For the first time, IMO will discuss the maritime autonomous ships. The use of autonomous ships – or so-called unmanned ships - will create the need for a regulatory framework for such ships and their interaction and co-existence with manned ships.
BIMCO’s Maritime Technology and Regulation Department will attend the 99th session of the IMO’s Maritime Safety Committee (MSC 99), which will be held from 16 - 25 May 2018 in London.
The MSC is the technical committee of IMO. It considers any matter concerned with aids to navigation, construction and equipment of vessels, manning from a safety standpoint, rules for the prevention of collisions, handling of dangerous cargoes, maritime security and safety procedures and requirements, marine casualty investigations, salvage and rescue and any other matters directly affecting maritime safety. The MSC approves and adopts amendments to conventions such as Safety of Life at Sea (SOLAS).
The agenda for MSC 99 is comprehensive and the following central items should be highlighted:
Amendments to mandatory instruments
MSC 99 will consider several of amendments to the following IMO Conventions:
- Draft amendments to Part A of the International Code on Intact Stability, 2008 (2008 IS Code) under the 1974 SOLAS Convention – Part A – Mandatory Criteria. These proposed amendments to the 2008 IS Code are intended to ensure that references to the non-mandatory part of the Code (Part B) do not, inadvertently, make them mandatory. The draft amendments include making some footnotes part of the main text where the content was intended to be mandatory.
- Draft amendments to the IBC, HCH, GC, IGC and EGC Codes – these draft amendments to the Certificate of Fitness (CoF) include a paragraph in the CoF clarifying the requirements for an approved loading and stability manual/booklet to be supplied to the ship. The requirements will enter into force on 1 January 2020.
- Uniform wording in MSC.1/Circ.1586 List of certificates and documents required to be carried on board ship, 2017, and related instruments – There is some inconsistency in the wording used in MSC.1/Circ.1586 when making reference to the stability information which a ship has to have available. In most locations it is called the “stability information” but in a number of phrases “intact stability book” is used. Consistency in terminology is desirable and appropriate changes should be decided upon.
- Draft aments to the 2010 FTP Code – To clarify that the fire protection materials and required approval test methods contained therein also apply to passenger ships carrying not more than 36 passengers. These amendments are likely to enter into force on 1 January 2020.
- 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. These amendments will allow Inmarsat C SaferyNET Maritime Safety Information messages to be presented on an integrated navigation display system and removes the term “NAVTEX” from the performance standards and replaces it with the term “Maritime Safety Information messages”.
Enhanced Survey Programme (ESP) Code
The 2011 ESP Code contains the survey requirements for bulk carriers and oil tankers. The Code has recently been reviewed and are now ready for MSC to issue a resolution on the amendments. The update of the code has taken a long time, and it is expected that the draft amendments to the ESP Code will be considered for approval at MSC 99, with a subsequent adoption at MSC 100.
The entry in to force are expected to be 1 July 2020. Note, that the MSC resolution repeats much of the IACS Unified Requirements (URs) as set out in the Z10 series.
IMO will discuss the maritime autonomous ships. The use of autonomous ships – or so-called Maritime Autonomous Surface Ships (MASS) - will create the need for a new regulatory framework that takes into consideration interaction and co-existence with existing ships. It will be a regulatory scoping exercise in order to identify affected IMO regulations.
MSC 99 are asked to embark on a regulatory scoping exercise in order to identify affected IMO regulations.
BIMCO supports the initiative by the IMO to assess the need for changes to international conventions and national laws for autonomous ships to operate worldwide. There is an urgent need to come up with a definition of an autonomous ship is and this will be taken forward to MSC by emphasising that there is a need for developing categories of ships with different levels of automation. They should cover from partially automated systems that assist the seafarers to fully autonomous systems, which can undertake all aspects of a ships' operation without human intervention.
Requirements for practical seating arrangements in survival craft
MSC 99 will also have to discuss the personal mobility and practical seating capacity in survival crafts. This is the first time the unexpected application of minimum seating space is submitted to IMO. The way they are designed today leaves seafarers and passenger with very little or no space, so they cannot move around the craft eg for sanitary or medical reasons.
There is thus an urgent need to develop of a minimum standard for personal mobility and seating space in survival crafts by developing new regulation addressing additional space for movement after the occupants are seated.
BIMCO has together with other industry organizations and flag States co-sponsored three submissions:
- MSC 99/20/7 - Proposal for a new agenda item to amend the definition of 'Group A' in the IMSBC Code. (Submitted by Australia, Brazil, China, the Philippines, BIMCO and INTERCARGO)
The document proposes 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".
Based on a newly discovered risk related to moisture content which has adversely affects the stability of a ship the paper has been submitted to protect the safety crews and ships.
- MSC 99/20/8 - Proposal for a new output to amend paragraph 18.104.22.168 of the LSA Code. (Submitted by the Marshall Islands, Panama, ICS, BIMCO, INTERCARGO, IPTA, IMCA, IBIA and ITF).
The document proposes the need to amend the International Life-Saving Appliance (LSA) Code in order to ensure adequate safety standards for boats with single fall and hook systems and propose a new output for inclusion in the agenda of the Sub-Committee on Ship Systems and Equipment (SSE).
The paper has been submitted to ensure the safety of crew operating, maintaining and testing both lifeboats and rescue boats. Single fall systems should have the same level of safety provisions applicable to twin fall systems, including protection against accidental release.
- MSC 99/INF.18 - Standardized reporting of global piracy and armed robbery incidents. (Submitted by the Marshall Islands, BIMCO, OCIMF and INTERTANKO)
The document highlights 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. MSC should develop harmonized global maritime security incident type definitions and simplify the incident reporting framework. This would add clarity to the global security situation and better inform Member States.
A brief report on the outcome of the meeting will be published shortly after the meeting.