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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