Report of the 8th session of the IMO’s Sub-Committee on Implementation of IMO Instruments (III 8)

By Lars Lange, Secretary General, IUMI

The Sub-Committee on Implementation of IMO Instruments (III) brings together flag, port and coastal states to consider implementation issues, including the analysis of consolidated audit summary reports from the mandatory IMO Member state Audit Scheme. The Sub-Committee has a key role in casualty analysis and issuing lessons learned from marine incidents. It analyses port state control data and keeps under review the procedures for port state control. The Committee also reviews the work of the International Quality Assessment Review Body (IQARB) which is chaired by IUMI.

The III Sub-Committee held its 8th session (III 8) remotely from 25-29 July under the chairmanship of Claudia Grant from Jamaica and her Vice-Chair, Captain Marek Rauk from Estonia.

Development of guidance on assessments and applications of remote surveys 

The Sub-Committee progressed its work on development of guidance on assessments and applications of remote surveys, the International Safety Management (ISM) Code audits and ISPS Code verifications, in particular with an agreement on a roadmap and methodology on the way forward.

Given the urgent demand for guidance on remote surveys and ISM Code audits, the Sub-Committee agreed in its roadmap that amendments to Survey Guidelines under the HSSC and amendments to the Revised Guidelines on the implementation of the ISM Code, containing remote surveys and ISM audits, should be finalised next year at III 9, with a view to adoption in 2023.

In addition to the above, it was agreed to task a correspondence group with the agreed methodology to proceed on the basis of one document containing principles and common areas and three guidance documents:

  • Guidance on assessments and applications of remote surveys (part 3-1)
  • Guidance on assessments and applications of remote ISM Code audits (part 3-2)
  • Guidance on assessments and applications of remote ISPS Code verifications (part 3-3)

Procedures for PSC on the short-term GHG reduction measures

The Sub-Committee discussed specific PSC issues related to the implementation of the short-term GHG reduction measures, set to enter into force on 1 November 2022.  

Under the short-term measure, ships are required to calculate their Energy Efficiency Existing Ship Index (EEXI) following technical means to improve their energy efficiency and to establish their annual operational carbon intensity indicator (CII) and associated CII rating. Carbon intensity links the GHG emissions to the amount of cargo carried over distance travelled.

Ships will receive a rating of their energy efficiency (A, B, C, D, E - where A is the best). Administrations, port authorities and other stakeholders as appropriate, are encouraged to provide incentives to ships rated as A or B also sending out a strong signal to the market and financial sector.

A ship rated ‘D’ for three consecutive years, or ‘E’, is required to submit a corrective action plan, to outline how the required index (C or above) would be achieved.

A Correspondence Group has been tasked with incorporating the various amendments supporting the enforcement of the short-term GHG reduction measure into the PSC procedures. The Sub-Committee, however, agreed that at this stage, there was no support for an amendment to regard as a detainable deficiency the absence of implementation by the ship as planned at the time of the inspection of the three-year implementation plan and/or the plan of corrective actions for a ship rated as D for three consecutive years, or rated as E. The Sub-Committee agreed to advise the Marine Environment Protection Committee (MEPC 79) accordingly.

International Quality Assessment Review Body (IQARB)

On 28 July 2022, delegations were invited to attend a presentation titled "Update on the further development of the International Quality Assessment Review Body (IQARB)". It was held by Lars Lange, IUMI Secretary General, who chairs IQARB.

IQARB is an advisory and a non-decision-making body established in 2019 to review the certification process of the quality management systems of IACS classification societies. It comprises qualified individuals from maritime authorities, the IMO Secretariat and industry bodies – including those from the insurance industry, shipowners and shipbuilders. These collectively represent the views and interests of the stakeholders that have a particular interest in the work of classification societies and recognised organisations (ROs). 

In its annual meetings, IQARB members review IACS society audits based on the report of IQARB's Independent Quality Assessment Analyst. During the year, a standing Steering Committee and a Technical Committee support the IQARB in ensuring steady and ongoing progress. More information about IQARB-specific tasks is available here.

A permanent Secretariat for the IQARB is currently being established, and future funding issues are being considered. Opening up IQARB to all flag States and all classification societies is under discussion to ensure suitability for all participants, not only IQARB members.

Looking forward, IQARB offers flag States the option to consider the use of IQARB Factual Statements as a component to assist in fulfilling some of their obligations under the relevant provisions of IMO mandatory instruments, such as SOLAS, 1974, regulations I/6, II-1/3-1 and XI-1/1, etc. as well as the IMO Instruments Implementation Code (III Code) and the Code for Recognised Organisations (RO Code).