Report of 100th session of the IMO Maritime Safety Committee

By Hendrike Kühl, IUMI Policy Director

The Maritime Safety Committee (MSC) held its 100th session from 3-7 December 2018. Throughout the week progress was made on the regulatory scoping exercise on maritime autonomous surface ships (MASS), approval of revised guidelines on fatigue, polar shipping, and safety issues relating to fuel quality and low-sulphur fuel.

Regulatory Scoping Exercise (RSE) for the use of MASS

Much debate on this agenda item focussed on the four degrees of autonomy:

Degree 1: Ship with automated processes and decision support: Seafarers are on board to operate and control shipboard systems and functions. Some operations may be automated and at times be unsupervised but with seafarers on board ready to take control.

Degree 2: Remotely controlled ship with seafarers on board: The ship is controlled and operated from another location. Seafarers are available on board to take control and to operate the shipboard systems and functions.

Degree 3: Remotely controlled ship without seafarers on board: The ship is controlled and operated from another location. There are no seafarers on board.

Degree 4: Fully autonomous ship: The operating system of the ship is able to make decisions and determine actions by itself.

Ultimately the committee agreed to maintain the four degrees as they are and to prioritise levels 2 and 3 during the scoping exercise.

With regard to the instruments considered during the RSE and the level of detail it was agreed that the analysis of rules and regulations should be high level rather than detailed, and that the review of mandatory instruments should be prioritised.

The plenary also debated the methodology, i.e. a two-step approach (first step: identification of provisions which would/wouldn’t be applicable to MASS; second step: analyse the best way of addressing MASS). It was agreed that this two-step approach should be upheld.

MSC 100 further agreed on the development of interim guidelines for MASS trials. The committee and the MASS working group concluded that these guidelines should be generic rather than too technical. They should be conducted with safe manning still on board and (naturally) comply with all mandatory instruments. Information sharing with the IMO secretariat is important to disseminate relevant information to all interested stakeholders/Member States. 

The IMO secretariat will provide a web platform as part of the Global Integrated Shipping Information System (GISIS) on which information on the instruments and the analysis will be shared. This will be in place by end of March 2019.

The Committee agreed to establish am Intersessional Working Group (ISWG). Interested Members and NGOs can participate in the ISWG. The ISWG will meet in September 2019.

Safety measures for non-SOLAS ships operating in polar waters

Divergent views were expressed in plenary with regard to mandatory measures proposed in the two papers on this topic through a SOLAS amendment. This divergence continued in the working group. As an interim measure the working group proposed to issue a resolution to urge Member States to apply relevant Polar Code provisions. The committee endorsed the revised roadmap proposed by the working group which outlines the actions of Ship Design and Construction (SDC) 6 (recommendatory safety measures for fishing vessels of 24m and over and pleasure yachts above 300 GT not engaged in trade); MSC 101 (consider a resolution); Navigation, Communications, Search and Rescue (NCSR) 7 (assess chapters 9 and 11 of Polar Code against draft amendments to SOLAS ch. 14).

During the debate IUMI supported two papers submitted by Canada and New Zealand which called for additional safety measures for non SOLAS vessels operating in the Polar regions. In our statement we noted that IUMI’s preferred solution for the Polar Code requirements would be to make them applicable to non-SOLAS vessels too. Guidelines are a helpful starting point but from the insurers’ perspective they are only the second-best alternative.

2020 sulphur limit and fuel safety concerns

The discussion on this agenda item centred around the effective implementation of existing provisions for fuel quality and safety in IMO conventions. A paper in this regard was submitted by Liberia and several industry groups. IUMI supported the paper in principle, and in addition emphasised that the current system of leaving the testing or damage to the end user is outdated. This approach has become unacceptable and must be changed. An important step to do so is to require the refineries to test the fuel quality prior to delivery. In parallel, IUMI called for IMO to urge the International Organization for Standardization (ISO) to start working on amendments of the ISO8217 standard to deal with biofuels and the 2020 sulphur cap.

The outcome of the plenary debate was to produce a new output on the issue of fuel quality for MSC 101. A drafting group developed the following title and scope for this new output:

Title: “Development of further measures to enhance the safety of ships relating to the use of fuel oil”

Scope: “Based on the review of existing safety provisions for fuel oil and information concerning the safety implications associated with the use of fuel oil, develop further measures to enhance the safety of ships relating to the use of fuel oil.”

A working group is planned to be established on this issue at MSC 101.

Piracy and armed robbery against ships

The IMO secretariat provided an update on various regional developments. Nigeria provided a specific update on the situation in the Gulf of Guinea. Intertanko introduced the 5th edition of the piracy-specific Best Management Practice (BMP 5) on behalf of various industry groups and asked for this information to be distributed to the Member States.

Places of refuge

The committee agreed to include an output on the "Revision of the guidelines on places of refuge for ships in need of assistance (resolution A.949(23))”. Two sessions are scheduled to complete the item and NCSR has been assigned as the coordinating body. IUMI co-sponsored the respective paper submitted on this issue, supporting the call for a revision of the resolution because even though guidelines are already in place, experience has shown that ships in need of assistance may still face problems to get permission to enter a place of refuge in a consistent, harmonised and timely manner.

Trial for an independent assessment of the IACS Quality System Certification

The proposal an initial trial of an International Quality Assessment Review Body (IQARB) for the International Association of Classification Societies (IACS) Quality System Certification Scheme (QSCS) was accepted. The IMO secretariat will participate in the exercise and meetings will be convened at IMO.

Revised guidelines on fatigue approved

The MSC approved revised guidelines on fatigue which provide comprehensive information on the causes and consequences of fatigue and the risks it poses to the safety and health of seafarers, operational safety, security and protection of the marine environment. The aim is to assist all stakeholders to contribute to the mitigation and management of fatigue.

The 101st session of the MSC will take place from 5-14 June 2019. Don Harrell, Chairman of IUMI’s Facts & Figures Committee and Astrid Seltmann, Vice Chair of IUMI’s Facts & Figures Committee will give a presentation on casualty trends and global marine insurance statistics.