delivery of IMO’s GHG reduction strategy.

MSC 107/17/22 proposes a new output to develop amendments to circular MSC.1/Circ.1318/Rev.1 on Revised Guidelines for the maintenance and inspections of fixed carbon dioxide fire-extinguishing systems to clarify the testing and inspection requirements of CO2 cylinders.

MSC 107/17/24 proposes an approach to organizing the work of the Committee including a timeline and a format of the road map for the regulatory assessment and delivery of the regulatory framework as proposed in document MSC 107/17/21.

MSC 107/INF.10 provides the updated status of the work which is undertaken to address the IACS “common” observations as of 28 February 2023.

IACS will also contribute to the discussions under agenda item 3 (Consideration and adoption of amendments to mandatory instruments), agenda item 4 (Goal-based new ship construction standards), agenda item 5 (Development of a goal-based instrument for Maritime Autonomous Surface Ships (MASS)), and agenda item 6 (Development of further measures to enhance the safety of ships relating to the use of fuel oil).

Any enquiries on the above should be sent to Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT CCC 9

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following papers:

CCC 9/3/3 proposes amendments to paragraphs 7.3.1.3 and 9.4.1 of part A-1 of the IGF Code based on the experience gained to date in the application of the Code. The co-sponsors proposed as an alternative arrangement the use of non- return valves in lieu of the requirement for emergency shutdown (ESD) valves, as these are deemed to provide an equivalent level of protection for tank inlets safety relief valve discharge lines.

CCC 9/3/4 summarizes IACS comments after applying the Interim guidelines for the safety of ships using fuel cell power installations (MSC.1/Circ.1647) and provides suggestions for improvement in the following matters: terminology, fire and safety, control monitoring, risk analysis, testing of fuel cell power system, alternative design requirements, fuel cell modules supplied in metallic enclosures, and fuel cell spaces and arrangements. The items listed will benefit from further clarification based on the experience gained.

CCC 9/3/14 provides specific technical comments on the draft interim guidelines for ships using ammonia as fuel contained in annex 4 of document CCC 9/3 as proposed by Japan and as modified by the Correspondence Group.

CCC 9/3/15 provides detailed comments on annex 1 of document CCC 9/3 containing the draft interim guidelines for ships using hydrogen as fuel.

CCC 9/5/6 proposes amendments to the individual cargo schedules in appendix 1 to the IMSBC Code to delete superfluous requirements for additional self-contained breathing apparatuses (SCBAs).

CCC 9/10 proposes draft unified interpretations of appendix 1 – Individual schedules of solid bulk cargoes of the International Maritime Solid Bulk Cargoes Code (IMSBC Code) (resolution MSC.268(85)), to facilitate uniform and universal implementation of the MHB schedules of cargoes. IACS highlights the relevance of applying paragraph 4.3.2 of standard IEC 60092-506:2003 to MHB cargoes capable of creating an explosive gas atmosphere.

CCC 9/10/1 proposes a draft interpretation of the requirements of the IGC Code (paragraphs 4.4.1, 4.5, 4.6.2.1 and 4.6.2.4) and the 1983 IGC Code (paragraphs 4.7.1, 4.7.3, 4.7.4.1 and 4.7.7) related to secondary barrier testing. This unified interpretation applies to all gas carriers provided with membrane containment systems as defined in paragraph 4.1.5 of the IGC and in paragraph 4.2.2 of the 1983 IGC Code, except as otherwise explicitly indicated.

CCC 9/10/2 proposes draft unified interpretations (UIs) in relation to paragraphs 4.23.1.1, 4.23.1.2, 4.23.2.5, 4.23.4, 4.23.3.1, 4.23.3.2, 5.2.2.1, 5.12.4, 5.12.3.1, 8.1, 9.4.4, 16.3.4, 17.1 and 17.4 of the IGC Code, as contained in annex 1. Should the Sub-Committee choose to amend the IGC Code instead of agreeing to the UIs in annex 1 of the paper, in annex 2 IACS prepared draft amendments to the IGC Code (i.e., incorporating same UIs into the IGC Code) for the consideration of the Sub-Committee as part of the current work on the Revision of the IGC Code under agenda item 4 of CCC 9.

CCC 9/INF.16 provides information on gap analysis between ammonia as fuel and the IGF Code for LNG, taking into account the different properties, behaviours and hazards/risks.

CCC 9/INF.17 provides the outcome of the gap analysis on the application of the provisions of the IGF Code in relation to hydrogen as fuel.  IACS suggests that this information may also be considered while further developing the draft interim guidelines for hydrogen as fuel.

IACS will also contribute to the discussions under agenda item 4 (review of the IGC Code), item 7 (revision of the interim recommendations for carriage of liquefied hydrogen in bulk), and item 8 (Revision of the revised recommendations for entering enclosed spaces aboard ships (resolution A.1050(27)).

Any enquiries on the above should be sent to Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT SDC 9

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with the IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following papers:

SDC 9/7/1 comments on the report of the Correspondence Group on “Safety Objective and Functional Requirements for the SOLAS chapter II-1”, as provided in document SDC 9/7, and recommends performing identification of the failure mode(s)/hazards(s) being addressed by the existing prescriptive regulations, to ensure the alternative design and arrangements requirements adequately consider the intent of the existing regulations.

SDC 9/10 clarifies the necessary documentation in order to support the Administration or RO in verifying compliance with SOLAS regulation II-1/3-8 and proposes an interpretation, as set out in the annex.

SDC 9/10/1 follows on IACS document SDC 8/10/7 and responds to the Sub-Committee’s invitation to further consider the applicability of prototype testing of bulkhead/deck penetrations to ship types (cargo ships and/or passenger ships). IACS review concluded that there is no similar requirement or related explanatory note for testing bulkhead penetrations on cargo ships, hence the new interpretation proposed by IACS is only applicable to passenger ships. The interpretation clarifies that SOLAS regulation II-1/13 should be applicable to heat sensitive piping systems and should not be applied to cable penetrations in watertight bulkheads and decks.

SDC 9/10/2 proposes a draft interpretation of amendments of SOLAS chapter II-1 adopted by resolutions MSC.474(102) and MSC.482(103), concerning the expressions “ships constructed before 1 January 2024” and “Multiple hold cargo ships other than bulk carriers and tankers constructed on or after 1 January 2024.

SDC 9/10/3 proposes a revision of the annex to the Unified Interpretations of the 2008 Intact Stability Code (MSC.1/Circ.1537/Rev.1) so that the scope of application of the specific down-flooding points (ventilators, fitted with weathertight closing appliances, serving machinery spaces that are required to remain open) mentioned in paragraph 2 applies to the entirety of the 2008 Intact Stability Code (parts A and B).

SDC 9/12 proposes a correction to paragraph 2.2.2 of the Revised performance standards for water level detectors on bulk carriers and single hold cargo ships other than bulk carriers (resolution MSC.188(79)/Rev.1) to clearly distinguish installation heights of detectors between requirements of applicable SOLAS regulations.

SDC 9/15 discusses the impact of the proposals against existing regulations, the lack of technical justification to apply new draft requirements to the family of bulk carriers and recommends that without clear justification for specific ship type(s) the Sub-Committee invites MSC to only note the proposals in document MSC 102/21/9/Rev.1.

IACS will also provide advice and comments to the Sub-Committee on a number of other issues, both in plenary and in the Working Groups that are expected to be established. IACS will contribute to the discussions also on agenda item 5 (Review of the guidelines for the reduction of underwater noise) and item 11 (Revision of the Interim explanatory notes for the assessment of passenger ship systems’ capabilities after a fire or flooding casualty (MSC.1/Circ.1369) and related circulars).

Any enquiries on the above should be sent to Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT SSE 9

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with the IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following papers:

SSE 9/14 proposes to amend the interpretation of the separation of galley ducts from spaces contained in MSC.1/Circ.1276, to align it with SOLAS, as amended by resolution MSC.365(93).

SSE 9/14/1 proposes a revised draft interpretation of SOLAS regulations II-2/19.3.4.1 and II-2/19.3.5.4, pertaining to required air changes for the carriage of dangerous goods.

SSE 9/14/2 provides a draft interpretation of SOLAS regulation II-2/9.7.4.5 focusing on the fire insulation requirements for vertical ducts which pass through both a bulkhead and a deck, without serving the spaces they pass through.

SSE 9/14/3 seeks clarification on the implementation of paragraphs 6.1.1.3 and 6.1.2.6 of the LSA Code in respect to the hoisting-up of a dedicated rescue boat on a cargo ship from its stowed position for subsequent slewing out to ship’s side, and proposes an interpretation, with a view towards facilitating universal and uniform application.

SSE 9/14/4 proposes amendments to MSC.1/Circ.1416/Rev.1 based on practical implementation of the interpretation, with a view to facilitating the universal and uniform implementation of requirements for “non-traditional steering systems”.

SSE 9/15/1 considers the alternatives to fluorinated fire-fighting foam concentrates available for inclusion in ships’ fire-fighting systems, and the intent of the PFOS ban approved by MSC 106; and comments on the draft revised text of MSC.1/Circ.1312, as being considered in document SSE 9/15 (Secretariat).

SSE 9/19/3 comments on document SSE 9/19 and presents further modifications to paragraph 4 of draft interim guidelines on safe operation of onshore power supply (OPS) service in port. The proposal is offered in the event that the original text for paragraphs 4.2 and 4.5 of the draft interim guidelines is not kept as appears in document SSE 8/18/1.

SSE 9/19/4 suggests due consideration of safety and environmental impacts with respect to pressure/vacuum (P/V) valves when amending MSC/Circ.677 regarding reference to ISO standard 15364.

IACS will also provide advice and comments to the Sub-Committee on a number of other issues, both in plenary and in the Working and Drafting Groups that are expected to be established.

Any enquiries on the above should be sent to Mr Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT PPR 10

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with the IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following papers:

PPR 10/14  proposes a draft unified interpretation for the form of the Bunker Delivery Note (BDN) referred to in regulation 18 (Fuel oil availability and quality) of MARPOL Annex VI, to confirm that BDNs are acceptable in either hard copy or digital form providing they meet the relevant requirements of MARPOL Annex VI.

PPR 10/17/2 addresses the issues of compliance with the sampling point location requirements in MEPC.1/Circ.864/Rev.1 related to the fuel oil lines serving the emergency generator. The paper considers the need to revise MEPC.1/Circ.864/Rev.1 to define alternative fuel oil sample point location arrangement for the tank serving the emergency generator.

IACS will also provide advice and comments to the Sub-Committee on a number of other issues, both in plenary and in the Working Groups that are expected to be established. IACS will contribute to the discussions also on agenda items 3, 5, 7 and 17.

Any enquiries on the above should be sent to Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT NCSR 10

IACS has submitted/co-sponsored the following papers:

NCSR 10/16/3 proposes clarification of the application of the updated ISO 799:2019 standard, related to the existing footnote in the SOLAS consolidated edition 2020 where pilot ladders complying with ISO 799:2004 may need to be replaced with those complying with ISO 799:2019. In addition, potential modifications are proposed for MSC.1/Circ.1428 to be included in the poster to assist with the understanding of the IMO requirements.

NCSR 10/21/1 identifies gaps and/or inconsistencies existing in circular COMSAR.1/Circ.32/Rev.1 and proposes related amendments with a view towards uniform and universal implementation of GMDSS requirements.

IACS will also provide advice and comments to the Sub-Committee on items related to the development of guidelines for the use of electronic record books under SOLAS regulation V/28; pilot transfer arrangements and the  amendments to SOLAS regulation V/23 and resolution A.1045(27).

Any enquiries on the above should be sent to Mr Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk.

IACS PARTICIPATION AT SDC 10

In demonstrating its ongoing commitment to supporting 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 10th session of the Sub-Committee on Ship Design and Construction (SDC 10) which will meet at the IMO Headquarters in London from Monday, 22 to Friday, 26 January 2024.

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with the IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted the following papers:

SDC 10/3/2 comments on paper SDC 10/3 and offers proposals on the preliminary draft guidelines for emergency towing arrangements for ships other than tankers as described in paragraphs 10 to 13 of SDC 10/3/2.

SDC 10/6 proposes draft amendments to the 2011 ESP Code, as amended by resolution MSC.483(103), with a view to allowing the use of remote inspection techniques (RIT) for close-up surveys of existing bulk carriers and oil tankers. IACS proposes to include a definition of RIT and specific requirements.

SDC 10/8 presents IACS’ view on paper MSC 105/18/1 and offers comments on the proposed amendments intended to address both rudder-type and modern combined propulsion/steering systems.

SDC 10/9 proposes draft amendments to MSC.1/Circ.1331 on the Guidelines for the construction, installation, maintenance and inspection/survey of means of embarkation and disembarkation. The following sections are proposed to be amended: section 1 – Application, section 2 – Construction, section 5.1.1.2 – Accommodation ladder, section 5.1.2.2 Gangway, section 5.2.2 – Winch, section 5.3.3 – Tests.

SDC 10/10 proposes a draft unified interpretation relating to means of internal communication equipment required in an emergency to be supplied from the emergency source of power in passenger ships as required by SOLAS regulation II-1/42.2.3.1, with a view to facilitating a consistent implementation.

SDC 10/10/1 proposes a draft interpretation of paragraphs 2.1 and 2.2 of the Code on noise levels on board ships (resolution MSC.337(91)) to clarify against which standard the calibration of the sound level meter and its field calibrator shall be carried out.

SDC 10/10/2 proposes a revision of MSC.1/Circ.1572/Rev.1 regarding unified interpretations of the Performance standards for water level detectors on bulk carriers and single hold cargo ships other than bulk carriers (resolution MSC.188(79)) consequential to the adoption of resolution MSC.188(79)/Rev.2.

SDC 10/10/3 proposes a unified interpretation of SOLAS chapter XV and the IP Code to clarify with which SOLAS safety certificates the IP Safety Certificate should be harmonized in terms of validity, survey dates and endorsements, with a view towards universal and uniform implementation.

SDC 10/10/4 proposes a revision of MSC.1/Circ.1511 on the Unified interpretations of SOLAS regulations II-2/9 and II-2/13 to clarify the term “safe position” used in connection with means of escape from machinery spaces.

SDC 10/10/5 proposes revisions to sections 1.4 and 1.5 of the annex to   MSC.1/1572/Rev.1 in respect of the interpretation (including procedures and technical background) of SOLAS regulations II-1/3-6.2.3 and II-1/3-6.3.1 related to permanent means of access.

SDC 10/INF.8 provides information on the observed “near miss” safety incident with the permanent means of access, in support of the proposals in document SDC 10/10/5.

SDC 10/12/2 comments on the proposals in document SDC 10/12 (Germany et al.), in particular with regard to addressing the fire testing of the FRP structures and informs about the experience of IACS members leading to the conclusion on the need for improvement in the current testing regime for fire performance of composite structures.

SDC 10/14 proposes to transfer the output “Review of the 2009 Code on Alerts and Indicators” from the SSE Sub-Committee onto the provisional agenda of SDC 11.

IACS will also provide advice and comments to the Sub-Committee on a number of other issues, both in plenary and in the Working Groups that are expected to be established. IACS will contribute to the discussions also on agenda item 7 (Safety objectives and functional requirements of the Guidelines on alternative design and arrangements for SOLAS chapter II-1), agenda item 11 (Amendment to regulation 25 of the of the 1988 Load Line Protocol regarding the requirement for setting of guard rails on the deck structure), agenda item 13 (Revision of the Interim explanatory notes for the assessment of passenger ship systems’ capabilities after a fire or flooding casualty (MSC.1/Circ.1369) and related circulars), and agenda item 16 (Any other business).

Any enquiries on the above should be sent to Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT SSE 10

In demonstrating its ongoing commitment to supporting 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 10th session of the Sub-Committee on Ship Systems and Equipment (SSE 10) which will meet from 4 to 8 March 2024. 

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with the IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following 17 papers:

SSE 10/4 proposes amendments to paragraph 4.7.6.4 of the LSA Code; consequential draft amendments to paragraphs 6.9.7 (Part 1) and 6.1.1 (Part 2) of resolution MSC.81(70) to address the design and prototype test requirements for the equipment used in the simulated launching of free-fall lifeboats; and consequential amendments to MSC.1/Circ.1529 to expand its application to paragraph 4.7.6.4 of the LSA Code.

SSE 10/10/1 provides information on the technical evaluation of the CARGOSAFE FSA study, performed by IACS, and IACS’ initial deliberations on the risk mitigating measures proposed therein.

SSE 10/12 proposes a draft interpretation of SOLAS regulation II-2/11.4.1 with a view to ensuring consistent implementation of this provision for passenger ships and cargo ships.

SSE 10/12/1 proposes a unified interpretation of SOLAS regulation II-2/4.2.2.3.5.2.1 regarding acceptable equivalent arrangements.

SSE 10/12/2 proposes a unified interpretation regarding the fitting of the small-diameter self-closing control cock required by SOLAS regulation II-2/4 on sounding pipes in certain tanks.

SSE 10/12/5 proposes a unified interpretation on the secondary means of venting cargo tanks required by SOLAS regulation II-2/4.5.3.2.2, as amended by resolution MSC.392(95), and SOLAS regulation II-2/11.6.3.2 to achieve a unified understanding and implementation on board.

SSE 10/12/6 proposes a draft unified interpretation of SOLAS regulation II-1/3-13.2.4 to facilitate uniform documentation of load testing and thorough examination for existing non-certified lifting appliances.

SSE 10/12/7 provides comments on document SSE 10/14 relating to the proposed interpretations of paragraphs 6.1.1.3 and 6.1.2.2 of the LSA Code, with a view towards universal and uniform implementation.

SSE 10/12/8 provides comments on document SSE 10/14 relating to the applicability of SOLAS regulation III/20.11 and resolution MSC.402(96) to inflated rescue boats, with a view towards universal and uniform implementation.

SSE 10/12/9 provides comments on document SSE 10/12/3, providing information on the outcome of SSE 9 and MSC 107 on single essential propulsion components and their reliability.

SSE 10/14/1 provides comments on paragraphs 13 to 16 and annex 2 to document SSE 10/14 relating to the identified safety issues and barriers to consistent implementation of resolution MSC.402(96), with a view towards prioritizing the issues and establishing relevant solutions.

SSE 10/17 proposes to start the work on the output “Review of the 2009 Code on Alerts and Indicators” in the 2024-2025 biennium. It currently resides with the SSE Sub-Committee as the coordinating organ and it is proposed to transfer it to the provisional agenda of SDC 11.

SSE 10/17/1 proposes to include the output “Review and update SOLAS regulation II-2/9 on containment of fire to incorporate existing guidance and clarify requirements” in the provisional agenda for SSE 11.

SSE 10/17/2 proposes to include the output “Development of amendments to chapter 6 of the 2009 MODU Code regarding electrical equipment capable of operation after shutdown” in the provisional agenda for SSE 11.

SSE 10/17/3 proposes to include the output ʺDevelopment of amendments to chapter 15 of the FSS Code on enclosed spaces containing a nitrogen receiver or a buffer tank of nitrogen generator systemʺ in the provisional agenda for SSE 11.

SSE 10/19 proposes minor corrections to SOLAS regulations II-2/11.2 and II-2/11.4.1 with a view to ensuring consistent implementation of this provision for passenger ships and cargo ships.

SSE 10/19/4 proposes to include the output “Development of amendments to chapter 6 of the 2009 MODU Code regarding electrical equipment capable of operation after shutdown” in the provisional agenda for SSE 11.

IACS will also provide advice and comments to the Sub-Committee on a number of other issues, both in plenary and in the Working and Drafting Groups that are expected to be established.

Any enquiries on the above should be sent to Mr Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

IACS PARTICIPATION AT MEPC 81

In demonstrating its ongoing commitment to supporting 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 81st session of the IMO’s Marine Environment Protection Committee (MEPC 81), which will meet at the IMO Headquarters in London, from Monday 18 to 22 March 2024.

Noting the work IACS Members perform as Recognized Organizations of IMO Member States, verifying compliance of ships with IMO agreed requirements, and with a view to achieve clarity for all parties, IACS co-sponsored the following papers:

MEPC 81/3/6 comments on the draft amendments to MARPOL Annex VI regulation 13.2.2. The co-sponsors noted that the proposed amendments refer to “a Party”, which follows the precedent in paragraph 7.1 of the same regulation. However, the paper clarifies that since the matter involves conversion of ships in service, the decision must be made by the flag Administration, i.e. “the Administration”, not “a Party” to the convention. The same applies to the draft 2023 Guidelines as required by regulation 13.2.2, in respect of non-identical replacement engines not required to meet the Tier III limit and the unified interpretation and guidelines given in the draft revision of circular MEPC.1/Circ.795.

MEPC 81/4/6 provides draft guidance for the temporary storage of treated sewage and grey water in ballast water tanks. It takes into consideration related documents drafted for and discussed in prior sessions and seeks to incorporate such considerations into a revised guidance for the Committee’s consideration and action as needed.

MEPC 81/6/7 proposes a correction to the definition of capacity appearing in the CII Guidelines, G5, to clarify an identified discrepancy between the 2022 Guidelines on operational carbon intensity indicators and the calculation methods (CII Guidelines, G1) and the 2022 Interim Guidelines on correction factors and voyage adjustments for CII calculations (CII Guidelines, G5).

IACS will also contribute to the deliberations under agenda item 5 (Air Pollution Prevention).

Any enquiries on the above should be sent to Mr Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk