Maritime Compliance: Update on the IMO MSC 108 decisions affecting vessels

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(www.MaritimeCyprus.com) The 108th session of the IMO’s Maritime Safety Committee (MSC 108) was held from 15 to 24 May 2024. Amendments enhancing the fire safety of Ro-Ro passenger ships were adopted, as well as amendments extending emergency towing equipment to new ships other than tankers, and amendments improving the safety measures for ships using natural gas as fuel. A new code for autonomous ships was progressed, and the safety perspective of new fuels and technologies to support the reduction of GHG emissions from ships was considered.

Meeting highlights

  • Adopted SOLAS amendments to extend the requirements for emergency towing equipment to all new ships over 20,000 GT.
  • Adopted amendments to SOLAS and the FSS Code to enhance the fire safety of Ro-Ro passenger ships.
  • Adopted IGF Code amendments for natural gas as fuel based on experience with application of the code.
  • Approved interim guidelines for the use of LPG cargo as fuel.
  • Approved draft amendments to the IGC Code to enable the use of ammonia as fuel on ammonia carriers.
  • Approved goals and functional requirements for electrical and machinery installations in SOLAS Chapter II-1.
  • Progressed the new non-mandatory International Code for of Safety for Maritime Autonomous Surface Ships (MASS Code).
  • Considered the safety of alternative fuels and new technologies to support the reduction of GHG emissions from ships.

Amendments to mandatory instruments

Fire safety of ro-ro passenger ships
The number of fire incidents on vehicle decks of Ro-Ro passenger ships has grown over the past decade. The physical extent of Ro-Ro ships’ vehicle decks could potentially allow a fire to spread over the full length of a ship. Hence, for Ro-Ro ships carrying passengers, extinguishing and containing a fire are particularly critical.

MSC 108 adopted amendments to SOLAS Chapter II-2 to reduce the risk and consequences of fire in Ro-Ro and special category spaces on new and existing Ro-Ro passenger ships by considering inter alia:

    • The arrangement of Ro-Ro spaces for new ships.
    • The arrangement of weather decks for new ships.
    • Water monitors on weather decks of existing ships.

Related amendments to the FSS Code were adopted to include:

    • New requirements for fixed water-based fire-extinguishing systems on weather decks intended for the carriage of vehicles (FSS Code, Chapter 7).
    • Specifications for linear heat detection systems, and combined smoke and heat detection systems (FSS Code, Chapter 9).

The amendments will enter in to force on 1 January 2026.

Fire protection of control stations in cargo ships
MSC 108 adopted amendments to SOLAS Regulation II-2/7.5.5 to extend the fire detection requirements for cargo ships to include control stations and cargo control rooms.

Consequential amendments to the “Unified Interpretations of SOLAS Chapter II-2 and the FSS and FTP Codes” (MSC.1/ Circ.1456) were approved accordingly. The Unified Interpretations will be issued as a new MSC Circular, superseding MSC.1/Circ.1456 and MSC.1/Circ.1492.

The amendments will enter into force on 1 January 2026.

Emergency towing equipment
MSC 108 adopted amendments to SOLAS Regulation II-1/3-4 to extend SOLAS requirements for emergency towing devices to all new ships over 20,000 gross tonnage in order to facilitate emergency assistance and towing operations, and thereby reduce the risk of ship wreckage and pollution.

Currently, tankers of 20,000 DWT and above are required to have an emergency towing device. Other cargo ships and passenger ships must have a towing procedure, but are not required to have specific suitable equipment. Increased ship sizes, in general, complicates emergency towing to a safe place without the suitable equipment.

An associated new set of guidelines for emergency towing arrangements on new ships other than tankers is under development by the SDC Sub-Committee. MSC 108 also agreed that consequential amendments to the “Guidelines for owners/operators on preparing emergency towing procedures” (MSC.1/Circ.1255) should be considered.

The amendments will enter into force on 1 January 2028.

Safety of ships using natural gas as fuel (IGF Code)
MSC 108 adopted amendments to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), based on experience with the code since its entry into force in 2017. The amendments relate inter alia to:

  • Clarification of the application provisions
  • Amendments to the provisions for bunkering manifolds and bunkering operations
  • Clarification of the requirements related to the capacity of the fuel tank’s pressure relief valves
  • Clarification of the requirements for control of tank pressure and temperature
  • Clarification of the requirements for single fuel installations redundancy and propulsion capability
  • Clarification of the requirements for the venting of segments upstream of gas consumers
  • Clarification of the requirements to design pressure of the outer pipe or duct of fuel systems
  • New requirements for portable dry powder extinguishers in the fuel preparation room
  • Clarification of the hazardous area zone requirements

The amendments will enter into force on 1 January 2026.

Updated requirements to ensure the safe connection of a bunker system to a ship bunkering manifold (paragraphs 4.2.2 and 8.4.1 to 8.4.3 in Part A-1 of the IGF Code) are subject to voluntary early implementation by flag states. An MSC Circular will be issued in this respect.

Reporting on loss of containers at sea
MSC 108 adopted amendments to SOLAS Chapter V to mandate the reporting of the loss of containers at sea.

The amendments will enter into force on 1 January 2026.

Code for the safe carriage of grain in bulk
MSC 108 adopted amendments to the International Code for the Safe Carriage of Grain in Bulk (Resolution MSC.23(59)). The amendments include provisions for an especially suitable compartment: partly filled in way of the hatch opening, with ends untrimmed so that the grain surface lies within the hatch coaming, but the underdeck voids have not been trimmed.

The amendments will enter into force on 1 January 2026.

Enhanced survey programme (2011 ESP Code)
Amendments to the 2011 ESP Code to align the code with the survey and certification requirements of the IACS UR Z series were adopted in 2019 (MSC 101) and entered into force on 1 January 2021.

MSC 108 adopted modifications to the 2019 amendments so that both administrations and organizations recognized by the administrations may be involved with the approval and auditing of firms engaged in thickness measurements of hull structures on oil tankers.

The amendments will enter into force on 1 January 2026.

In-water performance of SOLAS life jackets
MSC 108 adopted amendments to the LSA Code and the revised “Recommendation on the testing of life-saving appliances” (Resolution MSC.81(70)) to address in-water performance of SOLAS life jackets, i.e. to specify the criteria for recognizing a successful turn of a test subject.

Amendments to the “Revised standardized life-saving appliance evaluation and test report forms (personal lifesaving appliances)” (MSC.1/Circ.1628/Rev.1) were approved accordingly.

The amendments will enter into force on 1 January 2026.

Single fall and hook systems with on-load release capabilities
The Life-Saving Appliances (LSA) Code, paragraph 4.4.7.6.8, provides measures to prevent the accidental release of the fall and hook system during the recovery of lifeboats and rescue boats. Lifeboats and rescue boats with single fall and hook systems are currently exempted from such measures.

MSC 108 adopted amendments to paragraphs 4.4.7.6.8 and 4.4.7.6.17 of the LSA Code to clarify the requirements for lifeboats and rescue boats fitted with single fall and hook systems not being able to release with a load on the hook when not fully waterborne.

The amendments will enter into force on 1 January 2026.

Lowering speed of survival craft for cargo ships
MSC 108 adopted amendments to paragraphs 6.1.2.8 and 6.1.2.10 of the LSA Code to include a minimum lowering speed calculated as a function of height, but of not higher than 1.0 m/s, and to define a maximum lowering speed of 1.3 m/s. Administrations may accept other maximum lowering speeds.

Amendments to the “Revised recommendation on testing of life-saving appliances” (Resolution MSC.81(70)) were adopted accordingly.

The amendments will enter into force on 1 January 2026.

Ventilation of totally enclosed lifeboats
MSC 107 adopted amendments to the Life-Saving Appliances (LSA) Code to mandate ventilation of totally enclosed lifeboats. A ventilation rate of at least 5 m3/hr/person should be provided to prevent high CO2 concentrations inside the lifeboat.

MSC 108 adopted consequential amendments to the “Requirements for maintenance, thorough examination and operational testing of LSA” (Resolution MSC.402(96)) to reflect the new ventilation requirements.

The amendments will enter into force on 1 January 2026.

IMDG Code and supplements
MSC 108 adopted the 42-24 amendment of the IMDG Code.

Consequential amendments to the “Revised emergency response procedures for ships carrying dangerous goods (EMS guide)” (MSC.1/Circ.1588/Rev.2) were approved accordingly.

The amendments will enter into force on 1 January 2026, with voluntary early implementation by flag states from 1 January 2025.

STCW Code – bullying and harassment
MSC 108 adopted amendments to the STCW Code on competency to prevent and respond to bullying and harassment, including sexual assault and sexual harassment (SASH).

The amendments will enter into force on 1 January 2026.

Training, certification and watchkeeping on fishing vessels MSC 108 adopted the revised 1995 STCW-F Convention and the new STCW-F Code, containing training, certification and watchkeeping provisions for fishing vessel personnel.

The amendments will enter into force on 1 January 2026.

Coating inspector certificates
MSC 108 adopted minor corrections to the “Performance standards for protective coatings for dedicated seawater ballast tanks” (Resolution MSC.215(82)) and the “Performance standards for protective coatings for cargo oil tanks of crude oil tankers” (Resolution MSC.288(87)). The corrections reflect a name change of the association referenced in connection with coating inspector certifications.

Removal of footnote to SOLAS Regulation IV/1.2
MSC 108 adopted amendments to SOLAS Regulation IV/1.2 to remove a footnote due to termination of the referenced agreement.

Maritime autonomous surface ships (MASS)

The prospect of autonomous ships operating internationally with little or no human intervention has revealed the need for a regulatory framework for such ships, including their interaction and co-existence with conventional manned ships.

The current regulatory framework generally assumes manning and human intervention. The IMO has agreed to develop a non-mandatory, goal-based code for MASS, potentially entering into force as a mandatory code upon experience with its application.

The non-mandatory MASS Code is planned to be finalized by 2025, followed by an experience-building phase after its adoption. A mandatory code is expected to enter into force on 1 January 2032, at the earliest.

MSC 108 agreed that the code should apply to cargo ships, excluding high-speed cargo craft. The new MASS Code was progressed and, in particular, MSC 108:

  • Agreed on a structure of the draft code that aligns the parts that apply to all ships with the parts that only apply if the ship has automated or remote control of the relevant functionality.
  • Considered how flag administrations may approve a Remote Control Centre (ROC).
  • Considered measures for the compatability of a specific MASS and an ROC, based on the principles of the ISM Code.
  • Generally agreed that the master should remain on board if there are other persons on board.

The work will continue in a Correspondence Group until MSC 109 (December 2024). In addition, an intersessional Working Group meeting is planned for September 2024.

New technologies and alternative fuels

MSC 108 considered potential alternative fuels and new technologies to support the reduction of GHG emissions from ships from a safety perspective.

A list of alternative fuels and technologies was developed, including inter alia:

  • Ammonia
  • Hydrogen
  • Fuel cell power installations
  • Nuclear power
  • Solar power
  • Wind power
  • Lithium-ion batteries
  • Supercapacitor energy storage technology

Safety obstacles, barriers and gaps in the current IMO instruments that may impede the use of the various alternative fuels and new technologies were identified.

The consideration of alternative fuels and new technologies will continue at MSC 109 (December 2024).

Recommendations to address each of the identified barriers and gaps in the IMO regulatory framework will be considered in a Correspondence Group until MSC 110 (spring 2025).

Maritime cyber risk management

MSC 108 approved a draft revision of the 2017 “Guidelines on maritime cyber risk management” (MSC-FAL.1/Circ.3/Rev.2), providing high-level recommendations for marine cyber risk management. The revision addresses risk assessment aspects, cyber resilience and cyber-secured equipment and systems while maintaining a holistic approach.

Navigation, communications, search and rescue

Maritime services in the context of e-navigation
The IMO is working on developing a globally harmonized list of maritime services offered in harbours and geographical areas, displayed electronically in a standardized manner. The intention is to facilitate worldwide harmonized communication and the exchange of information between shore and ships.

MSC 108 agreed on a draft revision of the descriptions of the maritime services in MSC.1/Circ.1610.

ECDIS performance standards
MSC 106 adopted the “Performance standards for electronic chart display and information systems (ECDIS)” (Resolution MSC.530(106)) to open for the next technical generation of Electronic Navigational Charts. The revised standards will be applicable to ECDIS equipment installed on or after 1 January 2029. In a transitional period, from 1 January 2026 to 1 January 2029, ECDIS equipment may conform to either the current performance standards (Resolution MSC.232(82)) or the new Resolution MSC.530(106).

MSC 108 approved draft amendments to Resolution
MSC.530(106) on “Performance standards for electronic chart display and information systems (ECDIS)” to facilitate a standardized digital ship-to-shore and shore-to-ship exchange of a ship’s route plans.

Appropriate operational guidance for route exchange will be considered by the NCSR Sub-Committee accordingly.

Dissemination of information over multiple recognized mobile satellite services
MSC 108 recalled previous decisions of the Committee that once a mobile satellite service is recognized by the IMO, it must then be used by all information providers following its service.

It was agreed that draft SOLAS amendments should be developed to clearly state the requirements for dissemination and reception of maritime safety information (MSI) and information related to search and rescue (SAR) through all operational and recognized mobile satellite services. MSC 108 agreed that MSI should be disseminated through all operational RMSSs by 31 December 2026.

Carriage of cargoes and containers

IGF Code amendments
MSC 108 endorsed a working plan for the development of safety provisions for alternative fuels under the IGF Code, including hydrogen, ammonia, low-flashpoint oil fuels, methyl/ethyl alcohols and fuel cells. Guidelines for ships using hydrogen and ammonia as fuel are planned to be finalized by the end of 2024.

MSC 108 also approved draft amendments to the IGF Code for ships using natural gas as fuel. The draft amendments include:

  • Clarified application provisions.
  • Alignment with the IGC Code on suction wells for fuel tanks extending below the lowermost boundary of the tank.
  • Alignment with the IGC Code on discharge from pressure relief valves to discharge to tanks under certain conditions.
  • Clarified requirements to fire insulation for deck structures in relation to fuel tanks on open deck.
  • Clarified requirements for hazardous ducts through nonhazardous spaces and vice versa.
  • Updated requirements for hazardous zone radius for fuel tank vent mast outlet, increasing to 6 m for zone 1 and 4 m for zone 2.

The draft amendments are expected to enter into force on 1 January 2026, subject to adoption by MSC 109 (December 2024).

LPG cargo as fuel
MSC 108 approved interim guidelines for the use of LPG cargo as fuel.

Ammonia cargo as fuel (IGC Code)
MSC 108 approved draft amendments to paragraph 16.2.9 of the IGC Code and a draft MSC Circular on voluntary early implementation of the requirements. The intention is to enable the use of ammonia as fuel on ammonia carriers.

The draft amendments and the draft MSC Circular will be submitted to MSC 109 for adoption.

High-manganese austenitic steel
MSC 108 approved a revision of the “Guidelines on the application of high-manganese austenitic steel for cryogenic service” (MSC.1/Circ.1599/Rev.2), and a revision of the “Guidelines for the acceptance of alternative metallic materials for cryogenic service in ships carrying liquefied gases in bulk and ships using gases or other low-flashpoint fuels” (MSC.1/ Circ.1622).

These updates incorporate the use high-manganese austenitic steel for ships carrying ammonia as cargo and/or fuel in the guidelines.

Carriage of liquefied hydrogen in bulk MSC 108 adopted a resolution on revised “Interim recommendations for the carriage of liquefied hydrogen in bulk”.

Ship design and construction

Functional requirements for SOLAS Chapter II-1
SOLAS Chapter II-1, Regulation 55 allows electrical and machinery installations to deviate from prescriptive requirements, provided an equivalent level of safety is achieved and the intent of the requirements is met. To make this alternative design process more efficient, the IMO has agreed to define the intent of the prescriptive requirements in terms of functional requirements.

MSC 108 approved goals and functional requirements for electrical and machinery installations in SOLAS Chapter II-1 (Parts C, D and E). These goal-based provisions will be included in a second revision of the “Guidelines on alternative design and arrangements for SOLAS Chapters II-1 and III” (MSC.1/Circ.1212/Rev.1).

Water level detectors
MSC 108 approved a revision of MSC.1/Circ.1572/Rev.1 containing unified interpretations of the “Performance standards for water level detectors on bulk carriers and single cargo hold cargo ships other than bulk carriers” (Resolution MSC.188(79)).

The headings are amended to clarify that the interpretations of the performance standard apply to water level detectors used on all ship types as required by SOLAS Regulations II-1/25, II-1/25-1 and XII/12. The revision also improves the guidance for EX-properties to ensure appropriate protection against explosions in hazardous areas.

Industrial personal (IP) safety certificate
MSC 108 approved a Unified Interpretation of SOLAS Chapter XV and the IP Code to clarify which SOLAS safety certificate the IP safety certificate should be harmonized with in terms of validity, survey dates and endorsements.

Inspection and maintenance of permanent means of access
MCS 108 approved amendments to Sections 1.4 and 1.5 of the Annex to MSC.1/Circ.1572/Rev.1 containing Unified Interpretations to SOLAS Chapter II-1/3-6 on “Access to and within spaces in, and forward of, the cargo area of oil tankers and bulk carriers”. The interpretation inter alia suggests that the access arrangements should be inspected annually by the crew or a competent inspector.

Calibration of sound instruments
MSC 108 approved a Unified Interpretation of paragraphs 2.1 and 2.2 of the “Code on noise levels on board ships” (Resolution MSC.337(91)) to clarify the requirements for the calibration of sound instruments. Members states are invited to apply the interpretation at the next calibration due date.

Means of escape from machinery spaces
MSC 108 approved amendments to the “Unified Interpretation of SOLAS Regulations II-2/9 and II-2/13” (MSC.1/ Circ.1511). The interpretation clarifies that steering gear spaces where hydraulic oils for the steering gear equipment are stowed may be considered a “safe position” for the purpose of escaping from the machinery spaces.

Human element, training and watchkeeping

Comprehensive review of the STCW Convention and Code
MSC 108 agreed on a methodology and road map for a comprehensive review of the 1978 STCW Convention and Code. The intention of the review is to address inconsistencies and to improve the provisions based on experiences and new technologies.

 

Source: IMO

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