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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 the following papers:

MEPC 78/4 raises concerns about the temporary storage of treated sewage and grey water in the ballast tanks and seeks clarification from the Committee on the permission of such practice under the BWM Convention; also, the document provides possible approaches to be considered, if the permission of such practice is confirmed.

MEPC 78/9 comments on document MEPC 76/9/5 containing proposed changes to the draft amendments to appendix II of MARPOL Annex I, the draft Oil Record Book (ORB) guidance and the draft 2020 Integrated Bilge Water Treatment System (IBTS) guidelines.

MEPC 78/INF.16 provides information on the development of the 2022 IACS guidelines for the use of Computational Fluid Dynamics (CFD) for the purposes of deriving the Vref in the framework of EEXI regulation, which will be incorporated in an IACS Recommendation.

MEPC 78/INF.27 provides IACS’ understanding and recommendations contained in the new draft 2022 IACS guidelines on the implementation of EEXI. The Guidelines will be incorporated in an IACS Recommendation which is to be published soon.

IACS will also provide advice and comments to the Committee under agenda items 3 (Consideration of adoption of amendments to mandatory instruments), agenda item 7 (Reduction of GHG Emissions from Ships), agenda item 9 (Pollution Prevention and Response) and agenda item 15 (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 has submitted paper NCSR 9/19/1 which considers SOLAS regulation V/22 (requirements for navigation bridge visibility), specifically paragraphs 1.2 providing the provisions for blind sectors caused by cargo, cargo gear and other obstructions outside of the wheelhouse forward of the beam obstructing the “view of the sea surface” as seen from the conning positions.  IACS considers that “the view of the sea surface” (SOLAS regulation V/22.1.1) outside of the range forward of the bow to 10° on either side from the main conning position and obstructions, which cause blind sectors within that range, are open to interpretation and proposes a unified interpretation of SOLAS regulation V/22 in respect of “the view of the sea surface”.

IACS will also provide advice and comments to the Sub-Committee under agenda item 12 (Response to matters related to the ITU-R Study Groups and ITU World), item 16 (Revision of ECDIS Guidance for good practice (MSC.1/Circ.1503/Rev.1) and amendments to ECDIS performance standards) and item 18 (Development of SOLAS amendments for mandatory carriage of electronic inclinometers on container ships and bulk carriers).

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

IACS panels represent the top tier of the Association’s issue-specific bodies, so establishing a Safe-Decarbonisation Panel (SDP) sends the clearest possible signal of IACS’ determination to support industry through this multi-faceted, multi-decadal challenge.  Giving decarbonisation the same focus as the traditional areas of Safety, Environment, Hull, Machinery, Survey & Cyber significantly enhances the association’s ability to address safe decarbonisation concerns and support the protection of human life, property and the marine environment.

To help deliver common technical requirements at speed, the SDP will immediately convene four project teams to work on leading decarbonisation fuels and technologies.  While IACS remains technologically agnostic, extensive discussions with industry – itself a key feature and objective of the SDP – indicate that initial efforts should be focused on Ammonia, Hydrogen, Carbon Capture &  Storage and Batteries.  Additionally, the SDP will also evaluate current work streams at IMO on Methyl/ethyl Alcohols with a view to undertaking further work as appropriate.  Other alternative fuels and technologies will be considered by the SDP subsequently.

Recognising that efforts to decarbonize need to be collaborative to be successful, the SDP has also adopted a structured consultative approach so that all stakeholders – fuel manufacturers, technology providers, owners, builders and marine insurance – have multiple and multi-layered opportunities to engage with IACS at strategic, operational and technical levels.

Such close cooperation will help focus prioritization, maximise efficiency and remove duplication and allow for the resulting outputs to be properly targeted either in the form of IACS Resolutions or recommendations or submissions to IMO to support the development of detailed regulations.  Collectively, this work will help encourage industry to invest in new fuels/technologies by offering a degree of reassurance that standards are being harmonized and technologies are proven against these requirements.

Commenting on this development, IACS Chair Nick Brown said ‘IACS’ establishment of a Safe Decarbonisation Panel allows for an over-arching view on new initiatives, whether they be related to the propulsion of the vessels or to the changing nature of the cargoes ships will carry as a result of societal efforts to decarbonize, and so marks a step-change in embedding a safety-focus into this industry-wide effort.’

On other matters, C85 strongly endorsed the progress being made by the Independent Quality Assessment Review Body (IQARB) and committed to assisting that body develop into a respected entity that can be trusted by flag States, Industry and others to provide high-level oversight of the quality systems of Class Societies and Recognised Organisations.

C85 also reviewed the suite of measures adopted by IACS to help the industry maintain business continuity in the face of the operational challenges posed by the COVID-19 pandemic and noted the effectiveness of IACS’ COVID-19 Task Force in ensuring that ships were able to safely remain in service and in compliance with Class Rules and the requirements of the international Conventions.  C85 agreed, however, that the improving COVID situation now allowed for a phased withdrawal of the various exemptions noting that operational challenges still exist in certain areas.

Contact: Robert Ashdown, IACS Secretary General
E: robertashdown@iacs.org.uk T: +44 (0) 20 7976 0660

International Association of Classification Societies
Permanent Secretariat 4 Matthew Parker Street, London, England SW1H 9NP

E: permsec@iacs.org.uk

T: +44 (0)20 7976 0660

Notes to Editors:

1. Dedicated to safe ships and clean seas, the International Association of Classification Societies (IACS) makes a unique contribution to maritime safety and regulation through technical support, compliance verification and research and development. More than 90% of the world’s cargo carrying tonnage is covered by the classification design, construction and through-life compliance Rules and standards set by the twelve Member Societies of IACS.
2. A high resolution (18mb) portrait photo of Nick Brown is available at https://iacs.s3.af-south-1.amazonaws.com/wp-content/uploads/2023/09/25153926/nick-brown-scaled.jpg
3. More information on the work IACS has undertaken in response to the COVID19 pandemic can be found on our dedicated webpage http://iacs.org.uk/covid-19/
4. More information about IACS can be found by visiting iacs.org.uk and in our Annual Review available online at http://www.iacs.org.uk/about/iacs-annual-review/

The mandatory nature of IMO’s Energy Efficiency Existing Ship Index (EEXI) means it has a significant role to play in ensuring that the industry remains on track to meet GHG reduction targets.

IACS is fully supportive of IMO’s initiatives on decarbonisation and has played an essential role in the development of EEXI by the IMO’s Marine Environment Protection Committee (MEPC) through the provision of technical comments and proposals across ten submissions relating to ship energy efficiency and carbon intensity (EEDI/EEXI/CII), four of which focus on EEXI.

In addition to its work at IMO, IACS Recommendation No. 172 (Rec.172) has been developed to support the global and consistent implementation of the newly developed EEXI IMO framework by providing additional advice and guidance on certain elements of the regulatory text where cross-industry discussions had identified technical implementation nuances associated with the EEXI framework.

Specific issues identified as needing further elaboration in Rec.172 include: the approval of the EEXI Technical File; non-overridable power limitation; EEXI calculation methodology for LNG Carriers; ship type applicability; appropriate Specific Fuel Consumption (SFC) values, and; the uniform performing & validating of numerical calculations of the EEXI reference speed (Vref).

With the amendments to MARPOL Annex VI incorporating mandatory EEXI becoming effective on 1 November 2022 and taking effect at the shipboard level on 1 January 2023, it remains vitally important for IACS to provide and maintain clarity and to allow relevant stakeholders to benefit from a common approach amongst IACS Members in the calculation of a ship’s EEXI.

IACS Secretary General, Robert Ashdown, said ‘IACS is in a unique position to assist industry in complying with complex decarbonisation regulations by providing technical guidance that can help to maintain clarity while also enabling the practical and consistent application of this index on a global scale.’

Rec.172 is just the latest expression of IACS’ ongoing commitment to supporting industry in meeting IMO’s greenhouse gas (GHG) reduction targets and IACS will continue to actively participate in the revision or upgrade of EEXI and Carbon Intensity Index requirements.

Contact: Robert Ashdown, IACS Secretary General
E: robertashdown@iacs.org.uk T: +44 (0) 20 7976 0660

International Association of Classification Societies
Permanent Secretariat 4 Matthew Parker Street, London, England SW1H 9NP

E: permsec@iacs.org.uk

T: +44 (0)20 7976 0660

Notes to Editors:

1. Dedicated to safe ships and clean seas, the International Association of Classification Societies (IACS) makes a unique contribution to maritime safety and regulation through technical support, compliance verification and research and development. More than 90% of the world’s cargo carrying tonnage is covered by the classification design, construction and through-life compliance Rules and standards set by the twelve Member Societies of IACS.
2. More information on the work IACS has undertaken in response to the COVID19 pandemic can be found on our dedicated webpage http://iacs.org.uk/covid-19/
3. More information about IACS can be found by visiting iacs.org.uk and in our Annual Review available online at http://www.iacs.org.uk/about/iacs-annual-review/

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 paper III 8/INF.19 and co-sponsored paper III 8/12/1:

III 8/12/1 suggests amending resolutions A.1118(30) and A.1156(32) to provide guidance on the use of remote audits and surveys, respectively. It also indicates principles that could be considered for the future development of guidance on assessments and applications of remote surveys, ISM Code audits and ISPS Code verifications.

III 8/INF.19 provides a draft guidance on remote statutory surveys and draft guidance for performance of ISM/ISPS remote audits/verifications. These two draft guidance documents take into account the knowledge obtained from the development of IACS UR Z29 on classification surveys and the current practices and procedures implemented by individual IACS members when conducting remote statutory surveys, audits and verifications, when acting as recognized organizations (ROs) or recognized security organization (RSOs).

IACS will also contribute to the discussions under agenda item 4 (Lessons learned and safety issues identified from the analysis of marine safety investigation reports), agenda item 5 (Measures to harmonize port State control (PSC) activities and procedures worldwide, and agenda item 10 (Updated survey Guidelines under the Harmonised System of Survey and Certification).

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

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 8/2/1 follows on IACS submission to the 32^nd IMO Assembly and MSC 105. The document elaborates on three options to illustrate the variety and complexity of issues which will need to be addressed in the regulatory development process, some of which lie outside the immediate remit of the CCC Sub-Committee, thus necessitating an overarching Committee’s attention and effort.

CCC 8/3/1 proposes amendments to paragraph 5.11.2.2 of the IGC Code and paragraph 7.3.2.1 of Part A-1 of the IGF Code. IACS indicates that the negative manufacturing tolerance for thickness should be introduced in the formula as an “absolute value” to avoid the risk of having a very low minimum thickness of the pipe.

CCC 8/3/2 proposes a revision of regulation 11.3.3.1.2 of Part A-1 of the IGF Code, as amended by resolution MSC.458(101).

CCC 8/3/3 provides a clarification regarding regulations 11.3.2 and 11.3.3 of the IGF Code, as to the application of “A-60” fire integrity rating to the accommodation block and the deckhead of a machinery space, other than category “A” machinery space, where the deckhead is beneath the fuel containment system.

CCC 8/5/13 proposes to amend the IMSBC Code to clarify the carriage requirement of spare charges for SCBAs (self-contained breathing apparatuses) required solely by the IMSBC Code.

CCC 8/10/3 provides draft amendments to the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code), as amended by resolution MSC.370(93), incorporating published relevant unified interpretations.

CCC 8/10/4 provides draft amendments to the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code), as amended by resolution MSC.370(93), incorporating draft unified interpretations submitted to the previous session of the Sub-Committee and additional ones developed by IACS since then.

CCC 8/10/6 seeks clarification from the Sub-Committee regarding the certification requirements of gas carriers when using a low flash point fuel (LFPF) system that is completely independent of the cargo systems.

CCC 8/12 discusses the acceptance of lashing software as a supplement to the stowage and securing plan included in the approved Cargo Securing Manual (CSM), in order to evaluate actual loading conditions, and proposes a draft unified interpretation for endorsement of IMO.

CCC 8/12/1 proposes draft amendments to sections 1 and 2 of the annex to MSC.1/Circ.1558 on unified interpretations of the IGF Code, to facilitate the consistent and global implementation of paragraphs 2.2.15.3 and 2.2.17 of part A of the IGF Code.

CCC 8/12/2 proposes unified interpretation of paragraphs 4.20.3.5, 4.20.3.6, 4.20.3.7, 5.13.2.5 and 13.3.5 of the IGC Code in relation to the conduct of verifications and examinations required during the first full loading and unloading of the cargo. The unified interpretation is to be applied to all ships carrying liquefied gases in bulk.

CCC 8/12/4 proposes an interpretation of the requirements for additional self-contained breathing apparatus contained in SOLAS chapter II-2 and the IMSBC Code.

CCC 8/12/5 discusses issues identified with new building ships designed to be LNG bunkering ships, which, due to their operational particularities, are fitted with cargo transfer equipment in addition to the traditional cargo manifolds; the document proposes a draft unified interpretation to address those issues.

CCC 8/17/2 seeks clarifications of the application of paragraphs 11.3.1 and 11.3.2 of the IGF Code regarding fire protection of fuel preparation rooms (FPR) facing fuel tank(s) on deck, providing two possible views for the Sub-Committee to clarify the application of A-60 insulation as required by paragraph 11.3.2 of the IGF Code to the boundaries of the FPR could depend on the understanding an application of the of the requirements in paragraph 11.3.1 of the IGF Code.

IACS will also contribute to the discussions under agenda items 8 (Revision of the revised recommendations for entering enclosed spaces aboard ships (resolution A.1050(27))), and 13 (Development of Guidelines for the safety of ships using ammonia as fuel).

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

The event, which will be the 14th EUW will be held at Brewers’ Hall, London over 1.5 days, Tuesday 29 November and the morning of Wednesday 30 November.

IACS’ annual End User Workshop (EUW) is an event that brings together all key stakeholders of the QSCS. Attendees typically comprise all IACS members, all Accredited Certification Bodies (ACBs) that audit IACS members, as well as representatives from flag Administrations, the European Commission, the European Maritime Safety Agency (EMSA), QACE, any non-IACS classification societies that are interested in adopting QSCS voluntarily or with a view to applying for membership of IACS, and from ACBs that may be interested in auditing against IQMSR.

The format of the workshops is designed to promote free and open discussion with a view to maintaining the robustness, integrity, and consistency of the scheme. To promote discussion, stakeholders are given the freedom to feedback and reflect on their experiences of working in or with the QSCS and to propose and discuss any possible adjustments deemed appropriate to ensure QSCS continues to meet fully the demands and needs of all stakeholders for a robust and consistent scheme that is now widely recognised within the shipping industry as the ‘gold standard’ for classification societies and certification of IACS members.

After 2 years of remote workshops, IACS is finally looking forward to returning to a face-to-face workshop with lots of open and interesting discussions.

Organisations or individuals that have a clear interest in IACS QSCS and would like to participate in the upcoming End User Workshop should contact IACS Quality Secretary, Jonathan Spremulli at qscs.ops@iacs.org.uk

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 106/3/3 requests the Committee to confirm the understanding of the intended meaning of the terms “fitted”, “provided”, “installed” or “installation” used within the text, when preparing new mandatory instruments, non-mandatory instruments or when amending existing ones.  In addition, the paper proposes to clarify the term “building contract” and amend MSC.1/Circ.1500/Rev.1 to this effect.

MSC 106/11/1 considers the draft amendments to paragraph 4.4.7.6.17 of the LSA Code as agreed by SSE 7 which deletes paragraph 4.4.7.6.8 of the Code in the context of single-fall hook systems. After re-considering the text it was concluded that the deletion of exemptions to paragraph 4.4.7.6.8 would mean that this paragraph -is now applicable to off-load hooks as well, which is an unintended consequence. The co-sponsors consider that the application of paragraph 4.4.7.6.8 is not appropriate to some mechanically simplistic off-load hooks with few moving parts, i.e., a solid hook with a spring-loaded guard on the hook mouth.

MSC 106/11/2 proposes to modify the draft revised MSC.1/Circ.1315 to include an application statement pertaining to the phrase “installed on or after” and to revise the requirement for onboard discharge testing of fixed dry chemical powder fire-extinguishing systems so as to provide consistency with section 11.4.8 of the IGC Code (including its unified interpretation as per MSC.1/Circ.1617).

MSC 106/11/4 proposes amendments to the draft guidelines for lifting appliances and to the draft guidelines for anchor handling winches to address technical concerns and propose editorial improvements.

MSC 106/11/5 seeks confirmation from the Committee on whether fluorine-free and PFOS-free foam concentrates are to be considered as the only acceptable alternatives to the soon to be prohibited perfluorooctane sulfonic acid (PFOS) fire-extinguishing media on board ships.  The potential need to revise circular MSC.1/Circ.1312, to remove any references to fluoroprotein foam concentrates is also highlighted in the paper.

MSC 106/11/6 proposes to modify the draft amendments to SOLAS chapter II-2 and the 1994 HSC Code, which were finalized at SSE 8 and submitted to MSC 106 for approval, to prohibit the use of perfluorooctane sulfonic acid (PFOS) in firefighting equipment.

MSC 106/13/3 In order to facilitate global and uniform implementation, this document seeks clarification as to whether SOLAS regulation V/19.2.1.4 should be amended as a consequence of the adoption by MSC 106 of the draft revised Performance standards for electronic chart display and information systems (ECDIS).

MSC 106/13/4 proposes to include an application statement in the MSC resolution on the revised Performance Standards for electronic chart display and information systems (ECDIS), which was finalized at NCSR 9 and submitted to MSC 106 for adoption, with a view towards global and uniform implementation.

MSC 106/14/1 highlights the development of the International Quality Assessment Review Body (IQARB), the relevant discussions at III 8 and some of the causes underlying the major area of recurrent findings/observations from the IMSAS audits relating to delegation of authority and recognized organization (RO) oversight. In this context, it proposes that the III Sub-Committee and its Correspondence Group on the III Code Implementation Guidance be instructed to include, within that Guidance, text which will facilitate the use by flag States of IQARB Factual Statements as part of their RO oversight programme to demonstrate that their ROs have effective quality management systems in place.

MSC 106/18/3 discusses the applicability of resolution MSC.402(96) to the life-saving appliances installed on the high-speed crafts subject to the 1994 and 2000 HSC Codes, and on the mobile offshore drilling units subject to the 1979, 1989 and 2009 MODU Codes, with a view towards global and uniform implementation.

IACS will also contribute to the discussions under agenda item 5 (Development of a goal-based instrument for maritime autonomous surface ships (MASS)).

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

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 the following papers:

MEPC 79/4/6 proposes an interpretation of paragraph 4.10 of the Code for Approval of Ballast Water Management Systems (BWMS Code), to clarify that the interval for accuracy check/calibration of the BWMS components that take measurements should not be mandatorily linked to the survey scheme for the BWMS, as this should be performed in accordance with the calibration procedure at intervals specified in the manufacturer’s instructions.

MEPC 79/4/7 seeks clarification on the need for commissioning testing Ballast Water Management Systems (BWMS) which has undergone a major modification or an upgrade on board an existing ship in order to improve the performance of the BWMS and ensure the compliance with D-2 standard. Due to the existence of different interpretation on this matter, this document also proposes a unified interpretation of regulation E-1.1.5 and the Form of the International Ballast Water Management Certificate of the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (the BWM Convention)

MEPC 79/7/5 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 79/7/24 seeks clarification on several issues relating to the development and verification of SEEMP Part III and the issuance of the Statement of Compliance for the first year.  This document proposes unified interpretations of regulations 8.3, 26.3.1, 28.7 and 28.9 of MARPOL Annex VI, with the aim of achieving consistency in the application of this regulations.

IACS will also provide advice and comments to the Committee under agenda items 3 (Consideration of adoption of amendments to mandatory instruments), and agenda item 6 (Energy Efficiency of Ships).

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