(www.MaritimeCyprus.com) The China Maritime Safety Administration (MSA) Guidelines on Shipping Companies’ Fulfilment of Primary Responsibility for Work Safety (Version 1.0), issued in November 2025 and circulated to Shipmanagers and Owners, represent a comprehensive regulatory framework aimed at elevating safety governance across shipping companies operating in Chinese waters.
At their core, the Guidelines formalize the concept of “primary responsibility for work safety”, placing unequivocal accountability on shipping companies’ senior management. The legal representative and controlling persons are explicitly designated as ultimately responsible for safety performance, requiring demonstrable leadership, active oversight, and allocation of adequate resources.
A System-Based Approach to Safety Management
A central pillar of the Guidelines is the establishment of a comprehensive safety responsibility system covering all personnel, from shore-based executives to onboard crew. Companies are required to define roles, responsibilities, and accountability mechanisms in writing, supported by performance evaluations linked to remuneration and promotion.
This is reinforced through mandatory Safety Management System (SMS) enhancements, including structured procedures for risk assessment, incident reporting, training, and emergency preparedness. Importantly, companies must allocate dedicated safety budgets—typically 1% of annual revenue (or 1.5% for higher-risk sectors)—to ensure sustained investment in safety measures.
Dual Prevention Mechanism: Risk and Hazard Control
A defining feature of the MSA framework is the “dual prevention mechanism”, combining:
- Risk classification and control
- Hazard identification and rectification
Shipping companies must systematically identify operational risks (e.g. navigation, cargo, environment), assess their severity, and implement targeted mitigation measures. Parallel to this, a structured hazard reporting and rectification process ensures continuous safety improvement, supported by audits, inspections, and digital tracking systems.
Notably, high-risk operations—such as enclosed space entry, hot work, or dangerous cargo handling—require a “dual verification” process, meaning both shipboard and shore-based approval before execution.
Focus on High-Risk Scenarios
The Guidelines place strong emphasis on mitigating major maritime risks, particularly:
- Collisions with fishing vessels in congested Chinese waters
- Navigation under adverse weather (e.g. typhoons, poor visibility)
- Ship-bridge collisions
- Machinery and electrical failures
- Operations involving dangerous goods
Enhanced watchkeeping, pre-voyage risk assessments, and minimum CPA criteria are explicitly required to reduce collision risks, especially in high-density fishing areas.
Strengthened Shore-Based Oversight
A notable regulatory shift is the expansion of shore-based control and monitoring obligations. Companies must maintain 24/7 duty systems, conduct remote monitoring of vessels, and actively support onboard decision-making. Night-time bridge watch checks and real-time intervention during critical operations or adverse weather are specifically mandated.
Human Element and Safety Culture
The Guidelines also address the human factor extensively. They require:
- Structured training programmes (with defined minimum hours)
- Competency assessments before assignment
- Monitoring of crew fitness, fatigue, and behaviour
- Prohibition of unsafe practices (e.g. mobile phone use on watch)
Beyond compliance, companies are encouraged to foster a proactive safety culture, shifting from reactive adherence to active risk ownership across all organizational levels.
Emergency Preparedness and Continuous Improvement
Shipping companies must develop robust emergency response frameworks, conduct regular drills (including ship-shore exercises), and ensure timely reporting of incidents and near misses. Continuous learning from accidents is embedded as a regulatory expectation.
The China MSA Guidelines represent a significant evolution toward integrated, risk-based, and accountability-driven safety management. For Shipmanagers and Owners trading in China, compliance will require not only procedural updates but also a cultural shift toward enhanced transparency, proactive risk management, and stronger ship–shore integration.
Ultimately, these Guidelines align with global regulatory trends by reinforcing that safety is not merely an operational function—but a strategic responsibility led from the top and executed across every level of the organization.
The China MSA "Guidelines on Shipping Companies' Fulfillment of Primary Responsibility for Work Safety (Version 1.0)" can be downloaded below:
Source: China MSA
