€¦ · Web viewWG 1Working Group on goal-based standards (agenda item 6) WG 2Working Group on Maritime Autonomous Surface Ships (agenda item 5) [WG 3]Working Group on safety

WG 1 Working Group on goal-based standards (agenda item 6)WG 2 Working Group on Maritime Autonomous Surface Ships (agenda item 5)[WG 3] Working Group on safety measures for non-SOLAS vessels operating in

Polar waters (agenda item 7)DG 1 Drafting Group on amendments to mandatory instruments (agenda item 3)[ACAG] Capacity-building Needs Analysis Group

ITEM 1: ADOPTION OF THE AGENDA; REPORT ON CREDENTIALS

The ninety-ninth session of the Maritime Safety Committee (MSC 99) will be held at IMO Headquarters, 4 Albert Embankment, London SE1 7SR from Wednesday, 16 to Friday, 25 May 2018.

The session commences at 9.30 a.m. on Wednesday, 16 May 2018

Papers:

1 Provisional Agenda Secretariat

The Secretariat provides the provisional agenda for MSC.

1/1 Annotations to the provisional agenda Secretariat

The Secretariat provides supplementary information relating to the provisional agenda.

1/2 Arrangements for working and drafting groups at MSC 99

Secretariat

The Secretariat advises that the following working and drafting groups are expected be established at this session:

1. Working Group on Goal-based Standards;2. Working Group on Maritime Autonomous Surface Ships;3. Drafting Group on Amendments to Mandatory Instruments; and4. Working Group on Safety Measures for non-SOLAS Vessels Operating

in Polar Waters.

ICS Members attending the meeting on national delegations or as part of the ICS delegation are requested to inform the secretariat of any working groups that they plan to attend.

Members wishing to raise any issue during MSC 99 are invited to contact the ICS desk in plenary.

ITEM 2: DECISIONS OF OTHER IMO BODIES

The Committee will be informed of any relevant decisions of the:

1. 118th and 119th regular and twenty-ninth extraordinary sessions of the Council;2. Thirtieth session of the Assembly; 3. Seventy-first session of the Marine Environment Protection Committee;4. Sixty-seventh session of the Technical Cooperation Committee,

and will be invited to take action as appropriate.

Papers:

2 Outcome of C118 and C/ES.29 Secretariat

The IMO Secretariat provides the outcome of C 118, C 119 and C/ES.29.

Items reported to the Committee relate to:

Agenda item 2 – Decisions of other IMO bodies Agenda item 9 – Implementation of IMO instruments Agenda item 17 – Piracy and armed robbery against ships

2/1 Outcome of A30 Secretariat

The IMO Secretariat reports on decisions of the thirtieth session of the Assembly.

Items reported to the Committee relate to:

Consideration of the reports and recommendations of the Maritime Safety Committee;

Resolutions related to maritime safety Resolutions related to maritime safety and marine environment protection Strategy, planning and reform IMO Member State Audit Scheme

2/2 Outcome of MEPC 71 Secretariat

The IMO Secretariat provides information on 8 outcomes of interest to the Committee from MEPC 71. Actions requested of the Committee include:

Action 2.1 Note that MEPC 71 agreed, with a view to ensuring that safety aspects are adequately covered, to keep MSC informed of the ongoing work that MEPC is conducting in relation to the amendments to the 2013 Interim guidelines for determining

minimum propulsion power to maintain the manoeuvrability of ships in adverse conditions (resolution MEPC.262(68));

Action 2.5 Note that MEPC 71 approved a unified interpretation of regulation 1.23 of MARPOL Annex I (MEPC.1/Circ.872) regarding the use of even-keel hydrostatics for determination of the regulatory deadweight to be entered on relevant statutory certificates, corresponding to MSC.1/Circ.1573;

Action 2.6 Note that MEPC 71 added, in the scope of the proposed new output on "Consistent implementation of regulation 14.1.3 of MARPOL Annex VI", consideration of the safety implications relating to the option of blending fuels in order to meet the 0.50% m/m sulphur limit and instructed the PPR Sub-Committee to report to MSC any safety issues that may be identified with regard to low-sulphur oil fuel

Details of all 8 actions requested of the Committee can be found in paragraph 2 of the submission and also paragraph 17.4 of MEPC 71/17.

2/3 Outcome of TC 67 Secretariat

The IMO Secretariat reports the outcome of the sixty seventh session of the Technical Cooperation Committee (TCC). The Committee’s attention is drawn to two agenda items as follows:

Agenda item 2 – Decisions of other IMO bodiesIntegrated Technical Cooperation Programme (ITCP): Annual report for 2016.

The 2030 Agenda for Sustainable Development

Agenda item 19 – Implementation of IMO instrumentsVoluntary IMO Member State Audit Scheme and IMO Member State Audit Scheme

2/4 Outcome of MEPC 72 Secretariat

The IMO Secretariat provides information on 5 outcomes of interest to the Committee from MEPC 72. Actions requested of the Committee include:

Action 2.1 Note that the Committee adopted, by resolutions MEPC.302(72) and MEPC.303(72), amendments to the IBC Code and BCH Code, respectively, related to the Model form of the Certificate of Fitness for the Carriage of Dangerous Chemicals in Bulk, which are expected to enter into force on 1 January 2020.

ITEM 3: CONSIDERATION AND ADOPTION OF AMENDMENTS

TO MANDATORY INSTRUMENTS

Amendments to the 1974 SOLAS Convention and associated instrumentsThe Committee will consider, for adoption, draft amendments to chapters II-1, IV and Appendix of SOLAS, 1974, as amended, and to the 2010 FTP, 1994 HSC, 2000 HSC, IBC, IGC, 2008 IS and IMDG Codes.

Amendments to the Protocol of 1988 relating to the International Convention on Load Lines, 1966 (1988 Load Lines Protocol)The Committee will consider, for adoption, draft amendments to the 2008 IS Code.

Papers:

3 Amendments to the 1974 SOLAS Convention and associated instruments

Secretariat

The expanded Committee (i.e. All Contracting Governments to the 1974 SOLAS Convention) will consider for adoption the draft amendments detailed in the annexes to the document. The amendments concerned were previously approved by the Committee at MSC 98 and relate to:

1. Chapters II-1 and IV of, and the appendix to, the International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended;

2. The International Code for Application of Fire Test Procedures, 2010 (2010 FTP Code);

3. The International Code of Safety for High-speed Craft, 1994 (1994 HSC Code);

4. The International Code of Safety for High-speed Craft, 2000 (2000 HSC Code);

5. The International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code);

6. The International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code); and

7. The International Code on Intact Stability, 2008 (2008 IS Code).

3/Add.1

Amendments to the International Maritime Dangerous Goods (IMDG) Code

Secretariat

The Committee is invited to consider and adopt the draft amendments (39-18) to the International Maritime Dangerous Goods (IMDG) Code (resolution MSC.122(75)), which were agreed by the Sub-Committee on Carriage of Cargoes and Containers (CCC 4).

It is advised that the proposed amendments have been circulated under cover of Circular Letter No.3776 of 26 September 2017.

3/Add.2

Revised Emergency Response Procedures for Ships Carrying Dangerous Goods

Secretariat

The Committee is advised that CCC 4, following the instructions of MSC 96, instructed E&T 28 to finalize the consolidated Revised Emergency Response Procedures for Ships Carrying Dangerous Goods (EmS Guide).

The draft EmS Guide as revised by E&T 28 and its associated MSC circular are set out in the annex to the paper. The Committee is invited to consider the draft Guide and associated circular, with a view for approval in conjunction with the draft amendments to the IMDG Code (MSC 99/3/Add.1).

3/1 Amendment to part A of the International Code on Intact Stability, 2008

Secretariat

The expanded Committee (i.e. All Parties to the 1988 Load Lines Protocol) will consider for adoption a draft amendment to part A of the International Code on Intact Stability, 2008 (2008 IS Code) as detailed in the annex to the document. The Secretariat advises that the amendment concerned was previously approved by the Committee at MSC 98 and circulated.

3/2 Amendments to the 2008 SPS, BCH, EGC and GC Codes

Secretariat

The Secretariat provides the text of draft amendments to the following:

The Record of equipment for the Special Purpose Ships Equipment Certificate (Form SPS). This is a consequential amendment reflecting amendments to SOLAS chapter IV which allow for the use of recognised mobile satellite services other than Inmarsat; and

The Certificates of Fitness under BCH, EGC and GC Codes. These amendments provide requirements relating to loading conditions, including on ships which are not fitted with an approved stability instrument.

Adoption is anticipated at this session. Application of the amendments in this document is anticipated to be from 1 January 2020.

Regarding the amendments to the BCH Code, these were also adopted at MEPC 72.

3/2/Add.1

Amendment to the Record of Equipment of theCode of Safety for Special Purpose Ships

Secretariat

The Secretariat provides the text of a draft amendment to the Record of Equipment of the SPS Code, for approval in conjunction with the adoption of the corresponding amendments to SOLAS chapter IV and the appendix (Certificates).

The Secretariat has identified that previous amendments to the SPS Code have been made by both MSC resolutions and MSC circulars. It is advised that amendments to the SPS Code by resolution should be the normal practice.

Consequently, the Secretariat proposes to reissue circulars MSC/Circ.478 and MSC/Circ.739 as resolutions, and provides the required draft texts.

No substantive amendments are made to the content of circulars MSC/Circ.478 and MSC/Circ.739.

3/3 Draft amendments to MSC.1/Circ.1500 and draft MSC circular on the procedural aspects related to the drafting of amendments to safety-related IMO conventions, other thanthe 1974 SOLAS Convention, and related mandatory instruments

Secretariat

The Secretariat proposes draft amendments to MSC.1/Circ.1500 and the draft MSC circular on the procedural aspects related to the drafting of amendments to safety-related IMO conventions, other than the 1974 SOLAS Convention, and related mandatory instruments, prepared by the Secretariat in accordance with the request of MSC 98.

The Secretariat, after thorough consideration concludes that the inclusion of new provisions for keeping records for regulatory development for other safety-related IMO conventions might complicate MSC.1/Circ.1500 and make it less user-friendly.

In this context, the Secretariat is of the view that the most straightforward solution would be to:

1. Amend MSC.1/Circ.1500 as per the decisions in paragraphs 7 and 8, information in paragraph 11, and with a view to updating references and introducing editorial modifications, as necessary; and

2. Develop a new separate MSC circular on the procedural aspects related to the drafting of amendments to safety-related IMO conventions, other than the 1974 SOLAS Convention, and related mandatory instruments, based on chapter 3 of the Guidance (MSC.1/Circ.1500).

The Committee is invited to:

1. Endorse the proposed way forward;2. Consider the draft amendments to MSC.1/Circ.1500 and the draft MSC

circular on the procedural aspects related to the drafting of amendments to safety-related IMO conventions, other than the 1974 SOLAS Convention and

3. Take action as appropriate.

ITEM 4: MEASURES TO ENHANCE MARITIME SECURITY

The Committee will consider any relevant submissions by Member States and international organizations regarding maritime security, including:

1. The review of model course 3.24 on Security Awareness Training for Port Facility Personnel with Designated Security Duties, with a view to validation;

2. Final draft procedures and conditions for the electronic transfer of information into the Maritime Security module of GISIS,

and may establish a working group on maritime security.

Papers:

4 Validation of model courses related to maritime security

Secretariat

The Secretariat document provides the revised model course 3.24 on Security awareness training for port facility personnel with designated security duties,developed by a review group under the coordination of Malaysia. The revised model course is provided at annex 1 to the paper.

The Committee is invited to note the information contained in this document in general and, in particular:

1. Validate the revised model course 3.24 on Security awareness training for port facility personnel with designated security duties for final editorial review by the Secretariat and subsequent publication;

2. Instruct the HTW Sub-Committee to take into account the revised model course 3.24 when conducting the revision of model courses 3.19, 3.26 and 3.27; and

3. Decide whether to establish further review groups for the revision of model courses 3.20, 3.23 and 3.25, or whether to delegate the future review and validation of all model courses related to maritime security to the HTW Sub-Committee.

4/1 Updates on recent developments related to maritime security

Secretariat

The Secretariat provides information on the submission of security-related information through the Maritime Security module of the Global Integrated Shipping Information System (GISIS), including the electronic transfer of information into the module. It is noted that 28% of all registered port facilities require an update of the security-related information currently available, particularly as regards reviews or approvals of port facility security plans at five-year intervals

The document also provides information on counter-terrorism measures and the new UN Global Counter-Terrorism Coordination Compact; the number of States that have acceded to the SUA 2005 Protocols; a review of administrative requirements and; technical cooperation related to the enhancement of maritime security measures

4/2 Review of resolution MSC.312(88) on Revised guidelines on the prevention of access by stowaways and the allocation of responsibilities to seek the successful resolution of stowaway cases

Secretariat

The Secretariat provides the revised version of resolution MSC.312(88) on Revised guidelines on the prevention of access by stowaways and the allocation of responsibilities to seek the successful resolution of stowaway cases, as amended by the Facilitation Committee at its 41st session and, the Committee is invited to note the minor amendments made to the draft and take action as appropriate.

4/3 Non-ISPS vessels and port facilities Islamic Republic of Iran

The Islamic Republic of Iran describes the security conditions and threats for vessels and port facilities that are not subject to the ISPS Code and, proposes measures to be taken by the Organization, Member States and vessels to promote security and prevent unauthorised access for the vessels and ports concerned.

ITEM 5: REGULATORY SCOPING EXERCISE FOR THE USE OF MARITIME AUTONOMOUS SURFACE SHIPS

The Committee will consider matters related to the Regulatory scoping exercise for the use of Maritime Autonomous Surface Ships (MASS) (MSC 99/5), any other documents submitted by Member States and international organizations under this agenda item.

As decided at MSC 98, a working group on maritime autonomous surface ships will be established.

Papers:

5 Comments on the regulatory scoping exercise Secretariat

The Secretariat provides comments on the regulatory scoping exercise for the use of Maritime Autonomous Surface Ships (MASS). In addition, actions are proposed for consideration by the Committee to guide future work on MASS.

The comments and proposed actions focus on procedural and coordination matters both within, and outside the IMO.

Of particular note are the following actions:

Development of a preliminary glossary of terms; Consideration of a comprehensive analysis of the best way of

introducing the concept of MASS in IMO instruments; Development of a work plan for the scoping exercise; and Development of a roadmap and work plan for any work after the

scoping exercise.

It is reported that a cross-divisional MASS taskforce has been established to coordinate the work between the different bodies of the Organization.

Member States and international organisations are reminded that further work (outputs) on MASS after the completion of the regulatory scoping exercise would need to be approved by the Committee.

The Secretariat provides information of a procedural nature. However, the content demonstrates that the Secretariat understands the complexity of the work that may need to be undertaken, and the need to effectively facilitate this work.

ICS can support the detailed consideration of all the matters included in this document. It is anticipated that the Committee will seek the advice of the WG which will be established at this session, before concluding on any of the matters.

It may also be noted that the decisions relating to some of the proposed actions will come with cost implications for member States and would require approval from Council. This will determine the time and resources available for considering MASS. This may impact the following:

The anticipated pace of discussions; The level of detail in the discussions; and The level of engagement by member States. In this regard, ICS seeks

the highest possible level of engagement by member States and international organizations in document MSC 99/5/2.

5/1 Comments and proposals on the way forward for the regulatory scoping exercise

IFSMA and ITF

The co-sponsors provide comments and proposals for the regulatory scoping exercise. It is proposed that any work plan should consider:

Matters relating to UNCLOS, including consultation with the UN Division for Ocean Affairs and the Law of the Sea;

The need to engage MEPC, FAL, LEG and all MSC Sub-Committees to scope the potential human element and technical impacts of MASS;

The need to address the unique challenges that MASS presents and not to limit consideration to the removal of regulatory barriers to MASS;

Identification of the human element components within autonomous and automated systems, their functions and means of ensuring competency and accountability.

It is considered that national trials by some member States not be considered as validating the feasibility of unmanned or remotely operated ships worldwide. This reflects the use of small vessels under strictly controlled conditions.

It is further noted that the technology for unmanned ships is being promoted on an aspirational, rather than evidence led, basis. In this regard, the regulatory framework should not be hastily put in place to meet the needs of manufacturers. The urgency of any work on this matter is questioned.

The co-sponsors further consider that:

The target completion date for this work item should be extended to 2023. This reflects an assessment of the anticipated volume of work actually required; and

To protect international shipping, the Organization should establish that remotely-controlled or unmanned ships are not in compliance with existing international regulations and are not permitted to operate on

international voyages.

This submission follows up on document MSC 98/20/13 (ITF). The submission is the only document which considered UNCLOS and responds to the action identified by the Secretariat in paragraph 12.4 of MSC 99/5.

A number of the comments made, and proposed actions, are aligned with those in the ICS submission (MSC 98/5/2). However, the proposals for extension of the work item and for the IMO to prohibit the use of remotely-controlled or unmanned ships are not in compliance with IMO instruments are not.

The submission does not appear to recognise that the operation of remotely controlled and autonomous vessels (less than 24m) already takes place. Therefore, there is compelling need for this work to ensure that, even within TTW, interactions between such vessels and international shipping are managed appropriately.

Whilst appreciating that the work involved is likely extensive, whether an extension is required is less clear. It will depend on the extent to which assessments of IMO instruments presented in substantive and information papers to this session can be agreed as a basis for the work. The Committee will not start from scratch. An extension, if required, will be a matter for the Committee to consider in 2020.

A clear statement from the IMO to prohibit the use of remotely-controlled or unmanned ships whilst understandable, may be unnecessary. The SOLAS provisions for ships which embody features of a novel kind (SOLAS regulation I/4 (b)) do not permit exemption from SOLAS chapter V requirements, including the provisions for safe manning in SOLAS regulation V/14.

Moreover, in order to address the concerns raised in paragraph 15 of the submission regarding current trials, international trials of the technology may be required. Evidence from these will be an important factor in informed decision making by the Committee. Action to prohibit use could be counterproductive.

ICS can support further consideration of the submission by ITF and IFSMA in the WG, with exception of the proposals in paragraphs 20.7, 20.8 and the annex.

5/2 Proposals for the development of a work plan ICS

ICS appreciates all submissions under this agenda item and is pleased to introduce document MSC 99/5/2 providing proposals for the development of a work plan.

Paragraphs 2 to 5 provides the ICS perspective on the need for the regulatory scoping exercise. We consider that there will be a transition towards increasing use of autonomous systems on ships, but there is unlikely to be rapid, and widespread adoption of MASS, particularly unmanned MASS.

Paragraph 6 emphasises the purpose of the scoping exercise: to enable the Committee to make informed decisions regarding the regulation of MASS.

Paragraphs 7 to 10 provide an analysis of two alternative approaches to the regulatory scoping exercise. Both are based on the original tasks described in MSC 98/20/2. However, a preference is expressed for a holistic approach which considers both the regulations themselves and the approaches and regulatory tools used.

Paragraphs 11 to 13 elaborate on human element matters in the context of an approach to managing the process of change that adoption of autonomous systems represents. Specifically, the evolving skills and knowledge that may be required, and new challenges that the use of autonomous systems can be expected to present. This includes whether the STCW Convention in its current form can support safe operation of ships which use autonomous systems in cooperation with human decision making.

Whilst ICS does not give priority to the discussion on definitions, it is noted in paragraph 14 that we consider it appropriate to exclude consideration of manning from discussions on a definition. This reflects the view that it is premature to consider specific manning levels for ships using autonomous systems.

Paragraph 15 considers procedural matters relating to the approach to regulating autonomous systems. This is focused on the need to support informed decision making with evidence and data collection regarding the performance of autonomous systems in uncertain, real world situations. ICS considers that the Committee should explicitly describe its information needs for informed decision making.

Paragraph 16 addresses technology issues. This includes emerging issues with the use of performance standards, including specific rules

to support goal based standards, for regulating autonomous systems.

It is also noted that meaningful demonstration of equivalence could be problematic. Indeed, ICS questions whether the current approach to consideration of equivalence with existing IMO instruments is appropriate.

It is further noted that probabilistic approaches to regulation may be required where the preference so far has been for prescriptive performance standards. This should be carefully considered. It is also noted that throughout the Committee’s work on this item, it will be essential to promote transparency.

Paragraph 17 proposes that the Committee takes into account the comments and analysis provided, and further proposes that the working group considers the risks of focusing on the regulations alone, as well as the benefits of following a more holistic approach. We believe that this is necessary to respond to the action requested of the Committee in paragraph 12.6 of MSC 99/5.

5/3 Recommendations on identification of potential amendments to existing IMO instruments

Finland, Liberia, Singapore, South Africa and Sweden

The co-sponsors provide information on a preliminary review and categorisation of IMO instruments, including those under the purview of other Committees. The instruments are categorised as follows:

Category 1: Instruments which do not require amendments; and Category 2: Instruments that, as presently drafted, may require

amendments.

It’s is suggested that this work is the first stage of the regulatory scoping exercise. The second stage would apply to category 2 instruments and would involve identification of specific requirements or regulations for amendment.

The proposal in this submission is linked with the action identified by the Secretariat in paragraphs 12.1 and 12.5 of MSC 99/5. This action is for the consideration of the need to categorize or group related instruments during the regulatory scoping exercise.

This work may also provide a valuable contribution to assessing whether the information papers providing preliminary assessments may sufficiently cover

relevant IMO instruments.

5/4 Considerations on and proposals for the methodology to use within the framework of the regulatory scoping exercise

France

France comments on the methodology for the regulatory scoping exercise.

Scope

It is proposed that the scoping exercise is extended to cover IMO instruments outside the purview of the Committee. Specific reference is made to those instruments relating to facilitation, insurance, liability and compensation.

It is further considered that:

Autonomous ships should not be exempted from certain obligations because of how they operate. This reflects the need for such ships to co-exist within existing ships at sea;

The additional complexity introduced by shore-based control should also be taken into account; and

Special attention be paid to the technical standards of classification societies and requirements for statutory certification of the innovative aspects of autonomous ships.

Methodology

Regarding the approach to the regulatory scoping exercise itself, it is proposed that both a “top down” and “bottom up” approach is adopted.

The “bottom up approach” starts with existing instruments and compares them with the autonomous ship concept. The “top down” approach starts with the autonomous ship concept and then considers the functions of the crew and the notions of shipowner, liability and manning requirements.

It is suggested that the two approaches could be subjected to a risk and opportunities analysis for ships, companies and the industry.

Definitions

France proposes definitions for levels of autonomy and an autonomous ship. It is however noted that the focus should not be on the navigation function.

Level of Safety

Equivalence with SOLAS is considered the minimum acceptable level of

safety for autonomous ships. It is proposed that consideration is given to how the formal safety assessment method could be used to ensure that this is achieved.

The comments and proposals of France should be given further careful consideration in the WG to be established at MSC 99. Of particular interest will be the discussion on the approach combined “top down” and “bottom up” approach. This is a more advanced approach than that of focusing only on regulatory barriers and therefore moves towards the holistic approach advocated by ICS.

Regarding the definition, the shortfall is the focus on “navigation”. Arguably, the IMO should be considering autonomy as it may be applied to any safety or operational function on board.

Regarding the matter of certification and classification society technical standards. This is an important matter and relates to the concerns and comments made by ICS (MSC 99/5/2) regarding how expected performance of autonomous systems is verified in uncertain, real world situations.

Regarding the discussion level of safety. ICS can agree with France that the minimum level should be equivalence with SOLAS but:

What is the current safety level embodied in SOLAS? What is the current safety level embodied in other IMO instruments

which have a bearing on ship operations, for example the COLREGs? Is equivalence an adequate minimum standard? In the context of

systems capable of achieving higher levels of autonomy, this is unlikely to be the case.

UK Position: France’s definition of autonomous ships, as detailed in paper 99/5/4, is mainly based on navigation. The UK believes the issue to be wider than just navigation. However, several of the points raised in the paper are in line with UK thinking.

5/5 Plan of approach for the scoping exercise Australia, Canada, Denmark, Estonia, Finland, Japan, the Netherlands,Norway, Singapore, Sweden, the United Kingdom, the United States, IMarEST and IMCA

The co-sponsors propose an approach to the regulatory scoping exercise, specifically the content of the final report of the scoping exercise.

It is proposed that the report contains:

A list of IMO instruments included in the work; A description of MASS and concepts of autonomy, automation,

operations and manning; A vocabulary for use in connection with further work on MASS; A description of IMO instruments that are currently in force, but may

preclude the operation of MASS; A description of IMO instruments that are currently in force that would

have no application to the operation of MASS if the ship is unmanned, as they relate to human presence on board;

A description of IMO instruments that are currently in force that do not preclude the operation of MASS and therefore do not need to be amended. It is recognised that it may however be necessary to establish equivalences or interpretations, and identify any gaps or barriers; and

Recommendations for the future scope of work on MASS at IMO.

The co-sponsors also provide draft terms of reference for the WG to be established at MSC 99, and recommend the establishment of inter-sessional correspondence groups to complete the work.

This submission contributes to the task to develop a work plan identified by the Secretariat in paragraph 12.7 of MSC 99/5.

The focus of the proposal for a new work item at MSC 98 focused on “unmanned” autonomous ships. This submission takes a positive step

towards recognising that ships may have autonomous capabilities but remain manned.

The proposed content of the report and terms of reference for the WG are appropriate, and reasonable. However, the scope of the terms of reference would not allow for all of the issues highlighted by the Secretariat in MSC 99/5 to be addressed. The scope may also limit the extent to which discussion on matters of a broader but significant nature can take place.

ICS can support further consideration of the submission in the WG, provided that the comments of other submissions on the scope of the terms of reference are taken into account.

5/6 Considerations on definitions for levels and concepts of autonomy

Finland

Finland provides a review of current definitions of “levels of autonomy” for further consideration in the working group at MSC 99.

The definitions for “levels of autonomy” included are:

Bureau Veritas; Lloyd’s Register; Norwegian Forum for Autonomous Ships; Ramboll – Core (on behalf of Denmark and provided in document MSC

99/INF.3); Rolls-Royce; and UK Marine Industries Alliance.

It is found that:

The number of levels varies between definitions, and the suggested content of the levels varies noticeably;

The definitions need to be tested and validated in real projects in order to ensure their practical applicability and this should be done before the levels of autonomy are agreed upon; and

A focus on navigation is some of the definitions is problematic. In this regard two factors should be considered. First, does the level apply to all systems, or individual systems; and second it may be possible for dynamic changes between levels.

It is considered that to fully understand the concept of MASS, different options and solutions combining manning, automation, remote control and autonomy need to be considered.

This submission provides a useful summary of definitions which should be

given further careful consideration. ICS can support further consideration of the submission in the WG, provided that the comment in paragraph 15 regarding testing and validation are taken into account. For example, by limiting agreement to a working definition at this stage.

5/7 Proposal on the work plan of the regulatory scoping exercise for the use of MASS

China and Finland

China and Finland provide an analysis of the characteristics of MASS, and describe the anticipated outcomes from the regulatory scoping exercise.

The characteristics of MASS, that make them different from existing ships are summarised as:

The role of the human as a manager of complex systems, rather than an operator;

The use of data on board, and the challenges presented by increased connectivity;

Rapid evolutions in technology; and Integration of complex systems, presenting challenges for

understanding how systems will behave following design changes.

Taking into account the characteristics and the challenges these will create, it is proposed that the regulatory scoping exercise should consider:

Goal-based standards to allow for technological change; New measures for verifying conformity with the requirements of IMO

instruments.

It is further proposed that the outcome of the regulatory scoping exercise addresses:

Definition of MASS and automation levels; A comprehensive review report; Interim guidelines for MASS trials in international voyages; and Development of mechanisms for sharing data and lessons learned

regarding projects and applications of MASS.

In addition, a detailed work plan for the regulatory scoping exercise in provided.

This submission contributes to the task to develop a work plan identified by the Secretariat in paragraph 12.7 of MSC 99/5.

The submission is clearly intended to address the needs of manufacturers rather than shipowners and operators. It provides an unjustified sense of

urgency for the work.

Notwithstanding this, much of the analysis of the characteristics of MASS and potential challenges are reasonable. The views on collection and sharing of data and experience are aligned with similar views by ICS in document MSC 98/5/2.

The proposal for the development of Interim guidelines for MASS trials in international voyages is not compatible with the proposal by IFSMA and ITF in document MSC 99/5/1 which proposes a resolution precluding such activity.

UK Position: The UK intends to remind the Working Group and MSC of the need to be clear on the definition of Goal-Based standards, and how far it can be practically used in response to the proposal of China and Finland suggesting a Goal-Based approach to be adopted.

5/8 Recommendations on categorization and regulatory scoping exercise of MASS

China and Liberia

China and Liberia propose that when defining MASS, manned MASS and unmanned MASS should be considered separately.

It is proposed that a formal safety assessment (FSA) or gap analysis is conducted during the scoping exercise, taking into account the proposal in MSC 98/20/13 (ITF).

In addition, it is recommended that goal-based interim guidelines for unmanned cargo carriers are developed as a priority.

As with the submission by China and Finland in document MSC 98/5/7 the submission is clearly intended to address the needs of manufacturers rather than shipowners and operators.

The proposal for interim guidelines relates directly to the Chinese project to build and test an autonomous cargo carrier, due for delivery in 2021.

The proposal to conduct a formal safety assessment or gap analysis is reasonable. However, ICS questions whether sufficient information is available to develop risk models to support a FSA. It is further proposed that risk control measures are developed which result in equivalence with existing IMO instruments. This is potentially problematic because:

The current safety level embodied in existing IMO instruments is unknown; and

The assumption that equivalence is appropriate, is not justified.

It is unclear, whether the IMO will be in a position to develop interim guidelines, at least before the regulatory scoping exercise is complete.

5/9 Japan's perspective on regulatory scoping exercise for the use of MASS

Japan

Japan provides comments on the regulatory scoping exercise, particularly the importance of the recognition of phased development of new and advancing technologies.

It is proposed that:

The regulatory scoping exercise should not focus on unmanned operation only. It should address several transition phases;

A common understanding of the extent to which equivalency is used. There is considered to be a risk that excessive use may undermine safety; and

The regulatory scoping exercise should consider the safety of all maritime traffic including conventional ships.

This submission shares similar views to those expressed by ICS in MSC 98/5/2.

5/10 General comments on a way forward ITF

ITF provides further perspectives on the way forward with the regulatory scoping exercise.

Key points highlighted are:

A road map outlining the phases needed for a progression to unmanned ships could be developed as a useful guide to a way forward;

Any timelines developed should be based on attaining specific goals. It should not be focused on specific dates;

The focus should be on identifying functional requirements for various operating scenarios and a regulatory framework for ensuring that the semi-autonomous systems managing those functions are safe and reliable; and

Having fully autonomous unmanned ships as the primary goal of a regulatory framework at this time, is an inappropriate objective.

There are elements of the analysis provided which align with the views expressed by ICS in MSC 98/5/2.

5/11 Comments on documents MSC 99/5, MSC 99/5/2, MSC 99/5/5, MSC 99/5/8 and MSC 99/5/9

Turkey

Turkey provides comments on the regulatory scoping exercise and the development of a work plan. It is considered appropriate for the working group to consider a work plan which starts with the matters less likely to lead to lengthy debate.

A phased approach should also be adopted, based on evidence and in accordance with guiding principles (TBD). This should prioritise discussion on manned MASS. It is also proposed that the exercise is conducted using all relevant Sub-Committees and that an inter-sessional working group be established.

The phased approach proposed is aligned with the comments in document MSC 99/5/9 (Japan) and MSC 99/5/10 (ITF). The need to establish guiding principles could be aligned with the approach proposed by ICS in MSC 99/5/2 as this could establish a basis for a more holistic approach.

5/12 Comments on document MSC 99/5/5 United States

The United States proposes definitions for MASS and autonomy levels which should be considered as part of the regulatory scoping exercise. These are based on the information provided by Denmark in MSC 99/INF.3 but are more general, and not focused on navigation.

Procedural proposals are also made regarding the conduct of the work by IMO and the Committee.

The UK does not support the US suggestion for the Secretariat to do an initial review of IMO instruments as there is no foreseen benefit for this. It is also not necessary to increase the time frame or extend the target date to complete the scoping exercise until Terms of Reference have been agreed. However, the UK agrees with the statements that definitions of autonomous ships should be beyond navigation. The UK can support, as a starting point, the reviews undertaken on the IMO instruments by or on behalf of member states on how these will be amended to allow or prohibit MASS.

5/INF.3

Final Report: Analysis of Regulatory Barriers to the use of Autonomous Ships

Denmark

Denmark provides the results of an analysis of regulatory barriers to the use of autonomous ships.

5/ Report of a survey on what maritime IFSMA and ITF

INF.5 professionals think about autonomous shipping

The co-sponsors provide information on the report of a survey conducted into the views of maritime professionals on autonomous shipping.

5/INF.8

Work conducted by the CMI International Working Group on Unmanned ships

CMI

CMI provides information on a legal assessment of the regulatory barriers to unmanned ships.

5/INF.13

Establishing international test area "Jaakonmeri" for autonomous vessels

Finland

Finland provides information on an international test area for autonomous vessels.

5/INF.14

Studies conducted in Japan on mandatory regulations relating to Maritime Autonomous Surface Ships – SOLAS, STCW and COLREGs

Japan

Japan provides information on the outcome of studies into the application of mandatory IMO instruments (SOLAS, STCW and COLREGs) to MASS.

5/INF.16

Presentation by Norway on 21 May 2018 on the "YARA Birkeland" development

Norway

Norway provides information on the “YARA Birkeland” project.

UK Position: The UK believes that it is too early to discuss human element issues in relation to MASS and that the Secretariat will not be in a position to carry out the work of the scoping exercise. Levels of automation would be preferable to definitions in order to move this work forward.

The UK acknowledges the point highlighted by Turkey that the scoping exercise should be approached from a human element point of view in paper 99/5/11 but only to the extent of being open to the review considering both manned and unmanned MASS as proposed by Japan (99/5/9).

EU is not coordinated on MASS and there are some papers that seem to contradict each other. The EU Shipping Forum will look at autonomy in a Working Group, and the Commission is looking within EU context for experts.

ITEM 6: GOAL-BASED NEW SHIP CONSTRUCTION STANDARDS

The Committee will consider:

1. New proposals submitted by Member States and international organizations regarding the remaining work concerning the amendments to part B of the GBS Verification Guidelines, based on the report of the GBS Working Group at MSC 98;

2. Any proposals concerning part A of the GBS Verification Guidelines submitted by Member States and international organizations on other approaches for the maintenance of verification, and changes consequential to the revision of part B, before the adoption of the draft Revised guidelines; and

3. Any other documents submitted by Member States and international organizations under this agenda item.

A working group on goal-based standards will be established.

Papers:

6 Progress report on the work related to goal-based standards

Secretariat

The Secretariat provides an update on the decisions taken by MSC 98 relating to:

1. The maintenance of verification audits;

It is noted that MSC 98 considered that the rectification of outstanding non-conformities had been accomplished and the initial verification had been successfully completed per the GBS Verification Guidelines contained in resolution MSC.296(87)

2. Corrective actions taken by ROs to address the identified observations at the initial verification audit;

It is recalled that MSC 96 requested the 12 IACS member ROs to address the observations identified during the audit process taking into account the audit team recommendations and the comments made in submission MSC 95/5/9 (Greece) and submit the outcome of their review to the Committee at a later session.

The Committee is advised that the “corrective actions” addressing the observations have been submitted for the review of the Committee and are detailed in submissions MSC 99/INF.9 and MSC 99/INF.19.

3. The progress on the development of amendments to the GBS Verification Guidelines;

The Secretariat highlights the discussions relating to the frequency of maintenance of verification audits and the view of the GBS WG at MSC 98 that a 3 year audit cycle could be appropriate but that alternative proposals could be considered based on future submissions. The adoption of the draft revised guidelines is expected at MSC 100.

4. The future direction of the safety level approach (SLA).

It is recalled that MSC 98 invited Member States and international organizations to submit concrete GBS-SLA examples as well as comments on 2 options for section 14 of the draft Interim guidelines for development and application of IMO goal-based standards safety level approach on "Application of the safety level approach to the IMO rule-making process" to MSC 99, with a view to further developing the draft Interim Guidelines

A revised timetable and schedule of activities for the implementation of the GBS verification scheme is also provided.

6/1 Development of the Interim guidelines for goal-based standards –safety level approach

IACS

IACS provides proposals to revise paragraphs 13 and 14 of the draft Interim guidelines for goal-based standards – safety level approach.

IACS highlights: The general apprehension expressed regarding the complexity of the

process in section 14 of the draft Interim guidelines and need for simplification;

The submission by Germany, MSC 98/6/5, providing a different approach for section 14 noting the strong support of the Committee;

Issues with both the interim guidelines as contained in annex 3 to MSC 98/WP 7 and in the annex to MSC 98/6/5 in relation to proposals for section 14 but notes that both proposals agree on the fundamental basis of GBS-SLA, i.e. hazard identification, hazard screening and development of a risk model and assessment of risk control options or mitigating measures; and

The process described in section 14 may be conducted in an objective and robust manner by utilizing the FSA methodology as prescribed in

the IMO FSA Guidelines.

IACS therefore proposes to amalgamate sections 13 and 14 of the existing draft Interim guidelines into a single section (section 13) and provides proposed text in the annex to their submission which is stated to support the:

Development of new rules and regulations based on GBS-SLA; and

Amendments of existing rules and regulations based on GBS-SLA.

6/2 Views on the three-year cycle for the maintenance of verification

IACS

IACS' provides their views on the three-year cycle for the maintenance of verification in the draft part A of the IMO GBS verification guidelines contained in document MSC 98/WP.7 together with suggestions related to other approaches, which might be proposed at MSC 99.

IACS states that it believes rule changes submitted annually should be audited (maintenance of verification) collectively at the end of a 3-year cycle for the following reasons:

The three-year cycle would allow sufficient time to conclude the verification process of a specific audit (including closure of possible non-conformities) prior to beginning the subsequent audit, thus avoiding the overlap of two consecutive verification processes, making it clear which changes have already been verified and easing the consideration by Member States at MSC; and

The three-year cycle would reduce the administrative burden for all stakeholders (i.e. Administrations, classification societies, industry and IMO) owing to the establishment and management of the audit process.

IACS advises of its readiness to discuss other practicable solutions such as focussing the maintenance of verification audits on those substantive changes to the rules that have the most impact rather than adhering to a fixed time schedule. In addition, IACS provides proposed text to amend the draft GBS Verification Guidelines if there are proposals to permit audit outside the 3-year cycle. The proposed text is to ensure any audit outside the 3-year cycle is assessed for necessity by the IMO SG and Secretariat.

ICS believes that the text in the annex to the IACS submission is intended to address the scenario that the Committee concurs with and takes forward the proposal from Germany in its submission MSC 99/6/3

6/3 Maintenance of verification Germany

Germany supports a 3-year cycle for maintenance of verification but provides a proposal for a qualitative approach to evaluate the need for maintenance audits of rule changes, taking into account the nature and impact of submitted rule changes, rather than a simple quantitative sampling criterion.

In brief Germany proposes the categorisation of proposed rule changes into 3 categories from minor with no safety impact, category 1, to major, category 3. Depending on the categorisation of the rule changes proposed the audit cycle period may stay at 3 years, possibly be extended to 4 years where all proposed rule changes are minor or in the case where rule changes are proposed which fall into the major category then the rule changes should be reviewed as soon as possible and therefore outside of the 3-year cycle.

Germany in the annex to their submission provides text for amendments to the draft GBS Verification Guidelines in line with their proposals.

6/INF.9

Updated status report on ROs' Corrective Action Plan addressing GBS audit observations

Secretariat

As reported to the Committee in MSC 99/6 IACS provides the status report on the observations from the initial GBS verification audit of the 12 recognized organizations (ROs) that demonstrated that their rules were in conformance with the GBS.

In the submission 10 ROs provide their respective status reports in annexes 1 to 10 pertaining to the observations relevant to each RO received during the initial verification audit. Additionally, we are advised of the reasons there are no reports annexed to the submission for CCS and DNV-GL specifically that CCS received no observations and therefore did not need to submit a report and DNV-GL had already submitted their report to MSC 98.

The Committee is invited to note the information provided.

6/INF.19

Status reports addressing observations IACS

As reported to the Committee in MSC 99/6 IACS provides the updated status of work to address the IACS "common" observations as at 28 February 2018. The latest updated status is indicated using normal font with underline.

As stated in MSC 99/6, MSC 96 requested the 12 IACS member ROs to address the observations identified during the audit process taking into account the audit team recommendations and the comments made in submission MSC

96/5/9 (Greece) and submit the outcome of their review to the Committee at a later session. For ease of reference the original comments of Greece in relation to Observations reported back on are provided below:

IACS/2015/FR1-8/OB/07 Welding requirements – FR 3: Auditors observed that the version of URS-18 as referred to Res.3 (1997) requires full penetration welding for certain critical areas, whereas CSR have replaced that with "full or partial" penetration. IACS' proposed corrective action includes a provision of "more explanations"; however, Greece would agree with the auditors that the IMO-approved URS-18 version should be immediately applied in CSR. Any other versions should be submitted to IMO and applied after approval.

IACS/2015/FR1-8/OB/08

NB. IACS will report back the outcome on this observation to IMO in 2019

Vibrations – FR 3: Auditors' observation statements, as well as the GBS criterion referred to (3.2.1.11), point out that vibration levels, in general, are not considered in CSR-H "that may damage or impair the ship structure". IACS seems to consider this in the more limiting scope of vibrations from machinery or at sea trials. Greece believes that the auditors' comments are meant to address vibrations from any source – not just machinery, and should cover the whole ship.

IACS/2015/FR1-8/OB/12 Protection in holds – FR 3: Auditors point to preference of full penetration weld between tank top and sloping plates to address this observation for the protection of bulk carrier hold welds from bulldozers. However, among IACS' proposals is "enhanced weld inspections", which will most probably lead to the need for more repairs in-service. Greece believes that "enhanced weld inspections" and repairs in-service are unrealistic, and agrees with the auditors' proposal to effect "full penetration" welding as a means to address this observation.

IACS/2015/FR1-8/OB/13


No or insufficient margin in Fatigue Assessment – FR 4: Auditors question the apparent lack of margins in CSR fatigue assessment. Greece would point out that in all other industries fatigue life is always larger than design life to account for uncertainties. Also Greece believes that whipping/springing is important for fatigue in all ship types and sizes as previous studies have

shown. Greece would suggest, as part of the action plan, that IACS investigates prior work of its members regarding springing effects on bulkers and tankers, as well as its recent containership research.

IACS/2015/FR1-8/OB/17


Fatigue credit for grinding – FR 4: Auditors use 3 different reasonings to conclude that this is an inappropriate relaxation. They are quite clear to request its deletion, while they state "...recognizing that maintenance of coatings to PSPC standard is unrealistic while the ship in service". IACS, however, among its action plan, proposes to consider the development of inspection procedure to check on the soundness of coatings in-service. Many, if not most, of these post-weld treated areas are inside enclosed spaces (void spaces, ballast tanks) and cargo holds. Thus, Greece considers such inspections prohibitive. Considering the clear wording from the auditors, Greece would also urge the deletion of the relaxation as the only way forward to address this observation.

IACS/2015/FR9-15/OB/08

Testing of Watertight (WT) compartments – FR 12: URS-14 has been a thorny issue, here identified also by the auditors. Greece has criticized, in the past, UR's and Ul's involving statutory requirements that are issued and put into effect prior to having obtained IMO approval and the resulting complications for a number of ships being built, when such URs and UIs do not finally obtain full IMO approval. The auditors are quite explicit on the issue: "It also relates to a larger issue that, for the purpose of GBS, the acceptance criteria adopted in the different parts of the rule set should not be lower than... Table 5 of the CP1 (statutory requirements)". In this case, perhaps the best approach is to delete URS-14, as it is one of the IACS proposals in its Action Plan. Furthermore, the general guidance from the auditors that rules should not include criteria which are lower than statutory requirements should be noted, and adhered to, diligently.

UK Position: The UK supports the papers submitted under this Agenda item and notes the INF papers. The Safety Level Approach (SLA) is extremely complicated, however, Germany has proposed a pragmatic approach to the

maintenance of verification audits (99/6/3), which the UK support.

ITEM 7: SAFETY MEASURES FOR NON-SOLAS VESSELS OPERATING IN POLAR WATERS

The Committee will consider documents under this agenda item, in particular, with respect to the scope of application of the second phase of the Polar Code, its mandatory or recommendatory status and types of vessels to be addressed, and may establish, as decided at MSC 98, a working group on safety measures for non-SOLAS ships operating in polar waters.

In general terms ICS members do not operate non-SOLAS ships, however ICS will maintain a watching brief on this agenda item and report any issues of concern to members.

Papers:

7 Proposals for possible additional requirements for non-SOLAS vessels

Norway

Norway raises the lack of a legal framework to allow for mandatory application of the whole of the Polar Code to non-SOLAS ships and proposes some possible safety measures that may be achieved under the current framework.

For ships to which SOLAS chapter IV applies, Norway suggests that it should be considered to what extent the requirements of chapter 10 of part I-A of the Polar Code could be made applicable to cargo ships of between 300 gross tonnage and 500 gross tonnage, if they are operating in polar waters.

Additionally, the required performance standards referred to in section 1.4 of chapter 1 of part I-A should be met for the required additional systems and equipment.

Norway recommend that should the Committee agree to these proposals, that the NCSR Sub-Committee is instructed to consider the wider application of chapters 9, 10 and 11 of part I-A of the Polar Code, and to develop necessary amendments to SOLAS and/or the Polar Code.

7/1 Proposals for the provision of mandatory safety measures for all non-SOLAS ships operating in polar waters

Chile and New Zealand

New Zealand request the immediate commencement of work on the provision of mandatory safety measures for all non-SOLAS ships in polar waters. This proposal seeks to address the fact that non-SOLAS ships in polar waters continue to be lost or placed at serious risk in the absence of mandatory

safety measures.

The co-sponsors request that the Committee:

1. Reconfirms the application of mandatory status of phase II of the Polar Code work to be accomplished under the output on "Safety measures for non-SOLAS ships operating in polar waters";

2. Confirms that the scope of this output includes all non-SOLAS ships;3. Establishes a working group and a correspondence group to assist

SDC 6 with the immediate work on the output under a dedicated agenda item;

4. Directs the working group to consider the draft roadmap, set out in the annex

5. Agrees that MSC 100 will consider the process and mechanism to give effect to the overarching goal of mandatory safety measures for non-SOLAS ships.

7/2 The Cape Town Agreement of 2012 as a mandatory instrument relating to the safety of fishing vessels operating in polar waters

Pew

This paper aims to demonstrate that if a second phase of the Polar Code is developed, the Cape Town Agreement of 2012 could provide safety measures for fishing vessels operating in polar waters, once it enters into force, and ensure that potential measures would be binding.

7/3 Polar waters, the Polar Code and non-SOLAS vessels

FOEI, Greenpeace International, WWF and Pacific Environment

The co-sponsors summarize the process of the development of the mandatory Polar Code, including decisions around the need to address requirements for non-SOLAS vessels. It provides updated information and highlights the importance of regulating non-SOLAS vessels in polar waters, in relation to trends and incidents involving non-SOLAS ships, flag State and port State compliance for non-SOLAS ships, and risks to ecosystem hotspots from non-SOLAS ships.

7/INF.17

Information on fishing vessels and yachts active in the Antarctic

New Zealand

New Zealand provide supporting information data regarding accidents and incidents on fishing vessels and yachts, being the most prevalent and vulnerable non-SOLAS ships operating in Antarctic waters.

ITEM 8: CARRIAGE OF CARGOES AND CONTAINERS

The Committee will consider matters emanating from the fourth session of the Sub-Committee and take action as indicated in paragraph 2 of document MSC 99/8. Action in respect of the Sub-Committee's biennial status report will be taken under agenda item 20.

Papers:

8 Report of the fourth session of the Sub-Committee

Secretariat

The Committee is invited to take action on matters emanating from CCC 4 as follows:

Invite ISO/TC8 to consider developing a standard for Methyl/ethyl alcohol as marine fuel and; to invite ISO to develop a standard for methyl/ethyl alcohol fuel couplings;

Approve the draft amendments to parts A and A-1 of the IGF Code related to natural gas-specific requirements;

Authorize the Secretariat to effect the editorial corrections to relevant sections of the IGF Code;

Approve and issue CCC.1/Circ.2/Rev.1 on the Carriage of Bauxite which may liquefy;

Approve and issue CCC.1/Circ.4 on the Carriage of Ammonium Nitrate Based Fertilizer (non-hazardous);

Endorse the CCC 4 decision authorizing E&T 29 to prepare the draft amendments to the IMSBC Code for submission to CCC 5;

Endorse the CCC 4 decision authorizing E&T 29 to prepare the draft amendments to the IMDG Code, together with related recommendations and circulars for submission to MSC 99 for approval and adoption as appropriate;

Approve the draft UI of paragraph 13.3.5 of the IGC Code and associated draft MSC Circular;

Approve the draft UIs of the IGF code and associated MSC Circular; Subject to the approval of the UI of paragraph 13.3.5 of the IGC Code;

instruct III 5 to consider consequential updates to the Survey Guidelines under the HSSC;

Approve the 30th meeting of the E7T Group (IMSBC Code); and Approve the report in general.

8/1 Comments on documents MSC 99/8 and CCC 4/12 regarding the draft amendments to paragraph 9.5 of the IGF Code

Denmark

Denmark provides comments regards the draft amendments to paragraph 9.5 of the IGF Code and suggests the inclusion of an alternative solution to protect against leakage form liquefied fuel pipes outside machinery space.

Denmark expresses the view that the draft requirement is too restrictive and will prevent alternative solutions which could provide similar or better protection against leakage from liquid pipes.

It is proposed to include text in para 9.5.6 of document CCC4/12 to allow for these other such solutions.

UK Position: The UK agrees with the actions requested in paper 99/8 but opposes the proposal from Denmark in 99/8/1 to amend regulation 9.5.6 of the IGF Code.

ITEM 9: IMPLEMENTATION OF IMO INSTRUMENTS

The Committee will consider matters emanating from the fourth session of the Sub-Committee and take action as indicated in paragraph 2 of document MSC 99/9. Action in respect of the Sub-Committee's biennial status report will be taken under agenda item 20.

Papers:

9 Report of the fourth session of the Sub-Committee

Secretariat

The Secretariat provides information on the outcome of the fourth session of the Sub-Committee on Implementation of IMO Instruments (III) and highlights a number of actions requested of the Committee, including to, inter alia:

Concur with the HTW Sub-Committee to advise Member States on the release of marine safety investigation reports to the public in the GISIS MCI module; and

Endorse the issuance of III.2/Circ.2 on Action to be taken by port States on the required updates of ECDIS.

III 4 also invited the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR), at its fifth session, to consider the matter of required updates of ECDIS in relation to a date of revocation of III.2/Circ.2 and to make a recommendation to the Sub-Committee, subject to endorsement by MSC 99.

The Secretariat further advises that III 4 invited the Sub-Committee on Ship Design and Construction (SDC) and the Sub-Committee on Ship Systems and Equipment (SSE), to provide technical input on issues related to the consistency of in-water survey (IWS) provisions for passenger and cargo ships, as raised in both documents MSC 98/17/1 and III 4/8/3, and to make a recommendation to the Sub-Committee, subject to endorsement by MSC 99.

ITEM 10: SHIP DESIGN AND CONSTRUCTION

The Committee will consider matters emanating from the fifth session of the Sub-Committee and take action as indicated in paragraph 2 of document MSC 99/10. Action in respect of the Sub-Committee's biennial status report will be taken under agenda item 20.

Papers:

10 Report of the fifth session of the Sub-Committee

Secretariat


1. Note the discussion on the scope of the output on "Amendments to SOLAS regulation II-1/8-1.2 on the availability of passenger ships' electrical power supply in cases of flooding from side raking damage" and in particular, whether this matter should be solved by applying electrical engineering solutions, rather than naval architectural solutions (i.e. double hull or other structural requirements that would impact not only the current safe-return-to-port concept, but also the probabilistic requirements in SOLAS chapter II-1), and clarify what the exact outcome expected from the Sub-Committee under this output is (paragraphs 3.4.2 and 3.5);

Comments are provided in documents MSC/99/10/1 (CESA), MSC/99/5 (United States), MSC/99/10/6 (Netherlands) and MSC 99/5/7 (IACS).

ICS thanks the Netherlands, the United States, IACS and CESA for the documents submitted on this issue.

ICS recommends that clarification of the way forward for the Sub-Committee should be independent of anticipated design solutions, taking into account the relevant comments of the United States – MSC 99/10/5, and CESA – MSC 99/10/1.

It is further recommended that the Committee clarify the way ahead by agreeing on an appropriate goal for the new regulation, taking into account the analysis provided by the Netherlands in paragraph 11 of MSC 99/10/6.

When considering an appropriate goal, ICS requests the Committee carefully considers what it is that a passenger ship should be able to achieve following flooding from side raking damage affecting the availability of electrical power – safe return

to port or an effective and timely evacuation.

Regardless of how this work is taken forward, the comments provided by IACS in MSC 99/10/3 are pertinent. It is recommended that impacts on existing requirements be considered and addressed.

2. Note the agreement that passenger ships constructed before 1 January 2014 shall comply with SOLAS regulation II-1/8-1.3.1 not later than the first renewal survey after five years after the date of entry into force of the amendments to SOLAS regulation II-1/8-1, when considering the text of draft new SOLAS regulation II-1/8-1.3.2 for adoption (paragraph 4.7);

3. Approve the draft MSC circular on Guidelines on operational information for masters in case of flooding for passenger ships constructed before 1 January 2014, in conjunction with the adoption of the draft amendments to SOLAS regulations II-1/1 and II-1/8-1 (paragraph 4.11 and annex 1);

Comments are provided in documents MSC/99/10/3 (IACS).

ICS recommends support for the proposals by IACS regarding clarifications to the draft guidelines contained in annex 1 to SDC 5/15.

Furthermore, noting that the draft new guidelines are based on MSC.1/Circ.1532, it is understood that the provisions in both sets of guidelines should be aligned, so far as the flexibility required on ships constructed on or after 1 January 2014 allows.

Consequently, the provisions in these two sets of guidelines should be consistent and consequential amendments are recommended to at least MSC.1/Circ.1532.

4. Note the way forward for the finalization of second generation intact stability criteria agreed by the Sub-Committee (paragraphs 6.13 to 6.15);

5. Authorize SDC 6 to establish an Experts' Group on Intact Stability (IS) for consideration of a progress report of the IS Correspondence Group (paragraphs 6.16 and 12.9);

6. Note that Member States and international organizations objecting to the basic principles accepted for the development of the draft new SOLAS chapter [XV] and the draft new code addressing safety

standards for the carriage of more than 12 industrial personnel on board vessels engaged on international voyages were invited to provide proposals for the Committee's consideration (paragraphs 7.9 and 7.10);

Comments are provided in documents MSC/99/10/2 (Bahamas) and MSC/99/10/4 (Marshall Islands et al).

As a co-sponsor of document MSC 99/10/4 we fully support the comments made in that document and respectfully request that the Committee carefully considers and answers the two questions asked.

We thank the Bahamas for their submission and agree that the new chapter of SOLAS and IP code should be implemented and enforced in a consistent way, just as for all IMO instruments.

However, we consider that the current understanding of international voyage provided in SOLAS chapter I is sufficiently clear and we do not support classifying offshore installations or ships positioned offshore as ports for the purposes of defining international voyage.

To do so would risk the entire basis of how SOLAS is applied to the offshore energy sector. Ships routinely operate between ports and offshore locations (from one State’s jurisdiction) into the jurisdiction of another country. Classifying offshore installations or ships as proposed would risk introducing significant unintended consequences.

In practice, since most ships intending to carry industrial personnel will be certificated in accordance with SOLAS and other IMO instruments even if not operating international voyages so as to facilitate international mobility we would not expect this to be a major issue.

7. Approve the draft MSC resolution on Amendments to the 2011 ESP Code, with a view to adoption at MSC 100 (paragraph 8.22 and annex 2);

8. Approve the draft MSC circular on Guidelines for wing-in-ground craft (paragraph 11.10 and annex 3);

9. Consider the draft amendments to part A of the 2008 IS Code and take action as appropriate (paragraph 14.3 and annex 6); and

10.Approve the report in general.

10/1 Comments on document MSC 99/10Recommendations to clarify the task to improve the availability of passenger ships' electrical power supply in cases of side raking damage

CESA

CESA comments on the report of SDC 5 and makes proposals for how the Sub-Committee should proceed in its work to improve the availability of passenger ships' electrical power supply in cases of side raking damage.

CESA considers that naval architects and marine engineers should have flexibility to select the most appropriate means of ensuring the availability of electrical supplies and cautions against promoting a naval architectural solution such as requiring double hulls in way of main engine rooms at the expense of electrical engineering solutions such as redundancy.

CESA advocates a functional approach avoiding prescriptive requirements, regardless of whether electrical engineering or naval architectural design solutions are chosen. To facilitate this, they propose that the Sub-Committee should be instructed to consider and define the appropriate extent and assumed location of the side raking damage for which the ship will retain damaged stability and availability of systems.

Additionally, the Sub-Committee should be instructed to define a list essential functions which will remain available following side raking damage which will be consistent with safe return to port and evacuation requirements. See also documents MSC 99/10/5, MSC 99/10/6 and MSC 99/10/7.ICS agrees with CESA that any work to develop requirements for improving the availability of passenger ships' electrical power supply in cases of side raking damage should be independent of anticipated design solution and that any resulting outputs should be consistent with safe return to port and evacuation requirements.

UK Position: The UK supports the approach suggested by CESA, which proposes avoiding prescriptive regulations.

10/2 Comments on document MSC 99/10 Bahamas

The Bahamas comments on the report of SDC 5 with respect to the work which is being undertaken to develop a new chapter of SOLAS and mandatory code for the carriage of more than 12 industrial personnel (IP code).

The Bahamas considers that the definition of international voyage provided in

SOLAS regulation I/2(d), "a voyage from a country to which the present Convention applies to a port outside such country, or conversely” is insufficiently clear and that it is necessary to agree a common understanding of what is meant by “port” and what is meant by “outside such country”.

The Bahamas has concerns that unless there is a unified understanding of what is meant by international voyage then different Administrations will adopt different positions on what constitutes an international voyage. This will lead to inconsistent application of the new chapter of SOLAS and the new IP code.

The Bahamas reviews how this is addressed in other instruments and stresses the need for clarity on this issue to ensure that the new instruments are implemented and enforced consistently.

The Bahamas considers that either the nature of international voyage should be specially described in the proposed new SOLAS chapter [XV] or the scope of work should be redefined to make the new code recommendatory.

ICS agrees with the Bahamas that the new chapter of SOLAS and IP code need to be implemented and enforced in a consistent way and that this requires a consistent understanding of what is meant by international voyage.

ICS considers that the definition of international voyage provided in SOLAS regulation I/2(d), "a voyage from a country to which the present Convention applies to a port outside such country, or conversely” is sufficiently clear. We consider that this means a voyage from a port in one country, to port within the jurisdiction or another country, and that offshore locations do not constitute ports.

Therefore, it should be anticipated that since the overwhelming number of voyages made by ships carrying industrial personnel will be between a port and either an offshore installation (or installations) or another ship at an offshore location they are not international voyages even if the offshore location is within the jurisdiction of another country.

This is the understanding which has been consistently applied to offshore vessels, so for example a platform supply vessel operating from a port in country “A” and supplying an offshore installation within the exclusive economic zone (EEZ) of country “B” is not considered to be making an international voyage unless it also makes a port call in country “B” (or indeed, another country “C”).

This understanding is generally accepted and has worked satisfactorily over many decades, should it be changed then it could have significant implications for all other ships operating in the offshore energy sector, and for

ships operating in other sectors such as survey, scientific research and dredging ships (among others).

UK Position: The UK believes that the Bahamas paper needs to be considered carefully since the implications might be significant. It is unclear whether the MSC will be able to reconcile the differing view on the issue, but the UK will seek to ensure that clear directions are provided to SDC.

10/3 Comments on document MSC 99/10Draft guidelines on operational information for masters in case of flooding for passenger ships constructed before 1 January 2014

IACS

IACS proposes amendments to the draft Guidelines on operational information for masters in case of flooding for passenger ships constructed before 1 January 2024.

IACS highlights the fact that the term “non-linked breaches” which is used in the draft guidelines is not used in any other IMO instruments and asks the Committee to confirm that it has the same meaning as the term “discontinuous hull breaches”.

The submission notes that provisions on manning and qualifications of persons in paragraph 18 of the draft guidelines are not fully aligned with parallel provisions in paragraph 16. To avoid confusion IACS proposes some revisions to paragraph 18 in order to align it with paragraph 16.

They further propose that in paragraph 25 where the draft guidelines state that the Administration should be advised of ships fitted with systems before they are required by SOLAS II-1/8-1.3 and which do not fully comply with the guidelines that additional text be inserted to clarify that it is the company as defined in SOLAS regulation IX/1.2 which should make this notification.

Finally, IACS notes that consequential amendments may also be required to MSC.1/Circ.1532 Revised Guidelines on operational information for masters of passenger ships for safe return to port and MSC.1/Circ.1400 Guidelines on operational information for masters of passenger ships for safe return to port by own power or under tow.

IACS requests that the Committee consider to confirm that provisions within the draft guidelines would be applicable to these two existing MSC circulars, and if so whether they should be revised accordingly.

The suggested amendments and requests for clarification contained within the document would be useful and as such are supported by ICS.

ICS also supports amending the two existing circulars identified by IACS so as to align them fully with the draft guidelines.

10/4 Comments on document MSC 99/10 Marshall Islands, United States, Vanuatu and ICS

In response to the invitation of SDC 5 for interested Member States and international organizations to submit concerns relating to the development of the draft new SOLAS chapter [XV] and the draft new code for the carriage of more than 12 industrial personnel (IP code) to this session of MSC for the Committee's consideration, the co-sponsors highlight a number of concerns and request the Committee to consider two specific questions related to this work.

Although these concerns were raised at SDC 5 they were considered by the coordinator to be outside the terms of reference for the working group established at that session and so were not considered.

The co-sponsors consider that it is essential that the two questions asked are considered and answered by the Committee. The answers will, to a large extent, determine some of the key requirements of the draft new chapter of SOLAS and draft new IP code, and facilitate identifying consequential amendments which may be necessary for other instruments.

If these questions are not properly considered at this stage then the result may be conflicting requirements in different IMO instruments, uncertainty and a necessity to do significant reversionary work to amend the working draft documents later.

Firstly, will a ship certificated under the draft new IP code be allowed to carry other categories such as special personnel (SP), so long as no more than 12 passengers are carried?

If the answer is yes then the co-sponsors ask the Committee to make a decision on the aggregated total number of passengers, IP and SP which may be carried before the ship will be required to comply with the IP Code.

The co-sponsors recommend that this number should be 12, and also emphasize that this would not require any reference to non-mandatory instruments in the new SOLAS chapter [XV] or the IP Code.

Secondly, the Committee is asked to determine whether the application of the new SOLAS chapter [XV] and the IP Code be limited to ships

holding cargo ship safety certificates?

The co-sponsors consider that this was never the intent when work to develop the draft new chapter of SOLAS and draft new IP code commenced.

The proposal to restrict application to ships holding cargo ship safety certificates, which has now entered the working draft is considered to be a misinterpretation of the agreed philosophy for developing the new instruments.

The intention was to use safety requirements of cargo ships as a baseline and then to consider what additional requirements may be necessary for ships to safely transport and accommodate more than 12 industrial personnel.

This was never intended to require ships certificated under the draft new IP code to hold a cargo ship safety certificate, only that the new draft IP code would be based on cargo ship safety requirements.

If the Committee does decide that ships certificated under the new draft IP code shall hold a cargo ship safety certificate then this could exclude many ships which may be expected to carry industrial personnel from its application, for example small vessels and column stabilised accommodation service vessels.

The document will be introduced by the United States.

UK Position: The UK would support clarification about how to handle the “aggregation” of different types of person onboard these vessels. The UK is also of the view that the IP Code would apply to vessels holding cargo ship certificates only.

10/5 Comments on document MSC 99/10 United States

The United States comments on the report of SDC 5 regarding the availability of passenger ships' electrical power supply in cases of side raking damage.

The United States reviews the origin and history of this work, and the decision of MSC 93 to approve it as a prescriptive output for double hulls in way of main engine rooms under an existing work output on amendments to SOLAS chapter II-1 subdivision and damage stability regulations.

They note that prescriptive requirements submitted for the consideration of SDC 3 were not agreed and the work changed from focusing on prescriptive requirements to defining performance based outputs.

The United States highlights that regardless of whether prescriptive or functional requirements are developed, the resulting technical solutions adopted (such as engine room double side, longitudinally separated redundant engine rooms and widely distributed power supplies) will most likely be similar.

The United States supports the provision of functional requirements which allow either naval architectural or electrical engineering solutions to improve the availability of the electrical power supply in cases of side raking damage.

They consider the clarifications provided within their submission to be a confirmation of the output itself, which they support.

The position of the United States is generally consistent with that of CESA. Since this is a commenting document it is likely that all comments on this matter will be introduced together, therefore ICS will make a single intervention on this matter – see MSC 99/10.

10/6 Comments on document MSC 99/10 Netherlands

The Netherlands provides comments the report of SDC 5 regarding the availability of passenger ships' electrical power supply in cases of side raking damage.

The submission reviews the history of this work, noting that it originated at MSC 93 and was initially concerned with provision of double hulls in way of main engine rooms so as to protect machinery from side raking damage and to maintain power supplies as long as possible.

In addition, how the work subsequently evolved into considering a performance/goal based output following consideration of prescriptive proposals at SDC 2 and SDC 3.

It is noted that SDC 5 agreed that it would be necessary to clarify the purpose of the draft new SOLAS regulation II-1/8-1.2 before taking further action and that the output was initiated with a view to improving the availability of passenger ships' electrical power supply in case of an emergency.

As such, SDC 5 did not proceed with finalising draft amendments to SOLAS regulation II-1/8-1.2 and instead requested that the Committee clarify what it expected the Sub-Committee to deliver under this output and whether electrical engineering solutions such as distributed power supplies could be accepted as a solution rather than naval architectural solutions such as double walls in way of engine rooms.

The Netherlands considers that the original intent of this work was to protect machinery from side raking damage to maintain power supply as long as possible and that it was not limited to electrical systems. The Netherlands considers that the work should be applicable to systems specified in SOLAS II-2 regulation 21.4 (a list which includes the propulsion system, steering gear, fuel transfer system and fire main).

The Netherlands considers that the purpose (or the goal) of the desired output needs to be established, they identify two possibilities;

What they consider to be the original intention, to protect the main machinery spaces against side raking damage such that the ship is able to safely return to port under its own power; or

Limited: protection of the electrical power system against side raking damage such that it is ensured for escape routes and essential services to remain available.

It is argued that functional requirements could be established based on the goal which is agreed relating either to the systems in SOLAS regulation II-2/2.1 or to the electrical power supply in SOLAS regulation II-1/40 to II-1/42.

If the Committee decides that the output should be based on what the Netherlands believes to be the original goal they propose that the Sub-Committee be tasked with developing options for amending SOLAS regulation II-1/8-1.

The sponsors propose that each option should contain the goal, functional requirements and performance standard. This would not be restricted to electrical power supply therefore the Netherlands suggests amending the title of the output to "Amendments to SOLAS regulation II-1/8-1 related to protection in cases of flooding from side raking damage".

If the Committee supports the more limited goal of protecting the electrical system against side raking damage then the Sub-Committee should be asked to develop options for amending SOLAS regulations II-1/40 to II-1/42, in order to enhance the resilience of the electrical power system in case of side raking damage. This would not require that the output be renamed.See also MSC 99/10/1, MSC 99/10/5 and MSC 99/10/7.

ICS agrees that the Committee should clarify the desired output for this work, since this is a commenting document it is likely that all comments on this matter will be introduced together, therefore ICS will make a single intervention on this matter – see MSC 99/10

UK position: The UK supports the original goal (14.1), which is the protection

of the main machinery spaces against side raking damages such that the ship is able to safely return to port under its own power, which was understood to be the original intent.

10/7 Comments on document MSC 99/10Protection of electrical equipment in the event of raking damage

IACS

IACS provides comments the report of SDC 5 regarding the availability of passenger ships' electrical power supply in cases of side raking damage.

IACS expresses concern at the direction taken by this work and note that many delegations at SDC 5 had noted that there was a lack of clarity about what it was intended to achieve. Noting that the Committee had been asked to clarify the scope of this output and confirm whether the matter should be solved by applying electrical engineering solutions, rather than naval architectural solutions.

If the intent is to apply electrical engineering solutions then IACS argues that it should be determined whether the whole electrical supply system is to be protected or only specific items, such as passenger lifts.

IACS also expresses concern that if a naval architectural solution is applied then consequential impacts on the current probabilistic damage stability requirements will need to be considered.

IACS is of the opinion that the raking damage stability standard as prepared by the Correspondence Group (CG) on Subdivision and Damage Stability (SDS), established at SDC 4, may not be consistent with the current rationale of the probabilistic stability framework.

IACS also express concern that considering side raking damage along the length of the ship, as envisaged in the draft SOLAS amendments developed by the CG may result in providing a double side-skin to a significant portion of the length of the ship and not just in way of the machinery spaces.

IACS warns the Committee that the flooding of such double-hull spaces, without suitable cross-flooding arrangements being provided, which may not be practicable, could induce a significant list which will make the required subdivision index R difficult to obtain.

ICS shares the concern of IACS at the possible consequences of agreeing requirements which are not practicable and agrees with IACS that the output of this work should be clarified.

However, we do not agree with IACS that the intent of the work undertaken at SDC 5 was to promote an electrical engineering solution rather than a naval architectural one.

Rather the intent was to develop a goal based approach in which designers

would have flexibility to select electrical engineering or naval architectural solutions, or a combination of both, as appropriate.

Since this is a commenting document it is likely that all comments on this matter will be introduced together, therefore ICS will make a single intervention on this matter.

ITEM 11: POLLUTION PREVENTION AND RESPONSE

The Committee will consider matters emanating from the fifth session of the Sub-Committee of relevance to MSC and take action as indicated in paragraph 2 of document MSC 99/11.

Papers:


Secretariat

The Secretariat invites the Committee to note that draft amendments to the IBC Code and consequential draft amendments to the BCH Code were prepared by PPR 5, with a view to submission to MEPC 73 and MSC 100 for approval and subsequent adoption.

ITEM 12: NAVIGATION, COMMUNICATIONS AND SEARCH AND RESCUE

The Committee will consider matters emanating from the fifth session of the Sub-Committee and take action as indicated in paragraph 2 of document MSC 99/12.

Papers:


Secretariat

The Secretariat provides the report of NCSR 5. The Committee is invited to:

1. Adopt, in accordance with resolution A.858(20), the establishment of new traffic separation schemes and associated measures, for dissemination by means of a COLREG circular, as follows:

1. "In Dangan Channel" (paragraph 3.28.1 and annex 1); and2. "In the vicinity of Kattegat" (paragraph 3.28.2 and annex 1);

2. Adopt, in accordance with resolution A.858(20), the establishment of new and an amendment to the existing routeing measures other than traffic separation schemes, for dissemination by means of an SN circular, as follows:

1. Amended areas to be avoided "Off the coast of Ghana in the Atlantic Ocean" (paragraph 3.29.1 and annex 2);

2. The establishment of the precautionary area "Dangan Channel No.2" with the recommended directions of traffic flow (paragraph 3.29.2 and annex 2);

3. The establishment of deep-water routes, recommended routes and precautionary area "In the vicinity of Kattegat" (paragraph 3.29.3 and annex 2); and

4. The establishment of two-way routes, precautionary areas and areas to be avoided "In the Bering Sea and Bering Strait" (paragraph 3.29.4 and annex 2);

3. Agree that the new routeing measures be implemented, as follows:

1. Routeing measures set out in paragraphs 3.28.1, 3.29.1, 3.29.2 and 3.29.4 be implemented six months after their adoption (paragraphs 3.30.1); and

2. Routeing measures set out in paragraphs 3.28.2 and 3.29.3 be implemented on 1 July 2020 (paragraphs 3.30.2);

4. Approve the draft amendment to MSC.1/Circ.1376/Rev.2 on Continuity of service plan for the LRIT system (paragraph 4.5 and annex 3);

5. Approve the draft amendments to the LRIT Technical documentation, parts I and II (MSC.1/Circ.1259/Rev.7 and MSC.1/Circ.1294/Rev.5, respectively), and instruct the Secretariat to publish the corresponding revised versions of the circulars when the third modification testing phase is conducted (paragraph 4.19 and annex 4);

6. Adopt the draft MSC resolution on performance standards for shipborne Indian Regional Navigation Satellite System (IRNSS) receiver equipment (paragraph 5.4 and annex 5);

7. Approve the draft MSC circular on Interim guidelines for the harmonized display of navigation information received via communications equipment (paragraph 6.11 and annex 6);

8. Authorize the holding of the second meeting of the IMO/IHO Harmonization Group on Data Modelling (HGDM 2), to be held from 29 October to 2 November 2018 at IMO Headquarters, and instruct the Secretariat to take action, as appropriate (paragraph 8.15);

9. Endorse the action taken by the Sub-Committee, as an exceptional case, in authorizing the Secretariat to submit the report of HGDM 2 to NCSR 6 three weeks beyond the deadline for bulky documents, i.e. by 9 November 2018 (paragraph 8.16);

10.Authorize the Joint IMO/ITU Experts Group, at its fourteenth meeting from 3 to 7 September 2018, to submit an updated draft IMO position to MSC 100, for the Committee's approval of the position to be submitted to ITU's Conference Preparatory Meeting to be held in February 2019 (paragraph 12.11);

11.Endorse the action taken by the Sub-Committee in instructing the Secretariat to convey the liaison statement on autonomous maritime radio devices to ITU-R Working Party 5B (paragraph 12.22);

12.Endorse the action taken by the Sub-Committee in instructing the Joint IMO/ITU Experts Group to prepare the necessary liaison statements on the possible interferences with L-band maritime satellite communications, and forward them directly to ITU-R Working Party 5B and the European Conference of Postal and Telecommunications Administrations (CEPT) (paragraph 14.8);

13.Adopt the draft MSC resolution on Statement of Recognition of Maritime Satellite Services provided by the Inmarsat Global Ltd. (paragraph 14.24 and annex 7);

14.Note the discussion and provide guidance on the way forward with respect to the recognition of the Iridium mobile satellite system for use in the GMDSS (paragraphs 14.26 to 14.56);

Comments are provided in documents MSC 98/12/2 (China), MSC 98/12/5 (UK), MSC 98/12/6 (Germany), MSC 98/12/7 (United States), MSC 98/12/8 (United States), MSC 98/12/9 (Finland, Mexico and United States).

ICS considers that the recognition of additional mobile satellite service providers for use in the GMDSS supports the resilience of the system. It also provides shipowners and operators with the ability to select appropriate equipment and services for their operations when complying with the carriage requirements of SOLAS chapter IV.

ICS supports the equitable treatment of candidate services based on clear and relevant recognition criteria, applied consistently throughout the recognition process – now and in the future.

Recognition is an important element in assessing the capabilities of a candidate service. However, it is the obligations imposed by the public service agreement, as verified annually by IMSO, which ultimately ensure that the level of services required by the GMDSS is implemented and maintained. It is recommended that these comments are taken into account when considering the way forward in this case.

15.Endorse the action taken by the Sub-Committee in authorizing the Joint IMO/ITU Experts Group to prepare a liaison statement on the proposed revision of Recommendation ITU-R M.1371-5 with respect to the method to match the two IDs assigned to an EPIRB-AIS, and forward it directly to ITU-R Working Party 5B (paragraph 15.7);

16.Approve the draft MSC circular on Amendments to the IAMSAR Manual, taking into account ICAO's concurrence with the inclusion of the proposed amendments to the Manual, for inclusion in the 2019 edition of the Manual (paragraph 18.4 and annex 8);

17.Consider possible options to solve the challenges identified in relation to the workload of the Sub-Committee (paragraph 20.13);

Comments papers are MSC 99/12/3 (Secretariat) and MSC 99/12/4 (UK).

18.Adopt the draft MSC resolution on Amendments to the Revised

Performance standards for integrated navigation systems (INS) (resolution MSC.252(83)) relating to the harmonization of bridge design and display of information approved by NCSR 4 (paragraph 22.9.1 and annex 11);

These amendments are related to the work done on "Interconnection of NAVTEX and Inmarsat SafetyNet receivers and their display on Integrated Navigation Display systems". This is not an e-Navigation related piece of work.

19.Approve the draft MSC circular on e-navigation Strategy Implementation Plan – Update 1 (paragraph 22.12 and annex 12);

20.Revoke III.2/Circ.2 as from 1 July 2018 (paragraph 22.20); and

III.2/Circ.2 is the circular on Action to be taken by port states on the required updates of electronic chart display and information systems (ECDIS).

21.Approve the report in general.

12/1 Recognition of BeiDou Message Service System for use in the GMDSS

China

China provides an application BeiDou Message Service System (BDMSS) for recognition and use in the GMDSS.

12/2 Comments on the issue of recognition of Iridium mobile satellite system for use in the GMDSS, contained in document MSC 99/12

China

China provides comments on the issue of recognition of the Iridium satellite system for use in the GMDSS. The submission considers Iridium to be “an immature system with potential risks”. This risk areas are highlighted as:

Availability of the space segments, specifically the pending deployment of Iridium NEXT;

Availability of network, particularly in light of persistent outages highlighted in the IMOS report;

Calculation on availability, specifically the use of un-endorsed calculation methods.

Restoration and spare satellites, particularly the absence of any demonstrated capability tested as part of contingency satellite exercises;

System reliability, particularly the availability of a hot back-up; and The absence of convincing evidence that "partially met" items in annex

1 to NCSR 3/WP.5 can identified as "fully met" in NCSR 5/14/2.

It is proposed that the Committee instructs NCSR 6 to continue its work related to recognition of Iridium and to advise the Committee on final recognition when the issues identified have been resolved.

12/3 Workload of the NCSR Sub-Committee Secretariat

The Secretariat provides an analysis of the workload of the NCSR Sub-Committee, including possible options to address challenges identified.

This submission responds to the request of NCSR 5 and concerns raised at that session regarding the workload of the Sub-Committee.

12/4 Comment on the report of the Sub-Committee:Future work methodology for the NCSR Sub-Committee

United Kingdom

The United Kingdom comments on the future work method of the NCSR Sub-Committee and recommends that the time available for the meeting is extended. The intention is to following the MSC model of an 8-day meeting.

12/5 Recognition of the Iridium mobile satellite system for use in the GMDSS

United Kingdom

The United Kingdom expresses its concern regarding the recognition of Iridium, including “conditional” recognition.

The outstanding issues highlighted include:

The lack of an assessed and verified "hot back-up" of the commercial gateway;

No clearly associated MRCCs for SAR operations; The compatibility between the Iridium use of MMSI as the mobile

terminal identifier and the carriage of multiple terminals to comply with SOLAS regulation IV/15 or on a voluntary basis;

The risk to service during the future replacement of some 45 satellites; and

Access to registration information.

It is considered that there are outstanding issues which do need to be resolved, prior to recognition, but that absolute clarity should be given to Iridium on what these are. Iridium should be given the freedom to demonstrate how they have address the outstanding issues. Any recommendation on recognition should be based on this outcome.

12/6 Comments on the recognition of the Iridium mobile satellite system for use in the GMDSS

Germany

Germany provides information on concerns relating to the recognition of Iridium, in particular:

A full back-up in the ground segment; and The requirement to enter a PIN for certain types of calls.

It is proposed that NCSR 6 is tasked to further consider these concerns and report back to the Committee accordingly.

12/7 Report of the fifth session of the Sub-Committee – Comments on documents MSC 99/12/2 and MSC 99/12/5

United States

The United States responds to the concerns raised by China (MSC 99/12/2) and the United Kingdom (MSC 99/12/5). It is concluded that:

Recognition only means that Iridium has met the requirements of resolution A.1001(25). Before commencement of service, other issues need to be resolved, including executing the PSA with IMSO and having IMSO issue the Letter of Compliance;

Recognition is not a final step. If it were then it would be impossible to have any additional GMDSS providers;

To change the recognition criteria would be prejudicial to Iridium; and All the information required for recognition has been provided by

Iridium and has been evaluated by IMSO. IMSO has reported that Iridium has fulfilled all requirements of A.1001(25).

The Committee is urged to grant recognition to Iridium to allow all remaining items necessary to begin GMDSS service to be in place ready for January 2020.

12/8 Report of the fifth session of the Sub-Committee – Draft resolution for recognition of the Iridium mobile-satellite systemfor use in the GMDSS

United States

The United States provides a draft MSC resolution providing a "Statement of Recognition of the Maritime Mobile Satellite Services provided by Iridium Communications, Inc.".

The Committee is invited to adopt the resolution. It is further requested to invite IMSO to inform IMO when the Public Services Agreement has been concluded.

12/9 Report of the fifth session of the Sub Committee – Recognition of the Iridium mobile-satellite system for use in the GMDSS

Finland, Mexico and United States

The co-sponsors propose the next steps to be taken in accordance with the procedure for recognition. This procedure is described in the Criteria for the provision of mobile satellite communication systems in the GMDSS (resolution A.1001(25)).

12/10 Comments on NCSR 5/WP.1 and MSC 99/12 China

China provides comments on implementation difficulties relating to ECDIS software updates. The comments are made from the perspective of statutory surveys.

Three issues are highlighted:

Methods to demonstrate conformity of ECDIS equipment upgrades; Different understanding of ECDIS survey standards; and Implementation difficulties in ECDIS familiarization training.

It is considered that the root cause of recent update implementation issues has been a lack of discussion during the drafting process of ECDIS-related documents regarding how statutory surveys help flag States effectively organize ECDIS upgrades and other related issues.


1. Request NCSR 6 to consider the development of an appropriate instrument or revision of MSC.1/Circ.1503/Rev.1 (if necessary) to unify the implementation of ECDIS upgrades;

2. Request the III Sub-Committee in cooperation with the NCSR Sub-Committee to develop and submit a transitional plan for ECDIS updates to MSC for approval; and

3. Instruct the III Sub-Committee not to revoke III.2/Circ.2 before resolving related implementation difficulties.

The issues raised by China are pertinent. However, it may be preferable to hold back further discussion on this matter until IHO proposes another upgrade. At that stage, NCSR can consider the concerns raised at NCSR 5 and by China in this document, and be more critical in its assessment of any planned implementation schedule.

12/INF.7

Practical issues concerning implementation of the International Regulations for Preventing

China

Collisions at Sea, 1972

China provides information, in the context of the Member State Audit Scheme, on the relevance and applicability of certain elements of the COLREGs. This includes:

The widespread use of AIS, eliminating the need for separate steering and sailing rules for “vessels in sight of one another” and “vessels navigating in restricted visibility”;

The current regime of allocating collision avoidance responsibility, based on an outdated appreciation of the manoeuvrability of different types of vessel; and

The requirements for the sounding of bell and gong as fog signals, on the basis of existing none compliance.

ICS was made aware of a potential submission addressing issues with the implementation of the COLREGs. However, following careful consideration of an advanced draft, ICS expressed reservations regarding the technical content and the reported conclusion that elements of the COLREGs need to be reconsidered.

ITEM 13: SHIP SYSTEMS AND EQUIPMENT

The Committee will consider urgent matters emanating from the fifth session of the Sub-Committee and take action as indicated in paragraph 2 of document MSC 99/13.

Papers:

13 Urgent matters emanating from the fifth session of the Sub-Committee

Secretariat

The Secretariat reports urgent matters emanating from SSE 5. The Committee is invited to:

1. Note the progress made on the development of goals and functional requirements for onboard lifting appliances and anchor handling winches (OLAW) and, in particular, the views expressed on how to address training and certification of crews and shore-based personnel using OLAW (paragraphs 10.13 and 10. 31); and

The issue of training of personnel was raised by China in document SSE 5/10/2. This remains a contentious issue, particularly with regard to the general operation of lifting appliances by shore-based personnel in the case of certain ship types.

The Sub-Committee agreed that lifting appliances and anchoring handling winches should be operated by trained personnel (regardless of who they are) however there was limited discussion on the practical implications of this.

Specifically, the issue of the how the Master should verify that shore-based personnel have been appropriately trained, and the realistic actions they can take if they are not.

2. Note the decision to consider matters related to the development of a draft unified interpretation of SOLAS regulation II-2/9.2.4.2 at a future session when additional information is made available (paragraphs 12.2 to 12.4).

At MSC 98 the Committee had approved a Unified Interpretation (UI) of SOLAS chapter II-2 (MSC.1/Circ.1581) concerning:

Calibration of portable atmosphere testing instruments for cargo areas of tankers;

Fire integrity of space boundaries within tanker cargo areas; and Fire integrity of the bulkheads between the wheelhouse and

navigation lockers inside the wheelhouse of tankers

The original UI text submitted to MSC 98 by SSE 4 (see document SSE 4/19 Annex 9) had included an interpretation for regulation 9.2.4.2 of SOLAS chapter II-2. At MSC 98 it was however noted that this part of the UI might be considered to contradict the relevant regulation of SOLAS and was not included in the UI approved by MSC 98 (MSC.1/Circ.1581).

IACS agreed to give the matter further consideration and advise a future session of the Sub-Committee of progress should they identify a way forward.

ITEM 14: IMPLEMENTATION OF THE STCW CONVENTION

The Committee will receive the Secretary-General's report called for bySTCW regulation I/7, paragraph 2, on those STCW Parties whose evaluations have been completed; and will be invited to identify Parties found to be giving full and complete effect to the provisions of the STCW Convention; and to take appropriate action. The Committee will further receive the Secretary-General's report for the STCW Parties who have communicated their report of independent evaluation pursuant to STCW regulation I/8, paragraph 3, and will be invited to take appropriate action.

The Committee will be further invited to consider, for approval, any new competentpersons nominated by Governments (MSC 99/14) and take appropriate action.

Papers:

14 List of competent persons to be maintained by the Secretary-General pursuant to section A-I/7 of the STCW Code

Secretariat

The Secretariat provides information regarding competent persons made available or recommended by the STCW Parties for inclusion in the list of competent persons maintained by the Secretary-General in accordance with section A-I/7 of the STCW Code, for approval by the Committee.

Section A-I/7 of the STCW Code requires the Secretary-General to maintain a list of competent persons approved by the Committee to serve on panels established to assess information communicated to the Secretary-General.

Information is also provided about the competent persons who have been withdrawn by the Parties.

Annex 1 to the document contains the details of the competent persons nominated by Canada, Israel and Slovenia.

Annex 2 to the document contains the details of the competent persons withdrawn by Japan and the United Kingdom.


Approve the inclusion of five competent persons in the list maintained by the Secretary-General pursuant to section A-I/7 of the STCW Code, as recommended by three STCW Parties; and request the Secretariat to issue MSC.1/Circ.797/Rev.31;

Note the competent persons who have been withdrawn by two STCW Parties; and

Invite STCW Parties to inform the Secretariat of any amendments that

the list of competent persons may require (withdrawals, additions, change of address, etc.), with a view to ensuring that those listed in the latest revision of MSC.1/Circ.797 are available to serve as competent persons and are readily contactable.

ITEM 15: CAPACITY BUILDING FOR THE IMPLEMENTATION OF NEW MEASURES


1. A preliminary assessment of the amendments to mandatory instruments and outputs related to mandatory instruments approved at MSC 98 (MSC 99/15); and

2. Any relevant submissions by Member States and international organizations, regarding capacity-building-related issues, for further consideration of action to be taken, and may establish, as decided at MSC 98, the Capacity-Building Needs Analysis Group (ACAG).

Papers:

15 Assessment of capacity-building implications of amendments to mandatory instruments and outputs related to mandatory instruments approved at MSC 98

Vice-Chair

The Vice-Chair provides the preliminary assessment of capacity-building implications or technical assistance needs related to the draft amendments to mandatory instruments and the outputs related to mandatory instruments approved by MSC 98 and as set out in annexes 2 and 3 of the paper and decide whether the ACAG needs to be established.

ITEM 16: FORMAL SAFETY ASSESSMENT

The Committee will be invited to consider:

1. The report from III 4 with respect to the analysis of input/output speed of the FSA GISIS Marne Casualty Incidents (MCI) module (MSC 99/16); and

2. Any relevant submissions by Member States and international organizations, for further consideration of action to be taken.

Papers:

16 Analysis of the input and output speed of the GISIS MCI module

Secretariat

The Secretariat recalls the discussion at MSC 98 on analysis of the input and output speed of the GISIS MCI module and reports on the relevant outcome of III 4.

ITEM 17: PIRACY AND ARMED ROBBERY AGAINST SHIPS

The Committee will consider an update on developments related to piracy and armed robbery against ships (MSC 99/17) and any other documents submitted by Member States and international organizations under this agenda item, for further consideration of action to be taken.

Papers:

17 Developments since MSC 98 Secretariat

The Secretariat reports on developments related to piracy and armed robbery since MSC 98. It is reported that there were 203 incidents of piracy and armed robbery against ships worldwide in 2017, confirming the downward year on year trend with a reduction of about 8% at the global level.

The Organization is informed that only 20 States have responded to the Questionnaire on information on port and coastal State requirements related to privately contracted armed security personnel on board ships.

With respect to regional developments it is advised that piracy in the Gulf of Aden and Western Indian Ocean has been suppressed but not eradicated through a combination of the use of BMP 4, the presence of military forces and the use of armed guards. In the context of the Yemen conflict, reference is made to the ICS, BIMCO and Intertanko interim guidance on maritime security in the Red Sea and Bab al-Mandeb. It is reported that there are now 14 signatories to the Jeddah Amendment to the Djibouti Code of Conduct, which widens the scope of cooperation under the Code to other areas of maritime security beyond piracy and, the IMO Council requested States and concerned international organisations to consider providing both financial and in-kind support for technical assistance activities in support of the amendment.

The consideration of the Contact Group on Piracy off the Coast of Somalia with respect to the issue of floating armouries is reflected and, it is proposed that the Committee consider taking action with respect to the development of draft guidelines for floating armouries.

Finally, it is noted that the Gulf of Guinea and waters around Nigeria remain a threat to seafarers, with incidents resulting in hijackings of ships and holding crew members for ransom.

17/INF.15

Progress report of the Regional Cooperation Agreement on Combating Piracy and Armed Robbery against Ships in Asia (ReCAAP)

ReCAAP-ISC

ReCAAP-ISC provides an update on its activities since April 2017.

17/INF.18

Standardized reporting of global piracy and armed robbery incidents

Marshall Islands, BIMCO, OCIMF and INTERTANKO

The co-sponsors highlight the major differences in incident type definitions, reporting methods and, statistical analyses of maritime security incidents within and across regions. Concern is expressed that this can lead to the distribution of unreliable data which may serve to artificially elevate or minimize the actual risks to seafarers and ships.

The Committee is advised that an informal working group is to be established to develop harmonized global maritime security incident type definitions and simplify the incident reporting framework.

The information paper provided by the Marshall Islands et al is welcome and highlights a long-standing problem with respect to the classification and reporting of maritime security incidents around the globe. ICS supports the calls for harmonization and will be keen to contribute to the informal working group.

ITEM 18: UNSAFE MIXED MIGRATION BY SEA

The Committee will be invited to consider:1. the outcome of the interagency meeting of relevant United Nations agencies

(MSC 99/18); and2. any other documents submitted by Member States and international

organizations under this agenda item,and to take action as appropriate.

Papers:

18 Outcome of the inter-agency meeting with the maritime industry on mixed migration

Secretariat

The Secretariat reports on the outcome of the inter-agency meeting that included representation from IOM, UNCHR, OHCHR, UNODC, EU NAVFOR, ICS, BIMCO, IFSMA and ITF on mixed migration held on 30 October 2017.

The meeting followed consideration of MSC 98/16 (ICS) which provided information on the increasing death toll of migrants attempting to reach Europe via the central Mediterranean region and invited the Committee to support further action by the Organization, to promote appropriate and effective action at the United Nations and by other United Nations specialised agencies. The Committee noted that the United Nations-led Global Compact for Migration (GCM) was a three-phase approach that could culminate in a United Nations-wide approach to address the issue and that the consultation phase was taking place from April 2017 to November 2017. Pursuant to this initiative, the Secretary-General invited the Heads of concerned international organizations and the main stakeholders of the maritime industry to a high-level inter-agency meeting.

The main views expressed by industry were that:

1. There is a moral and legal obligation established in UNCLOS, SOLAS and SAR Conventions for the shipmasters and crews of merchant ships to rescue people at sea, with no differentiation between refugees, economic migrants, victims of people smuggling or survivors of accidents at sea, and shipmasters should never be asked to make such determinations;

2. Though the obligations of the shipmaster and crew are established in UNCLOS, SOLAS and SAR Conventions none of these conventions were initiated or essentially drafted to cope with issues and situations currently being experienced by commercial shipping in the Central Mediterranean;

3. The current situation in the Central Mediterranean region is potentially a

significant safety and security issue for the crews, as ships are not configured to take on board large numbers of migrants;

4. The shipping industry has concern for the safety and security of Masters and crews called upon to perform rescue at sea. The number of rescued people may significantly exceed the total ship's complement as well as the ship's capacity to provide a safe and secure environment during transit to a place of safety. The long-term psychological effect on seafarers who have conducted large-scale rescues at sea is a further matter of concern to the industry;

5. Under IMO regulations, as appropriate, ships are required to have equipment to conduct recovery operations and crews are required to train and practise rescue/recovery techniques. Such training remains generic and addresses SOLAS requirements rather than any particular global issue;

6. UNCLOS and SOLAS require ships to assist and, as necessary, to rescue people in distress at sea. At the same time UNCLOS and SOLAS place a corresponding requirement on States to provide adequate SAR resources and also to promptly identify and facilitate disembarkation in a place of safety;

7. SAR is an immediate response to an accident – it is not a policy solution, and policy must focus on prevention of hazardous journeys by sea;

8. Current political changes in Europe may make the provision of a disembarkation port more difficult;

9. The Internet provides an ample offer for buying large quantities of inflatable boats, and more stringent control measures for trading these craft should be made;

10. Rescued persons always want to be landed in Europe – any imposed requirement to land in, for example, Libya may create civil unrest among those rescued and lead to the charge that the ship's Master contravened the principle of non-refoulement. The possibility of a Libyan MRCC is a concern;

11. The assets used to rescue migrants are not suited by design for the task of picking up large numbers of migrants.

It is anticipated that EUNAVFOR Med may make a presentation to the Committee on recent developments regarding the EU response to Border Protection Measures in the Mediterranean Sea. It may be noted that ICS continues to participate in EUNAVFOR sponsored ‘Shade Med’ meetings that are hosted by the Italian Navy and that in late April, ICS hosted an Intersessional Shade Med meeting in London. Further intersessional meetings are anticipated to follow the next scheduled Shade Med meeting to be held in Rome during June.

The International Organization for Migration (IOM) provided comment to the meeting including advising that:

1. Policy must focus on prevention of hazardous journeys by sea;

2. Improved cooperation is required to save lives in search and rescue;

3. A safe and secure Mediterranean requires a holistic approach; and

4. Mainstreaming human rights and protecting vulnerable migrants is required, in all stages of migration.

The United Nations High Commission for Refugees (UNHCR) provided comment to the meeting including advising that:

1. Although the Central Mediterranean is currently the most visible, and most deadly, sea route, refugees and migrants resort to dangerous sea crossings in almost all parts of the world: in the Gulf of Aden and Red Sea; in the Caribbean; in the Andaman Sea, the Bay of Bengal, and across South East Asia;

2. This global dimension of protection at sea is important not just because it highlights the need for global responses. It also underlines the need to look beyond current emergencies and to invest in preparedness along with much bolder, forward-looking forms of international cooperation; and

3. UNHCR welcomes the readiness of the shipping industry to uphold its obligations under international maritime law to come to the assistance of anyone – seafarer, commercial passenger, refugee or migrant – in distress, in the face of challenges which have put the SAR system under serious strain. We need to find better ways of protecting the sustainability of that system, so that large-scale – and to some extent expected – movements of refugees and migrants by sea are met with adequate, predictable and cooperative life-saving measures by States, and so that the shipping industry can continue to meet its legal and humanitarian obligations without being asked to play a role that properly falls to others.

ITEM 19: APPLICATION OF THE COMMITTEE'S PROCEDURES ON ORGANIZATION AND METHOD OF WORK

The Committee will be invited to consider the outcome of A 30 on the revised Assemblyresolution on Application of the Strategic Plan of the Organization (MSC 99/19) and anyrelevant documents submitted by Member States and international organizations under this agenda item, for further consideration of action to be taken.

Papers:

19 Outcome of A 30Draft revised Committees' Method of work

Secretariat

The Secretariat present a draft revised document on Organization and method of work of the Maritime Safety Committee and the Marine Environment Protection Committee and their subsidiary bodies (Method of work), following the Application of the Strategic Plan of the Organization (resolution A.1111(30)) adopted by A 30.

The Committee will be invited to consider the draft revised document on Organization and method of work of the Maritime Safety Committee and the Marine Environment Protection Committee and their subsidiary bodies, and the associated draft MSC-MEPC.1 circular set out in the annex to the paper, taking into account the outcome of MEPC 72.

ITEM 20: WORK PROGRAMME

The Committee will consider:1. The biennial status reports of the sub-committees and provisional agendas for

the sub-committees' forthcoming sessions, on the basis of the Strategic Plan for the Organization (for the six-year period 2018 to 2023) and any recommendations and proposals made by the sub-committees (MSC 99/20), and Member States and international organizations;

2. Any relevant submissions by Member States and international organizations; and3. The approval of such intersessional meetings as may be proposed,

Papers:

20 Biennial agendas of the CCC, HTW and III Sub-Committees and biennial status reports of the NCSR, SDC and SSE Sub-Committees and provisional agendas for their forthcoming sessions

Secretariat

The Secretariat provides the biennial agendas of the CCC, HTW and III Sub-Committees and the biennial status reports of the NCSR, SDC and SSE Sub-Committees and the provisional agendas for their forthcoming sessions.

20/1 Proposal for a new output on the development of performance standards for Navigation Decision Support System (NDSS) for Collision Avoidance (CA)

Israel and Poland

The co-sponsors invite IMO to undertake work to develop a performance standard for Navigation Decision Support System for Collision Avoidance (NDSS CA). These systems are already commercially available.

It is suggested that NDSS CA will become an integral component of navigation decision support in the future, as it is intended to overcome the limited effectiveness of ARPA by utilizing AIS data.

It is proposed that the Organization develop a performance standard to assist in the process of approval for such systems. The intent is to achieve effective and harmonized means of supporting the Bridge Team in deciding on the optimum action to avoid collision in compliance with the International Regulations for Preventing Collisions at Sea, 1972 (COLREG).

The co-sponsors request inclusion in the current or upcoming biennium agenda of the NCSR Sub-Committee the new item on "Development of performance standards for Navigation Decision Support System for Collision

Avoidance".

AIS data should not be used to inform action to avoid collision. This system may not be consistent with the Organization’s own guidance on the use of AIS.

ICS thanks Israel and Poland for document MSC 99/20/1. Whilst understanding the intention of the proposal, we recommend that the following observations are taken into account:

It is unclear whether there is indeed a compelling need to develop a performance standard for a system which is not a mandatory carriage requirement.

We also question whether a performance standard which formalises the role of AIS data in collision avoidance is compatible with the cautions provided in the Revised guidelines for the onboard operational use of shipborne automatic identification systems (AIS) in resolution A.1106(29).

Finally, decision support systems can be reasonably expected to fall within the scope of the regulatory scoping exercise for MASS. Whilst this would depend on definitions agreed, it would seem premature to agree to work on a related new IMO instrument before the scoping exercise is concluded.

UK Position: The UK opposes the proposal for a new output on the development of performance standards for Navigation Decision Support System (NDSS) as COLREG requirements are currently adequate. The EU has full reservation on this paper but can support proposal in the next biennium.

20/2 Revision of the lowering speed of survival craft and rescue boats

Japan

Japan proposes a new output for the amendment to the LSA Code with regard to the lowering speed of survival craft and rescue boats.

Japan considers that increases in the sizes of ships was not taken into consideration at the time of development of the requirement for lowering speed of survival craft and rescue boats in the LSA Code and that an excessive lowering speed is dangerous. Therefore, the minimum lowering speed should be reviewed for safety, taking into account the increase of the sizes of cargo ships in recent years.

The requirement in paragraph 6.1.2.8 of the LSA Code prescribes the minimum lowering speed of survival craft and rescue boats without the upper

bound of the minimum lowering speed. Japan deems it appropriate to set the upper bound of the minimum lowering speed.

Japan request the inclusion, in the 2018-2019 biennial agenda of the SSE Sub-Committee and the provisional agenda for SSE 6, of a new output on "Revision of the lowering speed of survival craft and rescue boats".

UK Position: The UK supports the proposal for a new output for the amendment to the LSA Code with regard to the lowering speed of survival craft and rescue boats. This will enhance the safety of seafarers during lowering condition of lifeboat and rescue boat.

20/3 Proposal for a new output for a revision of resolution A.857(20) on Guidelines for Vessel Traffic Services

Australia, China, India, Norway, Republic of Korea, Singapore, South Africa, Turkey, IALA, IAIN, IFSMA, IHMA, and NI

The co-sponsors propose a new output for the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR) for a revision of resolution A.857(20) on Guidelines for Vessel Traffic Services.

This is to ensure that the resolution is modernized/updated and that it continues to serve as an effective instrument, providing a clear framework to implement VTS globally in a harmonized manner.

The co-sponsors suggest that whilst most of the principles in the document remain relevant, amplifying guidance and documentation, advances in equipment and training and the lessons learned from years of experience in operating VTS have revealed significant parts of the document where the text is now considered to be ambiguous or subjective. This has resulted in the resolution being open to differing interpretation and debate amongst Contracting Governments, Competent Authorities, VTS Authorities, mariners and allied services.

The co-sponsors request the Committee to approve the revision of resolution A.857(20) as a new output in the 2018-2019 biennial agenda.

ICS thanks IALA and the co-sponsors for document MSC 99/20/3. ICS recommends support, in principle, for the work to update resolution A.857(20) particularly in light of the extensive work done by IALA on

maintaining standards, recommendations and guidance for VTS.

VTS plays a valuable role within territorial waters (TTW), particularly in the approaches to ports. However, paragraph 13.2 regarding changes in traditional boundaries is of concern. ICS considers that beyond TTW it is the demonstrably effective measures adopted by this Organization which ensure that shipping traffic can navigate safely and without the need for additional information or coordination.

ICS questions whether there is justification for the Organization to encourage VTS beyond TTW, even on a recommendatory basis. and therefore recommends that work on updating resolution A.857(20) should not seek to encourage further changes in the boundaries for VTS.

20/4 Proposal for a new output on the application of the Quasi-Zenith Satellite System (QZSS) in the maritime field

Japan

Japan proposes inclusion of a new output in the agenda of the NCSR Sub-Committee to recognize the Japanese Regional Navigation Satellite System called Quasi-Zenith Satellite System (QZSS) as a future component of the World-Wide Radionavigation System (WWRNS) and develop performance standards for shipborne QZSS receiver equipment.

In addition, Japan proposes that QZSS be given due consideration in the development of guidelines associated with multi-system shipborne radio navigation receivers dealing with the harmonized provision of PNT data and integrity information.

Japan is establishing an independently-operated Asia-Oceania regional satellite navigation system called QZSS. QZSS is highly compatible with the Global Positioning System (GPS) maintained by the United States, and it is designed to provide all-weather and all-time positioning, navigation and timing services for users with accuracy and reliability in the Asia-Oceania region.

Japan requests inclusion of this proposal in the agenda of the NCSR Sub-Committee as a new output.

20/5 Proposal for a new output on fire resistance requirements of damping materials for reducing noise and vibration level applied in "A" and "B" class divisions

China

China proposes that in order to meet the requirements of the Code on noise levels on board ships (resolution MSC.337(91)), materials used in engineering

applications to reduce noise and vibration level are mainly damping materials, which can bring potential fire risk and reduce fire safety level.

They propose a new output on fire resistance requirements of damping materials applied in "A" and "B" class divisions, to ensure fire safety level and human life safety, as well as to facilitate the consistent application of SOLAS requirements and the Noise Code.

China requests that a new output is included in the 2018-2019 biennial agenda of the SSE Sub-Committee, i.e. the new output on "Fire resistance requirements of damping materials for reducing noise and vibration level applied in "A" and "B" class divisions", with one or two sessions needed for completion of the work.

ICS considers that China has identified a potential regulatory gap and supports their proposal for a new output for this matter. Should the work identify a need for amendments to fire protection instruments to assure safety then ICS considers that such amendments should be developed as an urgent matter.

UK Position: UK opposes China’s proposal for a new output on fire resistance requirements of damping materials for reducing noise and vibration level applied in “A” and “B” class divisions. The paper implies the damping material is not fireproof. The UK agrees that combustible material is to be avoided.

20/6 Proposal for a new output to amend the liferaft requirements of the SOLAS Convention

China

China proposes a new output to amend the liferaft requirements of the SOLAS Convention, in order to improve the effectiveness of liferafts and the safety of life at sea.

There is no requirement in SOLAS stating that liferafts on ships other than ro-ro passenger ships shall be either automatically self-righting or canopied reversible.

With large-size liferafts being widely used on board not only ro-ro passenger ships but also all passenger and cargo ships, seafarers may be incapable of righting liferafts, especially when being injured, exhausted or in adverse sea conditions. Safety risks are foreseeable during the righting of a liferaft (e.g. seafarers may be trapped under the bottom of the liferaft).

China therefore proposes that all passenger and cargo ships should be equipped with automatically self-righting or canopied reversible liferafts (except for liferafts with a capacity of no more than six persons) and, consequentially, to amend regulations 21, 26 and 31 of chapter III of SOLAS

and regulations 4.2 and 4.3 of chapter IV of the International Life-Saving Appliance (LSA) Code.

China requests the Committee consider this proposal and its justification and to include it into the current or upcoming biennium agenda of the SSE Sub-Committee as the new output titled "Amendments to the liferaft requirements of the SOLAS Convention". It is envisaged to take one to two sessions to complete it.

ICS has concerns that there this potentially expensive amendment is not fully supported by a compelling need.

UK Position: The UK supports in principle the proposal from China for a new output to amend the life raft requirements of the SOLAS Convention. Due to the LSA group workload, the UK also proposes that this should be taken to the next biennium.

20/7 Proposal for a new agenda item to amend the definition of 'Group A' in the IMSBC Code

Australia, Brazil, China, the Philippines, BIMCO and INTERCARGO

The co-sponsors propose a new agenda item for the Sub-Committee on Carriage of Cargoes and Containers (CCC) to amend the definition of "Group A" in the IMSBC Code to include phenomena other than "liquefaction".

During the 2016-17 biennium, the Global Bauxite Working Group (GBWG) carried out a study into the liquefaction of bauxite.

The GBWG identified a new mechanism which related to the moisture content of cargo. Noting that the IMSBC Code currently addresses moisture content mechanisms within the definition of Group A and that liquefaction is currently the only such mechanism defined, the GBWG recommended that further consideration be given to the classification category of Group A "liable to liquefy" cargoes (CCC 4/5/1/Add.1, paragraphs 10 and 25.4).

It was agreed that the phenomenon was, like liquefaction, a cargo property related to moisture content that adversely affects the stability of a ship, however, it was not liquefaction, as currently defined in the IMSBC Code as Group A.

The co-sponsors therefore request the Committee to include the new output in the 2018-2019 biennial agenda of the Sub-Committee on Carriage of Cargoes

and Containers, to enable proposals to be submitted to the fifth session of the Sub-Committee to amend the definition.

Given that following the Bulk Jupiter casualty the GBWG was formed and their conclusions are as outlined above, ICS can support the need for an amendment to the definition in the IMSBC Code of Group A cargoes, subsequent to which it is anticipated that bauxite would be amended within the Code to include as Group A & C cargoes, depending on the cargo composition.

ICS thanks the co-sponsors for their paper MSC 99/20/7 and supports the request for a new output to enable proposals to amend the definition of Group A “liable to liquefy” cargoes in the IMSBC Code.

20/8 Proposal for a new output to amend paragraph 4.4.7.6 of the LSA Code

Marshall Islands, Panama, ICS, BIMCO, INTERCARGO, IPTA,IMCA, IBIA and ITF

ICS proposes a new output to be included in the biennial agenda of the Sub-Committee on Ship Systems and Equipment (SSE), concerning the amendment of paragraph 4.4.7.6 of the LSA Code.

The paper highlights the need to amend paragraph 4.4.7.6 of the LSA Code in order to ensure adequate safety standards for boats with single fall and hook systems, and proposes a new output for inclusion in the biennial agenda of the Sub-Committee on Ship Systems and Equipment (SSE).

The paper identifies that whether lifeboats have single fall or twin fall arrangements the risks associated with each are similar and as such should have similar safety standards.

The co-sponsors therefore request the Committee to consider the proposal and approve a new output to amend paragraph 4.4.7.6 of the LSA Code for inclusion in the 2018-2019 biennial agenda of the Sub-Committee on Ship Systems and Equipment (SSE) and the provisional agenda for SSE 6.

The paper therefore aims to ensure consistency of standards for all lifeboats, to mitigate risks associated with accidental release during recovery operations and thereby preventing accidents or injuries

This document will be introduced by the Marshall Islands.

UK Position: The UK supports the proposal for a new output to amend paragraph 4.4.7.6 of the LSA Code as the amendment will provide further clarification on the application of the requirements.

20/9 Proposal for a new output concerning amendments to the Code of Safety for Diving Systems and resolution A.692(17)

Russian Federation, Vanuatu, IMCA and IOGP

The co-sponsors propose a new output concerning amendments to the Code of Safety for Diving Systems (resolution A.831(19)) and the Guidelines and specifications for hyperbaric evacuation systems (resolution A.692(17)).

The main aim of the proposal is to enhance commercial diving safety by amending resolutions A.831(19) and A.692(17) to reflect the experience and knowledge gained by the industry since the last reviews of these instruments were conducted around 27 years ago in the case of the Guidelines and 23 years ago in the case of the Code of Safety. In addition, the proposal aims to harmonize the IMO instruments and industry guidance relevant to commercial diving systems and hyperbaric evacuation systems.

The two main areas of focus for the proposed review are the application of the IMO diving instruments and evacuation arrangements for saturation divers.

Since the adoption of the aforementioned resolutions, the offshore sector has made great strides in the provision and use of hyperbaric evacuation systems. New and detailed industry guidelines on hyperbaric evacuation systems have been prepared by the International Marine Contractors Association (IMCA), the International Association of Oil and Gas Producers (IOGP), and the classification societies.

The co-sponsors are of the view that it is now imperative that the new industry guidelines should stimulate re-evaluation and revision of the IMO diving instruments, as per paragraph 3 of the Preamble to the Code. Failure to ensure that contemporary industry guidelines are fully reflected in the Code may well have adverse implications for human safety. In order to achieve its aims, and successfully protect persons who engage in offshore diving operations, the Code should be updated to ensure it reflects current industry best practice and modern safety management.

The co-sponsors therefore request the Committee include this output in the 2018-2019 biennial agenda.

UK Position: The UK supports the proposal for a new output concerning amendments to the Code of Safety for Diving Systems and resolution A.692(17).

20/10 Proposal for a new output to amend the Standardized Life-Saving Appliance Evaluation and Test Report Forms

United States and ILAMA

The c o-sponsors propose a new output to amend the Standardized Life-Saving Appliance Evaluation and Test Report Forms (MSC/Circ.980).

The aim of this proposal is to update the forms to incorporate the amendments to the International Life-Saving Appliances (LSA) Code and the Revised recommendation on testing of life-saving appliances (resolution MSC.81(70)) that have occurred since MSC/Circ.980 and its two addenda were approved by MSC 73, in February 2001.

The Committee has adopted seven amendments to the LSA Code and eight amendments to resolution MSC.81(70) since 2001, when MSC/Circ.980 and its addenda were approved. These amendments, which encompass a wide variety of LSA and arrangements, were adopted with no corresponding revisions to MSC/Circ.980 and its addenda.

The Committee is invited to:1. Agree that MSC/Circ.980 forms should be revised to incorporate

amendments to the LSA Code and resolution MSC.81(70) adopted since 2001 (paragraphs 4 to 16);

2. Agree that the impact on MSC/Circ.980 and its addenda will be evaluated with any future amendments to the LSA Code and resolution MSC.81(70), taking into account MSC.1/Circ.1500 (paragraph 11); and

3. Add the output to the agenda of the SSE Sub-Committee (paragraph 17).

The co-sponsors recommend the proposed output should be included in the Strategic Plan of the Organization, with SSE as the associated organ, and should be completed in no more than two sessions.

UK Position: The UK supports the proposal for new output to amend the Standardized Life-Saving Appliance Evaluation and Test Forms. The UK agrees that this will provide a clear and more concise format to conduct and record the tests under MSC.81(70) Part 1. The UK agrees that the forms are out of date and it is suggested that the work should go to SSE 7 due to the current work load of the LSA group.

20/11 Comments on document MSC 99/20/10 Dominica

Dominica supports document MSC 99/20/10 (United States and ILAMA), with regards to the urgency of a new output to amend the Standardized life-saving appliance evaluation and test report forms (MSC/Circ.980).

20/12 Comments on document MSC 99/20/4 Germany

Germany supports in general with comments and proposes amendments to the proposal for a new output contained in document MSC 99/20/4.

It is proposed that consideration is given to the merit of developing a more generic approach to developing performance standards for all shipborne GNSS receiver equipment. The two performance standards, including the output proposed in document MSC 99/20/4, to be discussed simultaneously by the Sub-Committee, could serve as the basis to develop a standard without requiring significantly more resources.

Germany requests the Sub-Committee to look at possible ways to take a more generic route when developing the required performance standards,

Germany proposes the following amendments to the proposed output:"Recognition of QZSS as a component of the WWRNS and development of performance standards for shipborne satellite navigation system receiver equipment applicable to WWRNS."

20/13 Comments on document MSC 99/20/10 ISO

ISO comments on document MSC 99/20/10 and addresses the need for minor corrections to references to standards for material tests for inflatable liferafts and hydrostatic release unit membranes in the Revised recommendation on testing of life-saving appliances (MSC.81(70)), as amended.

ISO proposes that the corrections do not constitute any actual changes to the testing requirements and as such may be addressed as a minor correction at this session in accordance with the decision taken at C/ES.27.

If the Committee agrees with the understanding provided in paragraph 8, then it is proposed to amend the relevant parts of the Revised recommendations, as set out in annex 1, by:

1. Replacing the references to the withdrawn standard ISO/TR 6065:1991 and instead including a reference to the identical tests contained in standard ISO 15372:2000; and

2. Replacing references to the standard test oil ASTM No. 1 and ASTM No.5 by including references to IRM 901 and IRM 905, respectively.

If the Committee agrees to the proposal in document MSC 99/20/10, then it is proposed to include any consequential amendments from this minor correction in the instructions to SSE 6.

UK Position: The UK supports the ISO proposal which addresses the need for minor corrections to references to standards for material tests for inflatable life rafts and hydrostatic release unit membranes in the Revised recommendation on testing LSAs. The minor correction could be agreed at this session without

requesting a new agenda item. The UK supports all the proposals in the paper.

20/INF.6

Relevant information on damping materials and their application on ships and fire test results

China

China provides relevant information on damping materials and their application on ships and fire test results with respect to document MSC 99/20/5 on a new output on fire resistance requirements of damping materials for reducing noise and vibration level applied in "A" and "B" class divisions, with a view to reducing the potential fire hazard of damping materials to ensure the safety of human life.

ITEM 21: ANY OTHER BUSINESS


1. Thematic priorities for the Integrated Technical Cooperation Programme (ITCP) for 2018-2019 (MSC 99/21);

2. An update on IMO/IACS cooperation on the IACS QSCS (MSC 99/21/1);3. Decisions taken by the Council at its 118th regular and twenty-ninth extraordinary

sessions relating to applications for granting consultative status to interested international non-governmental organizations (MSC 99/21/2);

4. Matters of significance concerning relations with other organizations, which are relevant to the work of the Committee;

5. Information on developments on GISIS (MSC 99/INF.2); and6. Any other submissions by Member States and international organizations which

may be received under this agenda item, and take appropriate action.

Papers:

21 Technical cooperation activities related to maritime safety, maritime security andfacilitation

Secretariat

The Secretariat advises the Committee on technical cooperation activities in relation to subjects under the purview of the Maritime Safety Division (MSD). It is reported that in addition to the TC activities delivered by MSD through ITCP funding, the MSD also administers the Enhancement of Maritime Security (global programme) with the associated International Maritime Security Trust Fund; the West and Central Africa Maritime Security Project and; support to the implementation of the Djibouti Code of Conduct. The list of the relevant technical cooperation activities carried out during 2017 is provided at the annex.

21/1 IMO/IACS cooperation on the IACS Quality Certification Scheme

Secretariat

The IMO Secretariat provides in the annex to the document the report of the IMO consultant/observer in relation to developments of the IACS Quality System Certification Scheme (QSCS) as part of the participation agreement between IMO and IACS. Notably it is reported that:

QSCS activities observed during 2017/18 indicates a high level of expertise and experience in the audit and administration of QSCS, which serves to ensure the Scheme consistently applied across the IACS membership, is high quality and fit for purpose; and

With a vigorous well led IACS Quality Committee and continued substantive resource investment on behalf of IACS members, the continued improvement of IACS QSCS is the objective of all parties.

The Committee is requested to:

1. Consider a proposal to agree the indefinite continuation of the IMO consultant/observer participation in the Scheme at no cost to the Organization; and

2. Offer its appreciation of Mr. Howard's contribution to the work of the Organization in his role as IMO consultant/observer for the past nine years

ICS thanks the IMO Secretariat for providing the valuable report of its Observer to QSCS Mr David Howard.

ICS has no doubt as to the importance of the IACS Quality System and Certification Scheme, QSCS, and its effective implementation in ensuring the provision by Classification Societies of class and statutory services to an acceptably high standard to the benefit of all stakeholders including shipowners and operators, member States of the IMO and of course the general public.

ICS is therefore extremely pleased to note the observer’s remarks that indicate there is a high level of expertise and experience in the audit and administration of QSCS, which serves to ensure the Scheme consistently applied across the IACS membership, is high quality and fit for purpose.

Finally, ICS, notes that the current IMO QSCS Observer Mr David Howard is retiring after 9 years and we would like to take this

opportunity to thank David for his hard work and dedication to quality matters and we wish him well for the future.

21/2 Draft revision of MSC/Circ.1065 on IALA Standards for training and certification of Vessel Traffic Service (VTS) personnel

IALA

IALA provides a draft revision of MSC/Circ.1065 on IALA Standards for training and certification of Vessel Traffic Service (VTS) personnel. The revisions include updated reference to new IALA model courses and editorial improvements.

21/3/Rev.1 Lessons learned from the casualty during the trial of an azimuth stern drive tug

China

China provides information regarding the lessons learned from the casualty during the sea trial of the azimuth stern drive (ASD) tug JMS Delta.

The outcomes of a simplified quantitative analysis of simulated manoeuvring tests resulted in the following lessons learned:

ASD tugs should not conduct manoeuvring tests at a high speed (circa 11 knots);

Proactive measures for azimuthing thrusters to limit engine power, steering angle, etc. should be considered; and

Operators of should be trained in azimuthing propulsion and steering systems, and understand the stability risks when operating ASD tugs at high speed.

It is proposed that a gap analysis of SOLAS and the STCW Convention is undertaken, to address the need for measures to limit engine power and steering angle on ASD tugs, and provide for adequate training of ASD tug operators.

This submission should be read with MSC 99/21/4 (China).

21/4 Considerations on lessons learned from the casualty during the trial of an azimuth stern drive tug

China

China provides a report of the outcome of a gap analysis of the existing regulations of SOLAS and the requirements of the STCW Convention referred to in MSC 99/21/3/Rev.1.

It is proposed that, at a future session, the Committee considers a comprehensive package of work to address identified gaps in training and technical requirements for azimuthing propulsion and steering systems.

The submission is designed to assess the level of support for work to respond to the JMS Delta incident referred to in MSC 99/21/3/Rev.1.

21/5 Development in meteorological services and revision of MSC.1/Circ.1293 on Participation in the WMO Voluntary Observing Ships scheme

WMO

WMO proposed non-controversial updates to MSC.1/Circ.1293 on Participation in the WMO Voluntary Observing Ships' (VOS) Scheme. The purpose is to provide the clarity needed to for global and consistent

implementation of SOLAS regulation V/5 and to revise outdated references.

The updates include an annex with a revised information on The voluntary observing ship scheme (VOS). This information has been considered and finalized by WMO and its member States.

No substantive change is made to the VOS which would impact on existing and future participating companies and ships.

21/6 Uniform wording in MSC.1/Circ.1586 and related instruments

Democratic People's Republic of Korea

The Democratic People's Republic of Korea proposes a minor correction to FAL.2/Circ.131, MEPC.1/Circ.873, MSC.1/Circ.1586, LEG.2/Circ.3 and related issues.

In the annex to the circular, the contents for "Stability information" and "Bulk Carrier Booklet" use two different expressions, "stability information" and "intact stability booklet", for one object.

The Democratic People's Republic of Korea proposes the following modification to the contents for "Bulk Carrier Booklet:

Bulk Carrier BookletTo enable the master to prevent excessive stress in the ship's structure, the ship loading and unloading solid bulk cargoes shall be provided with a booklet referred to in SOLAS regulation VI/7.2. The booklet shall be endorsed by the Administration or on its behalf to indicate that SOLAS regulations XII/4, 5, 6 and 7, as appropriate, are complied with. As an alternative to a separate booklet, the required information may be contained in the intact stability booklet stability information.

The following instruments were identified for consequential amendments:

1. Procedures for Port State Control (Assembly Resolution A.1119(30));2. Unloading of Bulk Carriers (BLU) Code;3. International Maritime Solid Bulk Cargoes (IMSBC) Code; and4. Guidelines for Verification of Damage Stability Requirements for Tankers

(MSC.1/Circ.1461).

21/7 Information on closure of seaports in the temporarily occupied Autonomous Republic of Crimea and the city of Sevastopol, Ukraine

Ukraine

The Ukraine draws the attention of the Committee to the closure of seaports in the Republic of Crimea and the city of Sevastopol.

21/8 Consideration of fire protection of control stations on cargo ships

Belgium and Luxembourg

The co-sponsors provide an analysis of the problems regarding the fire protection of control stations on cargo ships, including tankers referring to discussions and decisions made at FP 56 in January 2015.

The co-sponsors identify 2 options which apparently were identified at FP 56 as follows for the consideration of the Committee:

A proposal for a new output on this subject with a view to amending SOLAS (presumably the addition of "and in control stations" to regulations II-2/7 5.5.1, 5.5.2 and 5.5.3). This would be a follow-up to the invitation in the FP 56 report; and

A proposal for a new unified interpretation, based on the fact that the first paragraph of SOLAS regulation II-2/7.5.5 imposes a fixed fire detection and fire alarm system in control stations while regulation II-2/9.2.3.1.1 does not exempt them from having such a system. This could be called the minority viewpoint during FP 56

ICS notes the conclusion of the sub-committee at FP 56 in January 2013 on this subject as detailed in its final report FP56/23 see paragraph 9.19 “The Sub-Committee, recognizing that the problem deserved further attention and should be resolved through developing and adopting a relevant SOLAS amendment, agreed to the interpretation proposed by IACS, as an interim measure, for inclusion in the draft MSC circulars containing the interpretations agreed at this session (see paragraph 9.36), pending possible future amendments to SOLAS.

Consequently, the Sub-Committee invited Member States and international organizations to submit a relevant proposal for a new output to the Committee, in accordance with the Committees' Guidelines (MSC-MEPC.1/Circ.4/Rev.2)”.

ICS thanks Belgium and Luxembourg for their submissions which relates to discussions held in January 2013 at FP 56. ICS having reviewed the report of FP 56 does not recognise either of the options as detailed in paragraph 4 of the submission as having been brought

forward the way described particularly the references to minority viewpoint in paragraph 4.2 and the presumption in paragraph 4.1.

ICS believes that further careful consideration and clarification of this matter will be necessary before any decisions should be made concerning any possible SOLAS amendments and that to discuss this matter further Member States and international organizations should be invited to submit a relevant proposal for a new output with justifications.

21/9 New GISIS module on National Maritime Legislation

Secretariat

The Secretariat reports on a new GISIS module on National Maritime Legislation.

21/10 IMO Member State audit scheme WMO

Noting that the Member State Audit Scheme became mandatory in January 2016 and the nature of guidance previously provided by IALA and IHO that has been incorporated into the Auditor’s Manual for the scheme the World Meteorological Organization (WMO) provides additional guidance in the context of resolution A.1067(28) on Framework and Procedures for the IMO Member State Audit Scheme, within its area of competence.

The WMO provides guidance at the annex to its submission which is intended to assist Member States and the IMO audit team in relation to service standards of met-ocean information services complying with SOLAS regulation V/5.

21/11 Requirements for practical seating arrangements in survival craft

Marshall Islands and RINA

The Marshal Islands and RINA, provide observations on the subject of personal mobility and practical seating capacity in survival craft. The document states that the application of minimum seating space may lead to unintended and dangerous crowding on survival craft.

Referencing the work carried out and reported to the organisation by Norway under the scope of SARex1 (SSE 4/15 and SE 4/15/1) the co-sponsors raise concern that the current LSA Code seating arrangements for lifeboats are inadequate to allow movement within a lifeboat once seated. It is noted that movement may be required to attend to sanitary requirements or when afflicted by seasickness as well as for necessary exercise.

Together with outdated space requirements that do not allow for bulky clothing and the increase in average size of humans over time, as well as for the above reasons it is necessary to reconsider the space allocation on LSA.

The cosponsors propose further consideration of the need to develop a practical seating arrangement designed for the occupation of a survival craft by crew and passengers when rescue facilities are not rapidly available, for example any period longer than 60 minutes, additional space is likely to be required for the following:

1. Walkway space in front of all seat positions to enable the occupants to leave their seats and return to them without the need for adjacent occupants in the same row of seats to leave their seats;

2. Sleeping spaces for those who cannot sleep in the seated position;

3. Space for any increase above the current LSA Code minima of water and food rations required by the maximum expected time of rescue, by the designed external environmental conditions, or by a combination thereof;

4. Space for sanitary facilities that will discharge overboard; and

5. Space to treat survivors who are injured, unable to sit, and must be cared for in a horizontal position.

ICS welcomes the information provided by the Marshall Islands and RINA in MSC 99/21/11 and agrees that the concerns raised require careful consideration.

It will be appropriate for this consideration to also address the work carried out by the Correspondence Group on Life-saving Appliances Correspondence Group (CG) that will before SSE 6 consider three related items:

1. Safety objectives & functional requirements of the Guidelines for alternative design & arrangements for SOLAS III;

2. New requirement for ventilation of survival craft; and

3. Life-saving appliances and arrangements for ships operating in polar waters.

These various CG considerations together with the issues raised in

MSC 99/21/11 will very likely lead to the development of requirements for new LSA that bears little similarity to LSA of a type and design that has been generally fitted to ships for generations.

Whether or not the anticipated eventual amendments to the LSA Code are supported by industry, it may be appropriate to question whether ever more complex LSA equipment with associated increased requirements for complex system maintenance remain appropriate.UK Position: The UK supports in principle the proposals; however it does not support the parameters detailed in the paper. Instead the UK would like to open a discussion as a new agenda item.

21/12 Consideration of the continuous update and use of the list of non-mandatory instruments


The Democratic People's Republic of Korea seeks clarification on the relationship between MSC.1/Circ.1371 and the "Non-mandatory Instruments" module of GISIS.

21/13 Substantive error in the text of the Polar Code Russian Federation

The Russian Federation draws attention to the substantive error in the text of the part I-A of the Polar Code and suggests that the Committee considers the matter and instructs the Secretariat to make a correction.

The Russian Federation suggests that the Committee considers the following correction* to the text of paragraph 1.3.1 of part I-A of the Polar Code:

"1.3.1 Every ship to which this partCode applies shall have on board a valid Polar Ship Certificate."

21/14 Proposal for a unified interpretation of the term "conning position" referred to in SOLAS regulations


The Democratic People’s Republic of Korea (DPRK), proposes an interpretation of the term ‘conning position’ which is referenced in regulations in the 1974 SOLAS Convention.

The DPRK advises that existing interpretation of the SOLAS requirements for locating a ship’s ‘conning position’ can variously refer to a location(s) in the wheelhouse and to a position(s) on the bridge wing.

It is proposed that in order to promote a common understanding between ship designers, surveyors and port State control a unified interpretation of the term, ‘conning position’ based on a position within the wheelhouse from which a ship is commanded, manoeuvred and controlled is established.

ICS thanks the Democratic People’s Republic of Korea (DPRK), for this submission and notes the concern that various reported interpretations have led to the proposal for a unified interpretation of the term ‘conning position’.

The submission does not however provide evidence of a problem that needs to be addressed or the circumstances of any problem that may have occurred.

Without further information being provided, ICS therefore considers it premature to agree to a UI on this matter particularly in light of existing class rules that already address this topic.

UK Position: The UK opposes the proposal for a unified interpretation of the term “conning position” referred to in SOLAS regulations as this is not necessary as it is well defined in ISO standard.

21/15 The Ocean Cleanup's deployment in the North Pacific

Netherlands and Vanuatu

The Netherlands and Vanuatu provide information on the maritime safety aspects of The Ocean Cleanup’s deployment in the North Pacific.

Reference is used to the use of AIS, navigation lights, satellite tracking and position forecasting and the broadcasting of information to ships. This will supplement information provided in notices to mariners in the North Pacific.

This submission largely reflects MEPC 72/16/4 (Netherlands) which provided

information on the environmental aspects of the deployment. In response to the submission, concerns were raised by Member States regarding the visibility of the booms.

ICS would like to thank the Netherlands and Vanuatu for this submission, in particular the recognition that international shipping is very supportive of this innovative and ambitious project.

Whilst traffic in the deployment area is limited and the risks of a collision are anticipated to be low, the impact on the project could be significant in the event of a collision. In this regard, ICS appreciates the information provided in paragraphs 11 to 13 of the submission and its annex, which should provide re-assurance that appropriate steps will be taken to enable the location and identification of the boom during the deployment.

21/16 Standardization of casualty investigation process

Islamic Republic of Iran

Withdrawn.

21/17 Comments on document MSC 99/21/7 Russian Federation

The Russian Federation comments on document MSC 99/21/7 (Ukraine)

21/INF.2

Global Integrated Shipping Information System (GISIS)

Secretariat

The Secretariat informs the Committee of the status of the Global Integrated Shipping Information System (GISIS).

21/INF.4

Information on a research project regarding container weights

South Africa

The document provides information research conducted by the Citrus Growers Association in South Africa regarding the actual tare mass of reefer containers versus the tare mass indicated on the unit. It is reported that 55 CTUs were sampled and that of those, 10 were 1-3% lighter than the indicated tare mass, 3 were accurately declared and 42 weighed between 1 and 18% more than the tare mass indicated on the unit. The Committee is invited to note the information provided.

Whilst the information provided is interesting, the small sample size of the study would suggest that further studies are required before any action is

taken with respect to the VGM requirements and, in particular, the method 2 methodology for establishing the gross mass of a container.

21/INF.10

Summary of a survey carried out into the implementation of requirements formandatory weighing of containers

FONASBA

FONASBA summarises the findings of a survey carried out in mid-2017 to ascertain if the implementation of IMO mandatory requirements for the verification of the gross mass (VGM) of packed containers was being correctly implemented and, if the implementation had resulted in any discernible changes to trade patterns.

The findings of the FONASBA study are both welcome and encouraging and demonstrate that compliance with the VGM requirements continues to be high and does not present a barrier to efficient trade.

21/INF.11

Improved safety of pilot transfer arrangementresults of safety campaign/survey

IMPA

IMPA provides the outcome of 2017 safety campaign and survey on pilot transfer arrangements. The results suggest that regulatory action on pilot transfer arrangements (SOLAS regulation V/23 and Assembly resolution A.1045(27)) has not yielded the anticipated improvements in safety.

21/INF.12

Industry guidance on the development of a Polar Water Operational Manual

ICS and OCIMF

ICS and OCIMF advise of an initiative to produce industry guidance for the development of a Polar Water Operational Manual (PWOM), which must be carried on board ships under the requirements of the International Code for Ships Operating in Polar Waters.

The co-sponsors recognise the need for suitable guidance to assist the development of a ship's PWOM. Consequently, ICS and OCIMF have agreed to develop such a guidance document and subsequently formed a working group (WG) to carry out this task. It is anticipated that industry guidance on developing the PWOM will be based on appendix II (Model table of contents for the Polar Water Operational Manual (PWOM)) of the Polar Code.

It is further anticipated that the joint industry guideline will be completed in 2019. When complete the industry guidelines will be submitted to the Committee for information and for any action that may be deemed appropriate.

Documents

€¦ · Web viewWG 1Working Group on goal-based standards (agenda item 6) WG 2Working Group on Maritime Autonomous Surface Ships (agenda item 5) [WG 3]Working Group on safety