BIMCO attended the 4th Sub-Committee meeting on Implementation of IMO instruments (III) held from 25 to 29 September 2017 in London. This week’s agenda included the finalization of revised and updated Procedures for Port State Control (PSC)

Analysis of marine safety investigation reports

The Sub-Committee conceded the report of the Correspondence Group on Casualty Analysis and acknowledged the 17 identified lessons learned on Marine Casualties.

Inadequacy of port reception facilities

The availability of adequate port reception facilities are necessary to ensure compliance with the discharge requirements of MARPOL Annex V. MARPOL Annex V specifies that solid cargo residues and/or wash water that is hazardous to the marine environment cannot be disposed into the sea. Sub-Committee III 4 considered reports on the availability and adequacy of port reception facilities for cargo residues classified harmful to the marine environment (HME) and cargo hold washings containing such residues. An industry paper on the issue will be further debated at other relevant Committees and Sub-Committees. Meanwhile, owners are recommended to use the Procedure for Reporting Alleged Inadequacies of Reception Facilities, a copy of which is available here: https://gisis.imo.org/Public/PRF/InadequateFacilities.aspx

Harmonized System of Survey and Certification (HSSC)

A drafting group has been working all week on updating survey guidelines under the HSSC to incorporate aspects of the 2004 Ballast Water Management Convention, which entered into force 8 September 2017.

Also, an initial review was conducted of the model agreement for authorization of recognised organisations, which act on behalf of the Administration. The review of the Survey Guidelines under the HSSC consists of a list of obligations and requirements that have been adopted during the intersessional period. The Governments of all States; flag, port and coastal, are recommended to use the list when implementing IMO instruments on a national level. These guidelines are not mandatory under IMO, but the guidelines are mandatory for all European Union Recognised Organisations(ROs) under EU Regulation. The report of the Correspondence Group on the Review of the Survey Guidelines under HSSC and the Non-exhaustive list of obligations included the following item:

• Amendments to the Survey Guidelines under the Harmonized System of Survey and Certification, 2015, for Ships Operating in Polar Waters to be incorporated into the HSSC Survey Guidelines
• Amendments to the next edition of the HSSC, which though depends on the adoption of resolution MEPC.285(70) “Amendments to the Revised Guidelines and specifications for pollution prevention equipment for machinery space bilges of ships”
• Further the exemption of unmanned non-self-propelled barges from the survey and certification requirements under MARPOL
• Consistency of in-water survey. 

Measures to Harmonize PSC activities and procedures worldwide

The Sub-Committee received the different PSC regimes’ annual reports including their specific reports on last year’s Concentrated Inspection Campaign on crew familiarization for enclosed space entry. The common trend in the different regimes’ reports is their focus on ships and owners, who have been black listed.

The meeting also dealt with an INTERTANKO submission on the timeline for the Electronic Chart Display and Information System (ECDIS) update, which was extended from 1 September 2016 to 1 September 2017.  As some manufactures have been unable to provide the necessary updates within this timeframe, some ECDIS units have not been updated in time to comply with the new standard. After some discussion, the Sub-Committee agreed that ships using the previous version are not unsafe and issued a circular on actions to be taken by Port State Control Officers in order to take a pragmatic and practical approach should the equipment not be updated.

Finally, the III Sub-Committee approved their own work programme for the next two years and the different Sub-Committees.

The next meeting of the III Sub-Committee will take place at IMO from 24 to 28 September 2018.