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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MEPC 81/4/6 provides draft guidance for the temporary storage of treated sewage and grey water in ballast water tanks.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

IACS PARTICIPATION AT MSC 108

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 108th session of the Maritime Safety Committee (MSC 108), which will meet from Wednesday, 15 May to Friday, 24 May 2024.

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 achieving clarity for all parties, IACS has submitted and co-sponsored the following papers:

MSC 108/4/4 outlines the work IACS has undertaken to assess, consolidate and standardize the vocabulary relevant to MASS to support the verification and validation of MASS systems, as contained in the annexes of this document;

MSC 108/INF.11 informs about IACS Recommendation No.171 on incorporating cyber risk management into safety management systems;

MSC 108/6/1 highlights the increasing vulnerability of the maritime industry to cyberattacks due to increased digitalization and connectivity and provides an insight into existing instruments. The document proposes improvements to MSC-FAL.1/Circ.3/Rev.2 to provide further guidance which could be helpful to the maritime industry;

MSC 108/14/1 proposes to move forward the timeline for entry into force of the draft amendment to paragraph 16.9.2 of the IGC Code set out in annex 2 of document CCC 9/WP.4, through approval of the draft amendment at this session; earlier entry into force of the amendment, as an exceptional circumstance defined in MSC.1/Circ.1481; and issuance of an MSC circular inviting voluntarily implementation of the amendment based on MSC.1/Circ.1565;

MSC 108/19/3 discusses the approach by IACS to the development and submission to IMO of unified interpretations (UIs) and opines that approval of IMO UIs by “consensus” as opposed to by “unanimity” offers tangible benefits to IMO and the shipping industry in achieving their common goal of safe shipping, in a universal and uniform manner, as well as assisting the Organization with managing its workload;

MSC 108/19/6 provides explanations on and background for the review of the North Atlantic wave data (IACS Recommendation 34/Rev.2) and addresses several concerns expressed in document MSC 108/19 as related to the new data.

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 CCC 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 Carriage of Cargoes and Containers (CCC 10), which will meet from Monday, 16 September to Friday, 20 September 2024.

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 achieving clarity for all parties, IACS has submitted and co-sponsored the following papers:

CCC 10/3/2 proposes an amendment to paragraph 9.6 of the IGF Code to provide technical requirements for gas fuel vent pipes with single-walled construction in machinery spaces;

CCC 10/3/4 proposes amendments to paragraphs 11.5.1, 11.5.2 and 11.5.3 of part A-1 of the IGF Code concerning a water spray system for fuel storage tank(s);

CCC 10/4/3 proposes amendments to paragraph 11.3.2 of the IGC Code concerning a water spray system for fuel storage tank(s);

CCC 10/4/5 provides comments on the report of the Correspondence Group on Amendments to the IGF Code and Review of the IGC Code presented in document CCC 10/4;

CCC 10/4/7 provides comments on document CCC 10/4/1 proposing to develop interim guidelines for the use of anhydrous ammonia cargo as fuel;

CCC 10/7 proposes a revision of MSC.1/Circ.1353/Rev.2 to accept lashing software as a supplement to the container stowage and securing arrangement plan included in the approved Cargo Securing Manual in order to evaluate actual loading conditions, and draft performance standards and guidelines with which the lashing software should comply to allow consistent approval of lashing software;

CCC 10/8/2 contains comments on the report of the Correspondence Group on the Revision of Resolution A.1050(27);

CCC 10/10 proposes a draft unified interpretation of paragraph 5.7.1 of the IGF Code to facilitate the universal and uniform implementation of the IGF Code;

CCC 10/10/3 proposes a draft unified interpretation of SOLAS regulation II-1/2.29 to clarify the applicability of SOLAS regulations II-1/56 and II-1/57 to facilitate the universal and uniform implementation of the IGF Code to ships using gas as fuel;

CCC 10/INF.3 informs the Sub-Committee on revision 5 of IACS UI SC 89 of SOLAS regulation II-2/19.3.4 and the IMSBC Code cargo space ventilation requirements with the inclusion of a new cargo type in accordance with the amendments to the IMSBC Code (resolution MSC.539(107));

CCC 10/14/1 comments on document CCC 10/14 and proposes that further considerations are required before the Revised Interim recommendations for carriage of liquefied hydrogen in bulk, as adopted by resolution MSC.565(108), can be amended.

CCC 10/15/1 proposes risk-prevention-related areas which should be considered by the Sub-Committee in order to mitigate the risks and consequences of cargo fires on containerships;

CCC 10/INF.10 informs the Sub-Committee of IACS unified interpretation GF 20 of paragraph 5.3 of MSC.1/Circ.1621 regarding arrangements for methyl/ethyl alcohol fuel tanks;

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 82

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 82nd session of the Marine Environment Protection Committee (MEPC 82) which will meet from 30 September to 4 October 2024.

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 achieving clarity for all parties, IACS has submitted and co-sponsored the following documents:

MEPC 82/6/15 discusses the practical implications of implementing the amendments to Appendix IX of MARPOL Annex VI adopted during MEPC 81 concerning the information to be submitted to the IMO Ship Fuel Oil Consumption Database (IMO DCS). This document also outlines the understanding of IACS of the implementation of these amendments, as formalized in its unified interpretation MPC 131 (New, July 2024) which will enter into force on 1 November 2024 for flag States not objecting thereto;

MEPC 82/6/32 proposes consequential updates to the standardized data-reporting format for the data collection system and operational carbon intensity (Appendix 3 of the SEEMP Guidelines), seeking alignment with the amendments to Appendix IX of MARPOL Annex VI as adopted by resolution MEPC.385(81) and the amendments to the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (resolution MEPC.346(78)), adopted by resolution MEPC.388(81);

MEPC 82/10/3 comments on the draft amendments to the NOx Technical Code 2008 on certification of an engine subject to substantial modification, as set out in annex 14 to document PPR 11/18/Add.1, and proposes further modifications thereto.

MEPC 82/16/3 proposes changes to the 2023 Guidelines for the development of the Inventory of Hazardous Materials (resolution MEPC.379(80)) as a consequence of the introduction of controls on cybutryne in the International Convention on the Control of Harmful Anti-fouling Systems on Ships, 2001 (AFS Convention) to clarify the relevant threshold in respect to cybutryne, when samples are directly taken from the hull or when samples are taken from wet paint containers.

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 MSC 109

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 109th session of the Maritime Safety Committee (MSC 109) which will meet from 2 to 6 December 2024.

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 achieving clarity for all parties, IACS has submitted and co-sponsored the following documents:

MSC 109/3/3 comments on document MSC 109/3 (Secretariat) which contains draft amendments to paragraphs 11.3.2 and 11.3.2.2 of the IGF Code and proposes modifications to improve the clarity and achieve uniform implementation;

MSC 109/4/2 comments on document MSC 109/4/1 (Secretary-General) containing the final audit report on the revision 2 of IACS Recommendation 34 “Standard Wave Data” (IACS Rec.34/Rev.2), which is intended to address IACS/2015/FR1-8/OB/02 and accepts all recommendations;

MSC 109/4/4 provides comments on the newly proposed table format used for the GBS Maintenance Audits in document MSC 108/INF.14;

MSC 109/4/6 comments on the final report of the GBS audit addressing observation No. IACS/2015/FR1-8/OB/02 presented in document MSC 109/4/1 (Secretary-General) and proposes reaffirmation of the criticality of adherence to the principles of good seamanship and the responsibility for proper operation and maintenance, as well as endorsing and encouraging the need for the continuous development of the structural requirements of organizations which are recognized by the Administration in accordance with the provisions of SOLAS regulation XI-1/1, or national standards of the Administration;

MSC 109/INF.6 provides the updated status of the work which is undertaken to address the IACS “common” observations as on 30 August 2024.

MSC 109/5/4 while providing a brief on general data quality and management aspects, brings out aspects specific to MASS and suggests a high-level approach towards data quality, which is essential for the safety of MASS;

MSC 109/6/1 provides additional information on some alternative fuels and proposes a generic format for representing the physical properties for each fuel;

MSC 109/7/1 discusses the importance of further cybersecurity measures for ships and port facilities following the Committee’s approval of the draft revised Guidelines on maritime cyber risk management (MSC-FAL.1/Circ.3/Rev.3) and proposes next steps to enhance maritime cybersecurity;

MSC 109/11/1 proposes revisions of the FSA Guidelines in response to the invitation by MSC 108 to submit concrete text proposals in order to improve the text of the Guidelines;

MSC 109/11/2 proposes editorial changes to the Revised FSA Guidelines (MSC-MEPC.2/Circ.12/Rev.2);

MSC 109/13/8 comments on the draft performance standards for pilot transfer arrangements contained in annex 9 of document NCSR 11/19/Add.1 and suggests modifications to the footnotes and clarifications regarding dedicated strong points in paragraphs 12 and 15.1;

MSC 109/14/1 provides comments on the draft amendments to the IGC Code contained in document CCC 10/WP.7 for approval by MSC 109 and subsequent adoption by MSC 110;

MSC 109/21/1 offers the views and initial considerations of IACS on the nature of unified interpretations, understanding of the meaning of safeguards and the degree of their application to different cases of interpretations, and recommends the development of guidelines to assist in the application of safeguards;

MSC 109/21/2 identifies different understandings amongst stakeholders on whether a duplicated MF/HF radio installation may be also accepted as a primary MF radio installation for sea area A3, based on COMSAR.1/Circ.32/Rev.2, and aims for a global and consistent implementation of GMDSS requirements.

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