A brief look at the agenda of the IMO III 10 Sub-Committee

Published: 18 July 2024

The IMO Sub-committee on Implementation of IMO Instruments (III) 10th session will be held from 22 to 26 July. BIMCO will be there to monitor developments and intervene on behalf of its Members. The agenda of the meeting includes several important items, including inadequacy of port reception facilities, analysis of marine casualties and incidents investigation reports and guidance on remote surveys. The article covers some of the important and relevant items for BIMCO and its Members.

The Sub-committee on the implementation of IMO instruments (III) addresses the effective and consistent global implementation and enforcement of IMO instruments concerning maritime safety, security and environmental protection.

The agenda for III 10, taking place from 22 to 26 July 2024, covers a variety of topics; below, we have highlighted some key and notable items of interest to BIMCO and its Members:

Port Reception Facilities (PRFs)

A major topic of discussion will be PRFs. Data provided to the Sub-committee provides an indication of improvement concerning availability of PRFs, with a decrease in the number of reported cases and an increase in the response rate by port states.

Nevertheless, an issue persists on availability particularly where discharge of garbage ashore is concerned, creating issues for ships, which often have limited garbage storage facilities. The accumulation of excessive garbage onboard leads seafarers to store them in places not designated for such purpose, posing additional risks to the seafarers and the environment, and creating the risk of deficiencies, fines or detentions by port state control authorities.

Moreover, we have to consider the possibility that the reported information does not fully reflect reality, since not all cases of inadequate port reception facilities are reported to the flag states. It is common knowledge that the awareness of reporting obligations is limited in many ports.

Taking the above into consideration, BIMCO will fully support all proposed actions in order for port states’ responses to be assessed and the reporting on behalf of the ships, companies and ports to be enhanced.

Accident investigations and lessons learned

Regularly, accident reports are assessed during III sessions for the purpose of knowledge sharing and to enable integration safety improvements. The most notable outcome of the analysis submitted by InterManager to III 10 is that a significant under-reporting of accidents still exists. BIMCO strongly advocates for timely and consistent reporting and thorough investigations of all accidents to improve safety measures and prevent recurrence.

On the other hand, we expect an interesting discussion on the concerns raised by Panama regarding the measures taken onboard to ensure that the different operations are performed safely. Panama’s submission attempts to address the matter holistically, relating incidents and accidents to the managers, operators and recognized organizations of the vessels, and identifying the correct maintenance plan, crew familiarisation and training, and the quality of internal and external audits as areas for improvement.

Finally, China has submitted a document discussing the lack of mandatory requirements regarding fumigation onboard the ships and mitigation of associated risks. BIMCO shares the concern that insufficient attention is paid to fumigation onboard ships and will follow up developments.

Updated survey guidelines under HSSC / Guidance on remote surveys

Work to update the HSSC survey guidelines and guidance for remote surveys continues, with most significant the development of guidance on remote surveys, ISM Code audits, and ISPS Code verifications, including eligibility criteria, the use of remote technology and the agreement of flag and port States on the acceptance of remote survey pertaining to PSC deficiencies. BIMCO will closely follow up developments.

Other Considerations

China has raised the issue that currently shipping companies holding a Document of Compliance for "other cargo ship" could manage several different types of ships, while the technical, operational and management requirements might be significantly different. China proposes revising the forms of the DoC in the appendix to the ISM Code, as well as requiring for additional verification when new ship types are added to an existing DoC under "other cargo ship".

BIMCO supports in principle the need to explicitly specify the ship types under the category “other cargo ship”, however proposes to consider the amendment of SOLAS Chapter IX and relevant IMO instruments to specify and distinguish the ship types currently categorized as "other cargo ship", while believes that ISM Code sufficiently regulate any addition of new ship types and, thus, disagrees with the need for additional verification.

A report on the outcome of the IMO III Sub-committee will be published shortly after the meeting conclusion.

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