Blog Archives

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 MSC 101:

• Amendments to the IGF Code. Paper MSC 101/3/9 provides proposals to clarify the draft amendments to paragraph 11.3.3bis of the International Code of Safety for Ship Using Gases or Other Low-flashpoint Fuels (IGF Code). In particular, the paper opines three is a need to clarify that two conditions need to be met for the fuel storage hold space to be considered as a cofferdam  e. the type C tank is not to be located directly above machinery spaces of category A or other rooms with high fire risk; and compliance with the specified minimum distance to the A-60 boundary. Paper MSC 101/3/10 proposes additional text to paragraph 9.5.6 of the Code in order to clarify that leakage detection for secondary enclosures is required around all liquefied fuel pipes.

• Goal-based new ship construction standards (GBS) for bulk carriers and oil tankers. Paper MSC 101/INF.13 provides updated reports on the status of the work to address the observations, in relation to Rules that are ‘common’ to all IACS Members, that were raised as a result of both the initial verification and the first maintenance of verification audit.

• Development of further measures to enhance the safety of ships relating to the use of fuel oil. Paper MSC 101/8 proposes a method of work, and items to be taken into account, when developing measures to enhance the safety of ships relating to the use of fuel oil. For issues that cannot be addressed by operational measures, IACS is of the view that some additional measures should be adopted to minimize the risks associated with the use of fuels onboard ships, especially in relation to fuel oil blends. The paper also proposes that a structured and evidence-based approach should be taken in order to justify any need to take regulatory action. Paper MSC 101/8/1 provides further clarification on IACS Unified Interpretation (UI) SC 123, which addresses the arrangements and capacities of fuel oil service tanks as per SOLAS regulation II-1/26.11. In particular, the paper clarifies that this UI was developed to clarify emergency changeover arrangements for different types of fuel oil service tank arrangements for vessels trading in Emission Control Areas (ECAs).

• Draft revised Model Agreement. Paper MSC 101/10/2 proposes amendments to both the draft revised Model Agreement (between an Administration and a Recognized Organization (RO)) and the associated draft MSC-MEPC.5 circular. The paper identifies that some of the terminology and provisions in the draft revised Agreement, which is before MSC 101 for its consideration, exceed the remit of ROs and could be detrimental to the conclusion of such Agreements. The paper also proposes that the issuance of this new circular should not affect the validity of extant Agreements that have either been concluded based on, or that refer to, MSC/Circ.710 and MEPC/Circ.307; or that have been already updated to refer to the Code for Recognized Organizations (RO Code).

• Procedure for identifying safety issues. Paper MSC 101/10/3 provides comments on the Procedure for identifying safety issues that was agreed at the last session of the Sub-Committee on Implementation of IMO Instruments (III 5). The paper proposes that the Procedure should be reviewed by the IMO Experts Group on Formal Safety Assessment. It is proposed that this analysis by experts, who have significant knowledge and experience in undertaking risk assessments, should particularly consider the risk assessment and acceptance criteria in the Procedure.

• Revised Guidance on shipboard towing and mooring equipment. Paper MSC 101/12/4 proposes modifications to the draft revised Guidance regarding the marking of the safe towing load (TOW) on equipment; and that the designer should consider verifying the adequacy of the strength of the ship’s tow line.

• Unified interpretations on ventilation system openings. Paper MSC 101/12/5 notes that, as currently drafted, the revised unified interpretation, which is before the Committee with a view to its approval, only pertains to “unprotected openings”. This ordinarily means openings that are not required to be fitted with closure devices.  Therefore, openings that are fitted with closure devices would not be covered by this draft revised interpretation.  However, for operational reasons, ventilators that must remain open to ventilate certain spaces should be evaluated as unprotected openings, even if fitted with closure devices. Consequently, the paper proposes the deletion of the word “unprotected” from the term “Unprotected openings” in the draft revised unified interpretation.

• Manual launching of rescue boats (paragraph 6.1.1.3 of the LSA Code). Paper MSC 101/14/5 proposes a simple, but important, editorial clarification to the draft amendment to the LSA Code that is before the Committee for finalisation. The proposal aims to avoid an internal conflict between the provisions in paragraph 6.1.1.3 of the LSA Code, i.e. between the “existing” and the draft “new” provisions.

• Unified Interpretation of SOLAS regulations II-1/28, II-1/29 and II-1/30 (steering systems). Paper MSC 101/14/6 proposes an amendment to the proposed application date (June 2019) of this draft unified interpretation, which is before the Committee for approval. The paper opines that designers, manufacturers and shipyards need to be properly informed in advance of the date of application of the unified interpretation so they are able to take due account of these new provisions. Consequently, the paper proposes an alternative application date of 1 January 2020.

• Equipment used in the simulated launching of free-fall lifeboats. Paper MSC 101/21/10 proposes a new output to develop design and prototype test requirements for the arrangements used in the operational testing of free-fall lifeboat release systems without launching the lifeboat (equipment used in the simulated launching of free-fall lifeboats).

• Harmonisation of mandatory requirements related to watertight doors on cargo ships. Paper MSC 101/21/16 proposes a new output to review the mandatory requirements in the SOLAS, MARPOL and Load Line Conventions and the IBC and IGC Codes regarding watertight doors on cargo ships, to address the inconsistencies that currently exist.

Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at permsec@iacs.org.uk

The RCP 1 and associated Technical Background document (TB) are available via the following links:

– Rule Change Proposal 1 (RCP 1)

– Technical Background document for RCP 1

IACS is pleased to announce that the 2018 IACS Annual Review is now available to download from our website at www.iacs.org.uk/about/iacs-annual-review-2018

It has been a notable year for the association, which celebrated its 50^th anniversary in 2018; you can read about our history inside the review (“A culture of standards excellence”). Other areas of interest include articles covering IACS’ ongoing work in key areas such as sulphur 2020, autonomous ships and cyber safety, as well as our other activities that help to establish and maintain the highest quality and safety standards, and the enduring relationships we continue to build and sustain internationally and with industry partners. The Annual Review also includes our ‘Class Report’ with data on the IACS fleet.

If you would like to receive a hard copy, please do not hesitate to contact us at permsec@iacs.org.uk

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 74:

MEPC 74/4/14 – this paper proposes amendments to the form of the International Ballast Water Management Certificate (IBWMC) to clearly describe the recording of alternative ballast water management methods as allowed for in the International Convention for the Control and Management of Ships’ Ballast Water and Sediments. The proposals in the paper are intended to facilitate the accurate recording of the applicable ballast water management method in the IBWMC.

MEPC 74/5 – this paper provides information related to the technical consequences on ship machinery design due to the implementation of the EEDI requirements.  The paper discusses issues such as: engine derating; the impact of operating for extended periods in the Barred Speed Range (BSR); the impact on shaft alignment tolerances; the effect on propulsion improving devices; maintaining the manoeuvrability of a ship in heavy seas; and if there is a need for new property values in the EEDI calculations to take account of the increasing use of alternative fuels.

MEPC 74/6/2 – this paper urges the Committee to begin its substantive consideration of the development of a methodology for the data analysis that is to be conducted by the Organization (phase 2 of a three-step approach to address GHG emissions). To facilitate this work, some potential analyses are suggested using the data that is currently required to be provided to the IMO Ship Fuel Oil Consumption Database (phase 1 of the three-step approach). Six draft performance indicators are proposed, and it is opined that the agreed performance indicators will facilitate the discussions in the decision-making step (phase 3 of the three-step approach).

MEPC 74/11/1 – this paper proposes amendments to both the draft revised Model Agreement and its associated draft MSC-MEPC.5 circular that were prepared by III 5.  The paper identifies that some of the terminology and provisions, which have been introduced by III 5, exceed the remit of recognised organisations and could be detrimental to the conclusion of such agreements between Administrations and recognized organizations. The paper proposes that the issuance of this new circular should not affect the validity of “in force” signed agreements that have been concluded based on, or that refer to, MSC/Circ.710 and MEPC/Circ.307 or that have been already updated to refer to the Code for Recognized Organizations (RO Code).

MEPC 74/14/5 – this paper informs MEPC 74 that MSC 101 (meeting in June 2019) will consider a proposal for a new output on the harmonisation of mandatory requirements related to watertight doors on cargo ships. These safety-related requirements are to be found in various IMO mandatory instruments, including the MARPOL Convention and the IBC Code – instruments that are within the purview of MEPC. This paper invites MEPC 74 to agree that, if MSC 101 endorses the new work programme, the MEPC should be shown as a coordinating organ in the 2020-2021 biennial agenda.

It is expected that MEPC 74 will focus its discussions on key issues related to air pollution and energy efficiency, and the reduction of GHG emissions from ships.

Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at permsec@iacs.org.uk

This version is composed of CSR 01 JAN 2018 Rules and its subsequent changes:

1) Rule Change Notice 1 to 01 JAN 2018

2) Corrigenda 1 to 01 JAN 2018

3) Corrigenda 2 to 01 JAN 2018

This document can be found on the IACS website through the following hyperlink :

http://www.iacs.org.uk/publications/common-structural-rules/csr-for-bulk-carriers-and-oil-tankers/

Papers on agenda items related to Life-Saving Appliance (LSA) issues: 

• SSE 6/3/2 proposes that in taking forward the development of functional requirements in the context of SOLAS Chapter III and the LSA Code, a HAZID or a study is carried out to identify the hazards addressed by the requirements of both instruments. The paper also proposes changes to the draft Guidelines on Alternative Design and Arrangements for SOLAS Chapter II-1 and III (MSC.1/Circ.1212) contained in paper SSE 6/3 (the report of an intersessional Correspondence Group), aiming to clarify and improve the use of quantitative terminology as required by the GBS guidelines (MSC.1/Circ.1394/Rev.1).
• SSE 6/5/1 provides comments on the draft Interim Guidelines on Life-saving Appliances and Arrangements for Ships Operating in Polar Waters contained in paper SSE 6/5 (the report of an intersessional Correspondence Group). IACS believe the guidelines should apply to new and existing ships and that further review is needed before SSE finalises this item.
• SEE 6/17/1 providing a proposal to resolve a discrepancy that will otherwise exist between the provisions regarding the testing of winches on free-fall lifeboats and non free-fall lifeboats as described in paragraph 8.1.1 of resolution MSC.81(70).

Papers on agenda items related Fire Protection issues:

• SSE 6/6/5 provides extensive comments on the draft Interim Guidelines for minimizing the incidence and consequences of fires on ro-ro spaces and special category spaces of new and existing ro-ro passenger ships (contained in SSE 6/6) covering the following areas: prevention/Ignition, detection and decision, extinguishment and containment.
• SSE 6/7/2 provides extensive comments on the draft amendments to the Guidelines for the approval of fixed dry chemical powder fire-extinguishing systems for the protection of ships carrying liquefied gases in bulk (MSC.1/Circ.1315) contained in paper SSE 6/7 (the report of an intersessional Correspondence Group).

Papers on Unified Interpretations:

• SSE 6/12 provides a draft revision of IACS UI SC242 on SOLAS regulations II-1/28, II-1/29 and II-1/30. The UI addresses the redundancy required in the steering gear system for each steerable propulsion unit. The UI also clarifies that for a ship fitted with multiple steering systems, the requirements in SOLAS regulation II-1/30.2 are to be applied to each of the steering systems.
• SSE 6/12/1 proposes a unified interpretation to clarify the term “explosion-proof type or intrinsically safe” in the context of SOLAS regulation II-2/10.10.4 (requirements for two-way portable radiotelephone apparatus for fire-fighter’s communication) to avoid inconsistencies on the application of this requirement.
• SSE 6/12/2 seeks clarification whether free-fall lifeboats launching requirements are to comply with the requirements to launch lifeboats with the ship making headway at speeds up to 5 knots in calm water as required by SOLAS regulation III/3.2 and the LSA Code.
• SSE 6/12/3 proposes a unified interpretation to clarify the number of lifebuoys fitted with a buoyant lifeline that are to be provided in the vicinity of the ship’s means of embarkation as required by SOLAS regulation II-1/3-9 and MSC .1/Circ.1331.
• SSE 6/12/4 proposes a unified interpretation to clarify that the weather deck area above the fuel oil tanks installed at the after end of the aftermost hold space or at the forward end of the forwardmost hold space, are to be considered a “cargo area” when applying the IGC Code requirements for piping and fittings in the water-spray system withstanding 925^°
• SSE 6/12/5 proposes a unified interpretation of SOLAS regulation II-1/47 on fire detection and alarms for boilers in unattended machinery spaces. The UI intends to clarify the meaning of “inherent fire risk in exhaust uptake” and in “air supply casing: and the application of this regulation to different types of boilers.
• SSE 6/12/6 seeks clarification on determining the fire integrity of divisions when urea or sodium hydroxide solutions tanks, forming part of NOx and SOx emission control systems, are installed in a space separated from the engine room, to be categorised as “voids and auxiliary machinery spaces having little or no fire risk” or as “other machinery spaces”.
• SSE 6/12/7 (co-sponsored with SIGTTO) provides a draft interim unified interpretation to clarify that the initial onboard testing of a dry chemical powder fire-extinguishing system should be carried out by discharging dry chemical powder from all monitors and hand hose lines; but that this does not require the full discharge of the installed quantity of dry powder. Thereafter, the system should be blown through with dry air.
• SSE 6/12/8 provides a draft unified interpretation to clarify that the footnote to SOLAS regulation II‑2/9.7.5 regarding the protection of galley ducts, does not prohibit the use of a fixed CO₂ fire-extinguishing system that hasn’t been designed or tested to ISO 15371-2009.
• SSE 6/12/9 provides revision 2 of IACS UI SC269 providing clarification on the escape arrangements to the open deck from the steering gear space on cargo ships of less than 150 m in length.
• SSE 6/12/10 provides a copy of IACS UI SC288 on SOLAS regulations II-2/19.3.4.1 and II‑2/19.3.5.4 regarding the reduction in air changes to ventilate a cargo space where dangerous goods of class 2, 3, 4 liquids, 5.1 liquids, 6.1 and 8 are carried in closed freight containers and where the bilge pump is also located.
• SSE 6/12/11 provides a copy of IACS UI MODU3 that clarifies the term “after shutdown” in paragraph 6.5.5 of the 2009 MODU Code i.e. for Emergency Shutdown (ESD) systems arranged with multiple levels of ESD, the provision in this paragraph of the Code applies for any ESD level related to gas release.
• SSE 6/12/12 provides a copy of IACS UI SC 289 related to the FSS Code separation arrangements between inert gas piping systems in cargo tanks.
• SSE 6/12/13 provides a copy of IACS UI SC290 to clarify that the requirements in the IBC Code and the IGC Code related to emergency sources of electrical power should also be taken into account, when applying SOLAS regulation II-1/43.6.

IACS will also provide advice and comments to the Sub-Committee on almost all of the other issues that will be considered at SSE 6. In particular, IACS will contribute to the discussions on the following items:

• Develop new requirements for the ventilation of survival craft (agenda item 4)
• Amendments to chapter 9 of the FSS Code for fault isolation requirements for cargo ships and passenger ship cabin balconies fitted with individually identifiable fire detector systems (agenda item 8)
• Requirements for onboard lifting appliances and anchor handling winches (agenda item 9)
• Development of guidelines for cold ironing of ships and consideration of amendments to SOLAS chapters II-1 and II-2 (agenda item 11)
• Amendments to paragraph 4.4.7.6.17 of the LSA Code concerning single fall and hook systems with on-load release capability (agenda item 13)

Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at permsec@iacs.org.uk

The International Association of Classification Societies is pleased to announce the release of the Jan 2019 edition of the IACS Blue Book and the accompanying IACS Green Book. Together these publications summarise the technical output of IACS and, as such, continue to demonstrate IACS’ technical support to the shipping industry through our work and investment in technology, innovation, research and development both at the classification and statutory levels.

The IACS Green Book is designed for daily use and contains all current IACS Resolutions and Recommendations as well as their History and Technical Background. The Green Book is updated whenever a new or revised IACS Resolution or Recommendation is uploaded on the IACS website making it the ideal reference document for anyone wishing to refer to current IACS Resolutions. Because the Green Book only contains current material the file-size is more manageable and so better suited to be downloaded and used in the field.

The IACS Blue Book meanwhile, is an electronic library of all technical resolutions adopted by IACS as a result of its technical work and remains the core reference work for the Association containing, as it does, all previous revisions of IACS publications and historical data. It is updated and published once a year. Together, these IACS publications illustrate well how the aims and objectives of IACS are delivered for the benefit of international shipping and contain:

• IACS Unified Requirements which IACS members incorporate into their Rules
• Unified Interpretations of IMO convention requirements which IACS Members apply uniformly when acting on behalf of authorizing flag Administrations, unless instructed otherwise
• Procedural Requirements governing practices among IACS Members
• Recommendations relating to adopted resolutions that are not necessarily matters of Class but which IACS considers would be helpful to offer some advice to the marine industry
• Quality Documents containing QSCS (IACS’ Quality System Certification Scheme) description, Quality Management System Requirements, Audit Requirements, ACB (Accredited Certification Bodies) requirements and other quality procedures
• IACS Charter and IACS Procedures which define the purpose, aim and working procedures of the Association

These publications are of interest to Ship Designers, Consultants, Shipbuilders, Classification Societies, Ship-owners, Shipbrokers, Insurers, Associations, Accredited Certification Bodies, flag States, Port State Control, MOUs and the shipping industry at large and are available for download, free of charge, at www.iacs.org.uk/publications

• PPR 6/11/5 IACS provides comments on the proposed draft amendments to the 2015 Guidelines for Exhaust Gas Cleaning Systems (EGCS) contained in Annex 2 of the Correspondence Group report (PPR 6/11). The paper addresses the following issues: the conduct of environmental testing as part of the approval of the system; the monitoring system for daily spot checks of the exhaust gas monitoring system; the prevention of exhaust gases leak from the damper of a bypass line; the function that should be provided to the data recording and processing device; how non-compliant reports are clearly identifiable; addressing the washwater drain in the provisions regarding discharge water; and how “open-loop scrubbers” without treatment equipment are addressed in the Guidelines.

• PPR 6/16 IACS has developed and finalized an update to its Unified Interpretation (UI) MPC98 regarding the phrase “time of the replacement or addition of the engine” in regulation 13.2.2 of MARPOL Annex VI. This update reflects resolution MEPC.286(71) that adopted amendments to MARPOL Annex VI designating the Baltic Sea and the North Sea ECAs as NOx Tier III emission control areas. IACS has modified the text of the UI to negate the need for any further consequential changes if more NOx Tier III emission control areas are designated in the future.

• PPR 6/16/3 IACS seeks clarification on the recording requirements with regard to the engine operating status as required by regulation 13.5.3 of MARPOL Annex VI. IACS seeks clarification from PPR 6 as to whether the recording requirement in regulation 5.3 of MARPOL Annex VI applies to replacement engines (Tier II) subject to resolution MEPC.230(65), after the relevant NOx Tier III emission control area takes effect.  IACS offers a draft unified interpretation to facilitate global and consistent implementation of this regulation.

IACS will also provide advice and comments to the Sub-Committee, both in plenary and the Working and Drafting Groups that will be established, on a number of issues. In particular, IACS will contribute to the discussions on:

• Revised Guidance on Ballast Water Sampling and Analysis (agenda item 4)
• Consideration of the impact on the Artic of emissions of black carbon from international shipping (agenda item 7)
• Consistent implementation of regulation 14.3 of MARPOL Annex VI (agenda item 8)
• Standards for Shipboard gasification of waste systems and associated amendments to Regulation 16 of MARPOL Annex VI (agenda item 10)
• Review of the 2015 Guidelines for Exhaust Gas Cleaning Systems (Resolution MEPC.259(68)) (agenda item 11)
• Amendments to the 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants (Resolution MEPC.227(64)) to address inconsistencies in their application (agenda item 14)
• Ammonia emissions from marine diesel engines equipped with SCR systems (agenda item 19)

Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at permsec@iacs.org.uk

• SDC 6/3/4 – comments on the report of the Correspondence Group on Safe Mooring Operations and opines that, to facilitate the global and consistent implementation of these new provisions, either the draft new SOLAS regulation II-1/3-8.7 and the supporting guidance could be revised; or the HSSC survey guidelines could be revised. IACS prefers the latter proposal rather than adding more prescriptive content to the draft guidelines;

• SDC 6/4/2 – proposes a minor correction to SOLAS regulation II-1/17-1.1.1 (Integrity of the hull and superstructure, damage prevention and control on ro-ro passenger ships) to clarify the current ambiguity which causes confusion when interpreting how vehicles can be loaded into spaces below the bulkhead deck;

• SDC 6/4/3 – proposes amendments to SOLAS regulations II-1/13.5.1 and II‑1/13.6 (Watertight door remote control positions) to extend the remote operating positions, from the navigation bridge and the location above the bulkhead deck, to other locations in light of the requirement in SOLAS regulation II-2/23.6 (Safety centre on passenger ships) and the available computer technologies;

• SDC 6/7, SDC 6/7/Add.1, Add.2 and Add.3 – provides a draft new consolidated version of the International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers (ESP Code). This paper is co-sponsored by IACS and the IMO Secretariat;

• SDC 6/9 – proposes further clarifications to the unified interpretation of paragraph 3.4.2 of part B of the 2008 IS Code, as provided in MSC.1/Circ.1537, regarding the assumptions for calculating loading conditions;

• SDC 6/9/1 – provides an update of IACS Unified Interpretation (UI) SC156 on doors in watertight bulkheads of cargo and passenger ships that takes account of recent amendments to SOLAS Chapter II-1 and the associated Explanatory Notes;

• SDC 6/9/3 – provides a draft unified interpretation of SOLAS regulations II‑1/22-1 and II-2/21.4.13 regarding safe return to port requirements for flooding detection systems; and

• SDC 6/9/4 – provides the latest version of IACS UI SC123 that addresses service tank arrangements for low sulphur distillate and residual grade fuel oils; fuel switchover; and definitions of the type of fuel oil (SOLAS regulation II‑1/26.11).

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

• Revised SOLAS regulation II-1/3-8 and associated guidelines (MSC.1/Circ.1175) and new guidelines for safe mooring operations for all ships;

• Review of SOLAS Chapter II-1, Parts B-2 to B-4, to ensure consistency with Parts B and B-1 with regard to watertight integrity;

• Finalization of second generation intact stability criteria; and

• Mandatory instrument and/or provisions addressing safety standards for the carriage of more than 12 industrial personnel on board vessels engaged on international voyages.

Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at permsec@iacs.org.uk

IACS has submitted 2 papers to this meeting on the following issues:

• A draft unified interpretation concerning the requirements in chapter 10 of part I-A of the Polar Code, regarding the communication equipment in survival craft and rescue boats that is intended to operate in low air temperatures (NCSR 6/19)
• Identification of apparent gaps in MSC.1/Circ.1040/Rev.1 regarding the testing of the float-free recording medium capsule in voyage data recorder systems as per resolution MSC.333(90). IACS also proposes consequential amendments to MSC.1/Circ.1222 (Guidelines on annual testing of voyage data recorders (VDR) and simplified voyage data recorders (S-VDR)) (NCSR 6/22/1)

IACS will also provide advice and comments to the Sub-Committee, and contribute to the discussions on matters related to:

• The draft general guidance for navigation and communication equipment intended for use on ships operating in polar waters.
• The revision of SOLAS Chapters III and IV for modernization of the global maritime distress and safety system (GMDSS), including related and consequential amendments to other existing instruments.

Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at permsec@iacs.org.uk