BIMCO has submitted four papers to the Maritime Safety Committee. The papers discuss how autonomous ships should be tried before they are allowed to operate, and that cyber risk management should be part of the ship’s Safety Management System.
The following papers have been submitted to the 101st session of the Maritime Safety Committee (MSC) by BIMCO and others. The meeting will be held from 5 - 14 June 2019 in London.
The MSC considers any matter concerned with aids to navigation, construction and equipment of ships, 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).
Cyber risk management
The IMO has decided that administrations should ensure that cyber risks are appropriately addressed in existing Safety Management Systems (SMS) no later than the first annual verification of the company's Document of Compliance after 1 January 2021. The reason was that cyber incidents and attacks were considered additional risks to the safety of the ship, its crew and the marine environment.
At a conference in January 2019, the Director of the European Maritime Safety Agency, Ms Maja Markovčić Kostelac mentioned that shipping is vulnerable to cyber attacks and underlined the need to implement cyber risk management into the Ship Security Plan (SSP). The same understanding has been expressed by other EMSA officials. This is a problem because an ambiguity now exists in some countries as to whether the SSP or the SMS is the place to address cyber risks.
It should be noted that any changes to SSPs require flag state approval and given the rapid developments taking place with regards to cyber security, frequent updates are likely to be necessary. If the SSP becomes the chosen repository for cyber security procedures, the additional administrative burden and cost of flag state’s approval of any changes will land on the shipowner. The joint MSC submission advocates the SMS option to cover all elements relating to cyber security except for physical access to restricted areas such as cargo control rooms.
Document MSC 101/4/4.
BIMCO, together with industry partners ICS, IUMI, OCIMF, INTERTANKO, CLIA, INTERCARGO, InterManager and WSC published the 3rd version of the Industry Guidelines on cyber security onboard ships (the Industry Guidelines) at the end of 2018. The Guidelines have been improved and the submission informs IMO and its members states of the improved content.
Document MSC 101/4/1.
Trials for autonomous ships
BIMCO has co-sponsored a submission to MSC 101 in June 2019 on Interim guidelines on Marine Automated Surface Ships (MASS) trials together with Finland, Norway, Japan, Republic of Korea, Singapore and United Arab Emirates.
The guidelines take a precautionary approach to ensuring the safe, secure and environmentally sound operation of MASS. BIMCO entered this work to ensure that MASS are fully tested before they are allowed to operate on the open seas along with conventional ships.
In December 2018, the IMO decided to draft a set of interim guidelines with the aim of establishing a harmonised international framework to test MASS operations. The original text, which was based on a paper that was submitted by Norway and BIMCO, has been significantly improved.
Document MSC 101/5/5 and MSC 101/Inf.17.