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Key outcomes of the IMO III 10 Sub-Committee
Published: 31 July 2024
The 10th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 10) was held from 22 to 26 July. BIMCO was there to follow the developments.
We list key relevant points from the meeting here.
Alleged inadequacies of Port Reception Facilities (PRFs)
Investigations into the claims of alleged shortcomings of PRFs revealed that repeated issues in waste management and disposal arise from miscommunication between the ship and the receiving port, along with ships' late filing of disposal requests. Moreover, BIMCO expressed the view that not all cases when inadequate or non-existent PRFs were encountered were reported to the flag States.
Therefore, in order to ensure compliance with the MARPOL discharge requirements (oily wastes, garbage), especially within Special Areas, but also to relieve our crews of the inconvenience and associated risks of the excessive garbage onboard, it is crucial ship operators and ships:
- To provide precise information in advance of arrival in the port
- To accurately report inadequacies to ships’ flag states to address existing problems.
Accident investigations, lessons learned and safety issues identified
The analysis of the investigation reports resulted in the identification of two common safety issues:
- Lack of safety management and culture in many areas
- Lack of risk assessments, safety reviews or supervision.
To ensure enhanced focus on these safety issues, including the outcome of the investigation reports, the Maritime Safety Committee, the parent organ of the III, is considering an initiative to start a comprehensive review of the International Safety Management (ISM) Code and related guidelines.
Moreover, at III 10 it was revealed that:
- Fall accidents constitute an area for improvement, taking into consideration that modern ship deck and hold layouts are more complex, involving more working at height hazards.
- Most enclosed space entry accidents occurred while undertaking a planned activity, as a result of non-compliance with established enclosed space entry procedures rather than the procedures having been inadequate, with a high involvement of senior officers. Towards this direction, a submission is planned to address inconsistencies in the STCW trainings for entering enclosed spaces.
Additionally, a notable development concerning the safety of navigation and the avoidance of collisions with fishing vessels was that III 10 approved a recommendation to national Administrations to establish or expand regulations for the carriage and use of AIS and VHF for domestic fishing fleet.
The main conclusion of the discussions was that a comprehensive and timely reporting as well as thorough analysis of the investigation reports of all accidents is imperative in order to capture and share lessons learned and avoid repetition of similar occurrence. The approved Lessons Learned from the Marine Casualties reported by Member States will be released on the IMO website in a few weeks.
Guidelines and procedures for Port State Control (PSC)
III 10 continued discussions on proposed draft amendments to the “Procedures for Port State Control 2023” (Resolution A.1185(33)). The agreed draft amendments include, among others, developing PSC Guidelines on control and compliance measures to enhance maritime security, as well as having a single source for detainable deficiencies to avoid duplication and ensure consistency.
Remote surveys, ISM audits and ISPS verifications
III 10 made progress on the development of the draft “Guidance on assessments and applications of remote surveys, ISM Code audits and ISPS Code verifications”, and the associated MSC-MEPC circular.
III 10 agreed that:
- Initial and renewal surveys should not be carried out remotely, while portions of other periodical surveys (not two consecutive) may be eligible to be performed remotely.
- ISM shipboard audits should not be fully replaced by remote audit, but completed with an onboard attendance for a general examination of the ship condition and the observation of safe working practices.
- Document of Compliance audits will always need to be completed with the attendance of the auditor, except for annual audits and interim audits for the addition of a new ship type to an existing DoC, where consideration may be given to the use of remote auditing methods.
- Taking into account the highly sensitive nature of the information addressed in ISPS verifications, it was also agreed that the use of remote ISPS verification in lieu of in-person attendance should be limited to extraordinary circumstances.
Technical requirements will be further developed in the draft guidance for remote methods to achieve a level equivalent to in-person surveys.
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