IMO III 10: Updates on the application of remote surveys, audits and verifications

The 10th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 10) took place from 22 to 26 July 2024. The Sub-Committee continued its work on remote surveys, ISM audits and ISPS verifications. It also considered marine safety investigation reports and continued its work on amendments to the Survey Guidelines under the Harmonized System of Survey and Certification and to the Procedures for Port State Control.

Statutory News 19Relevant for ship owners and managers, Port State Control and flag states

Meeting highlights

  • Reviewed lessons learned from accident reports
  • Continued working on guidance on remote surveys, ISM Code audits and ISPS verifications
  • Continued working on the amendments to the survey guidelines under the Harmonized System of Survey and Certification (HSSC)
  • Continued working on the amendments to procedures for Port State Control (PSC)

Remote surveys, ISM audits and ISPS verifications

III 10 continued its work on the development of guidance on the application of remote surveys and International Safety Management (ISM) Code audits under ordinary circumstances. The guidance for surveys will be included in the survey guidelines under the Harmonized System of Survey and Certification (HSSC), while the guidance for remote ISM Code audits will be included in the guidelines for administrations on implementation of the ISM Code.

It was agreed that interim, initial, renewal and additional ISM Code company audits should be conducted in person, except for interim audits when a new ship type is to be added to an existing DOC. The draft guidance proposes to open for conducting annual audits remotely.

International Ship and Port Facility Security (ISPS) verifications should be carried out in person due to the sensitive nature of data. Therefore, remote ISPS verifications can only be performed under extraordinary circumstances.

A Correspondence Group, reporting to III 11 in 2025, was established to continue working on these matters.

Lessons learned and safety issues identified from the analysis of marine safety investigation reports

III 10 considered the work done on preventing collisions with fishing vessels. It was noted that 50% of the states which provided input to the work require AIS for fishing vessels, and over 70% require VHF. However, less than 20% of the fishing vessels involved in collisions were carrying a working AIS or VHF at the time of the collision. Therefore, it was agreed to issue a draft MSC.1 circular to recommend national Administrations to expand requirements for carriage of AIS and VHF for the domestic fishing fleet to prevent collisions. This draft circular will be submitted to MSC 109 in December 2024 for approval.

III 10 reviewed and approved draft text containing 34 cases of lessons learned from marine casualties. This text will be published on the IMO’s website.

III 10 considered five recent accidents related to fumigation on board and recommended that three MSC.1 circulars addressing this issue should be consolidated into one MSC.1 circular to facilitate effective implementation of the recommendation on use of pesticides.

Measures to harmonize Port State Control (PSC) activities and procedures

III 10 reviewed and agreed on amendments to the “2023 Procedures for Port State Control (Resolution A.1185(33))”.

Detainable deficiencies as specified in Appendices 8 (ISM Code), 9 (LRIT), 11 (certification of seafarers, manning and hours of rest) and 18 (MARPOL Annex VI) have been moved to Appendix 2 to combine detainable deficiencies under the different conventions in one place.

There are differences between STCW (International Convention on Standards of Training, Certification and Watchkeeping for Seafarers) and MLC (Maritime Labour Convention) regarding hours of rest, including different requirements for when a detention can be raised. However, as most PSC MoUs have established PSC deficiency codes on hours of work and rest, it was concluded that at the moment no update of the procedure is needed.

The review of the interim “Guidance on Control and Compliance Measures to Enhance Maritime Security (Resolution MSC.159(78))” was completed. It was decided on a way forward to include the circular into the procedures, expected to be completed at III 11 in 2025.

Outstanding work on the procedures will be continued in a Correspondence Group and the next version will be adopted by the Assembly 34 in December 2025.

Updated survey guidelines under the Harmonized System of Survey and Certification (HSSC)

III 10 continued to work on updates to the Survey Guidelines under the Harmonized System of Survey and Certification (HSSC). A Correspondence Group will continue work on amendments to the survey guidelines related to survey items relevant to the International Code of Safety for Ships Carrying Industrial Personnel (IP Code), as well as other updates deriving from amendments to relevant mandatory instruments entering into force on or before 31 December 2025.

The revised guidelines are expected to be adopted at Assembly 34 in December 2025 enter into force on 1 January 2026.

Other topics

Guidance on implementation of Cape Town Agreement

The Cape Town Agreement (CTA) sets minimum requirements on the design, construction, equipment, surveys and certification of fishing vessels of 24 metres in length and over, or equivalent in gross tonnes. The agreement has now been ratified by 22 States with a combined fleet of about 2,600 fishing vessels. The number of States is sufficient, but a combined fleet of 3,600 fishing vessels is needed. The intention of the guidance is to support implementation of the CTA. III 10 completed the interim guidance, and it will be considered by MSC 109 in December 2024 for adoption as an MSC resolution.

For existing fishing vessels, III 10 agreed that the implementation guidance should only address the technical requirements of the CTA. The applicability of Chapter I of the CTA will be addressed by MSC 109. Furthermore, it was agreed that member states should establish measures to ensure that the compliance of existing fishing vessels with relevant parts of the CTA is documented.

In addition, III 10 also agreed that references to the areas not under the purview of the IMO, including IUU (illegal, unreported and unregulated) fishing and PSMA (Port State Measures Agreement) should be removed from the implementation guidance.

Consideration and analysis of reports on alleged inadequacy of port reception facilities (PRF)

Administrations are required to report alleged inadequacies of PRF to the IMO’s Global Integrated Shipping Information System (GISIS), and the port authority is expected to respond with their comments. Actions have been taken, and improvement noted in the form of fewer reports on deficiencies, as well as in the improved response rate from port states.

Recommendations

DNV recommends that customers note the lessons learned from accident investigation reports, and also on the work on remote surveys, audits and verifications.

As III is a Sub-Committee, all decisions concerning rules, regulations and dates are subject to further consideration and approval by the Maritime Safety Committee (MSC), Marine Environment Protection Committee (MEPC) or by the Assembly.

The Port State Control (PSC) Concentrated Inspection Campaign (CIC) will run from 1 September 2024 to 30 November 2024, focusing on 'Crew Wages and Seafarer Employment Agreement under MLC.' To help you prepare, we recommend that you join our upcoming global webinar on 20 August, which will focus on the questionnaire published by the Paris and Tokyo MoUs at the beginning of August.

Learn more about DNV’s Port State Control services.

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