IMO Maritime Safety Committee (MSC 94) Introduction

Working together
for a safer world
IMO Maritime Safety Committee
(MSC 94)
Agenda Preview
Introduction
The 94th session of the IMO Maritime Safety Committee (MSC) will be held from 17 to 21 November 2014, at the IMO
headquarters in London. This briefing summarises subjects under discussion which are relevant to the work of Lloyd's
Register and addresses documents released as of 30th October 2014.
Overview of agenda items
The following agenda items are relevant to the work of Lloyd’s Register.
Decision of other IMO Bodies (agenda item 2)
MSC 94 will review the decisions of the Legal Committee, Technical Co-operation Committee, Facilitation Committee
and Marine Environment Protection Committee.
Lloyd’s Register will closely monitor the outcome of the Facilitation Committee (FAL 39) with regard to the discussion
on electronic certificates.
Consideration of adoption of amendments to mandatory instruments (agenda item 3)
MSC 94 will adopt mandatory instruments introduced hereunder. Associated non-mandatory instruments will also be
addressed under this agenda item.
Mandatory instruments for adoption are:
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Amendments to the 1974 SOLAS Convention
- Regulation II-2/10 - Fire fighting
- Regulation VI/2 - Cargo information
- Regulation XI-1/7 - Atmosphere testing instrument for enclosed spaces
- Appendix - Forms of certificate
- New Chapter XIV - Safety measures for ships operating in polar waters
The International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers,
2011 (2011 ESP Code)
Polar Code and related guidance
- Text of the code, editorial and suggested additions
POLARIS scheme for ice vs speed interactions
- Format and contents of certificates
- Requirements for ships undertaking single voyages
- Requirement for qualified ice crew
- Assessment of operational limitations
- Stability and subdivision
- Echo sounders and navigational aids
- Other concerns
Lloyd’s Register’s view
Lloyd’s Register has the following views:
- New Chapter XIV − A careful review is required as there are a number of areas which are vague, for example:
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The proposed application appears to require compliance with the whole of the Polar Code when operating in
the Polar waters when any SOLAS certificate is issued, e.g. for ships between 300 - 500 gt only a radio
certificate is required - whether such a ship needs to comply with the Polar Code in full is not clear.
Polar Code – The polar certificates require careful review:
While the certificate is a supplement, it is created only as supplement to the “Safety Construction” certificate
Endorsement for survey is not provided
It certifies compliance with the SOLAS regulation I/7 (not the Polar Code)
Need to address the SOLAS supplementary forms (Form E, P etc.).
Measures to enhance maritime security (agenda item 4)
Cyber security will be addressed under this agenda item.
Goal-based new ship construction standards (agenda item 5)
There will be a working group. MSC 94 will consider:
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Goal based rules on naval ships as an example of application of functional based rule development
Safety Level Approach (SLA) to the IMO Rule-Making - to further work on the outcome of MSC 92
Link between works done under this agenda item and the SSE Sub-Committee
Lloyd’s Register’s view
Lloyd’s Register supports further development of the safety level approach in order to clarify the process for future
development and assessment of the goal-based IMO rules.
Passenger ship safety (agenda item 6)
MSC 94 will consider
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The outcome of III 1 on consideration of the casualty report on the Costa Concordia, the contributing factors,
issues raised/lessons learnt and observations on the human element
Existing passenger ship safety - requirements for onboard computer or shore support (SOLAS II-1/9-1/3) to ships
constructed before 1 Jan 2014
SAR Plan (MSC 94/6/2)
Watertight doors
Readers are to note that there will not be a working group on passenger ship safety during MSC 94.
Lloyd’s Register’s view
Lloyd’s Register will carefully review discussions.
Human element, training and watchkeeping (report of the first session of the Sub-Committee) (agenda item
7)
HTW 1 was held in February 2014. Lloyd’s Register’s report on the meeting can be found here. Urgent matters were
reported to MSC 93. MSC 94 will review the non-urgent outcome.
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Draft amendments related to the IGF Code to the STCW Convention, part A and part B of the STCW Code, and
the associated draft MSC resolutions and STCW Circular
Draft Interim Guidance on training for seafarers on board ships using gases or other low-flashpoint fuel
Lloyd’s Register’s view
In general, Lloyd’s Register supports the outcome of HTW 1.
Ship systems and equipment (report of the first session of the Sub-Committee) (agenda item 8)
SSE 1 was held in March 2014. Lloyd’s Register’s report on the meeting can be found here. Urgent matters were
reported to MSC 93. MSC 94 will review the non-urgent outcome. The following issues, emanating from SSE 1, will be
considered for approval/adoption.
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Draft amendments to SOLAS regulation II-2/20
Draft MSC resolution on Amendments to the Code for the Construction and Equipment of Mobile Offshore Drilling
Units, 2009 (2009 MODU Code)
Draft MSC circular on Guidelines on alternative methods for lifeboat drills on MODUs
Draft MSC resolution on Amendment to the recommendation on conditions for the approval of servicing stations
for inflatable liferafts
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Draft amendments to SOLAS chapter II-2 (regulations II-2/4.5, II-2/11.6.1, II-2/11.6.2, and II-2/11.6.3.2) with a view
to subsequent adoption at MSC 95
Draft MSC circular on unified interpretations of chapters 5, 9 and 10 of the FSS Code
Draft MSC circular on the unified interpretation of part 3 of annex 1 to the 2010 FTP Code
Draft MSC circular on the unified interpretation of the Revised recommendation on testing of life-saving appliances
(resolution MSC.81(70))
Draft MSC circular on the unified interpretation of SOLAS regulation III/31.1.4
Draft MSC circular on amendments to the unified interpretations of SOLAS chapter II-2, the FSS Code, the FTP
Code and related fire test procedures (MSC/Circ.1120)
Draft MSC circular on amendments to the unified interpretations of SOLAS chapter II-2 and the FSS and FTP Codes
(MSC.1/Circ.1456)
There will be discussions on the following points:
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Implementation of paragraphs 8.10.1.4 to 8.10.1.6 of the 2000 HSC Code
Application of draft SOLAS regulation II-2/20.3
Lloyd’s Register’s view
In general, Lloyd’s Register supports the outcome of SSE 1. However, the following are noted:
- Interpretation of paragraphs 8.10.1.4 to 8.10.1.6 of the 2000 HSC Code (IACS submission on the exemption from
the installation of rescue boat for HSC if less than 30m in length) should be supported.
- Proposed amendment to the draft SOLAS regulation II-2/20.1 (IACS submission) should be carefully reviewed by a
drafting group, as the current draft questions the scope of application, i.e. if such alternative arrangements should
be entitled to all ships, including existing ships except for ships to which the new SOLAS regulation II-2/20-1
applies.
Navigation, communications, search and rescue (report of the first session of the Sub-Committee) (agenda
item 9)
NCSR 1 was held in July 2014. Lloyd’s Register’s report on the meeting can be found here. MSC 94 will consider the
outcome of NCSR 1; inter-alia, the following items are for approval/adoption:
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Draft SN Circular on World-Wide Radionavigation System
COMSAR.1/Circ.54 on Audits of LRIT Data Centres and of the International LRIT Data Exchange conducted by the
LRIT Coordinator
Draft amendments to LRIT-related circulars (MSC.1/Circ.1259/Rev.5, MSC.1/Circ.1294/Rev.3, MSC.1/Circ.1338,
MSC.1/Circ.1376/Rev.1 and MSC.1/Circ.1412)
E-navigation Strategy Implementation Plan
MSC circular on Guidelines on Harmonization of test beds reporting
Draft Assembly resolution on Revised guidelines for the onboard operational use of shipborne Automatic
Identification Systems (AIS)
Draft MSC circular on the Revised Joint IMO/IHO/WMO Manual on Maritime Safety Information (MSI)
Draft revised MSC.1/Circ.1210 on Guidance on the Cospas-Sarsat International 406 MHz Beacon Registration
Database (IBRD)
Draft revised MSC.1/Circ.1182 on Guide to recovery techniques
Draft revised text for re-numbered chapter 9 (safety of navigation) and 10 (communication) of the draft Polar Code
Draft re-numbered paragraph 11.4 (reporting) of re-numbered chapter 11 of the draft Polar Code
Draft revisions to sections 2.2 (navigation equipment) and 2.3 (communication equipment) of the Record of
additional equipment and operational limitations for the Polar Ship Certificate
Additional guidance on re-numbered chapters 9 and 10 for possible inclusion in part I-B of the draft Polar Code
Draft MSC circular on Unified Interpretations of SOLAS regulation V/23.3.3 on Pilot transfer arrangements
Draft MSC circular on Unified Interpretations on the Completion of items 2.1 and 2.2 of Part 3 of the Form E and
items 2.1 and 2.2 of Part 5 of Forms P and C
In addition, there are submission documents addressing:
- Pilot ladder arrangements
- Service status of Iridium satellite system
Lloyd’s Register’s view
Lloyd’s Register supports the outcome of the NCSR 1 meeting. However, the following are noted with concern:
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Strategic Implementation Plan for e-navigation. While Lloyd’s Register welcomes the outcome, Lloyd’s Register
considers that the plan is not ready to implement, as it lacks details and a realistic time scale.
With regard to the pilot transfer arrangement, Lloyd’s Register agrees with the IACS interpretation and the decision
at NCSR 1 that the calculation for the length of the pilot ladder should be inclusive of the allowance for the 15
degree list. Whilst Lloyd’s Register agrees with the decision at NCSR 1, if the intent is to apply this interpretation to
all ships, including ships in service, we will need a lead-in time that may be linked with dry docking.
Implementation of IMO instruments (report of the first session of the Sub-Committee) (agenda item 10)
III 1 was held in July 2014. Lloyd’s Register’s report on the meeting can be found here. MSC 94 will consider the
outcome of III 1.
MSC 94 will consider:
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The outcome of review of the FAL.5/Circ.39 on Interim Guidelines for use of printed versions of electronic
certificates
The outcome of the analysis of the marine safety investigation report concerning the grounding and loss of the
passenger ship Costa Concordia
The outcome of the analysis of the marine safety investigation report concerning the foundering of the livestock
carrier Danny F II
The general cargo ship Swanland casualty
MSC 94 will review for approval the following draft circulars:
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Draft MSC-MEPC.5 circular on Unified Interpretation on keel laying date for Fibre Reinforce Plastic (FRP) Craft subject to a concurrent decision by MEPC.
Draft MSC-MEPC.4 Circular on Guidelines for the Port State Control Officer related to the ISM Code - subject to a
concurrent decision by MEPC
Draft MSC Circular on PSC Guidelines on seafarers’ hours of rest and PSC guidelines in relation to the Maritime
Labour Convention, 2006 (agenda item 7)
MSC 94 will review for approval the following draft resolutions:
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Draft amendment to Code of the international standards and recommended practices for a safety investigation
into a marine casualty or marine incident (Casualty Investigation Code), Resolution MSC.255(84)
Lloyd’s Register’s view
Lloyd’s Register, in general, supports the outcome of III 1. Lloyd’s Register will closely monitor the discussion on the
electronic certificate issue.
With regard to the Draft MSC-MEPC.4 Circular on Guidelines for the Port State Control Officer related to the ISM
Code, Lloyd’s Register is of the view that this draft should be further carefully reviewed by the human element experts
who are familiar with the ISM Code. The current draft still lacks basic understanding of the shipboard safety
management system.
Carriage of cargoes and containers (urgent matters emanating from the first session of the Sub-Committee)
(agenda item 11)
CCC 1 was held in September 2014. Lloyd’s Register’s report on the meeting can be found here. MSC 94 will consider
the outcome of CCC 1; inter-alia, the following items are for approval/adoption:
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Draft amendments to the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) and the associated
MSC circular cover note (MSC.1/Circ.1352), to be re-issued as MSC.1/Circ.1352/Rev.1
Draft amendments to MSC.1/Circ.1353 on Revised Guidelines for the preparation of the Cargo Securing Manual,
to be issued as MSC.1/Circ.1353/Rev.1
Draft MSC circular on Informative material related to the IMO/ILO/UNECE Code of Practice for Packing of Cargo
Transport Units (CTU Code)
The IGF Code and associated amendment to the SOLAS Convention with regard to LNG as fuel.
- Amendment to the SOLAS Convention to make the IGF Code mandatory
- Structure of the code with regard to the different level of regulations and compliance mechanism
- Definition of gas (MSC 94/11/16)
- Scope of special approval or acceptance - to delete “or its RO acting on its behalf”
- Tank location and limitation
- Secondary barrier for LNG
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- Design, bunkering, monitoring and testing of liquefied gas fuel containment systems
- Other fuel tank issues
- Air-locks
- LNG Bunker Delivery Note
- Standard bunkering station
In addition, discussions on the following are envisaged:
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Environment element of the IMSBC Code
Verified gross mass of a container
Lloyd’s Register’s view
In general, Lloyd’s Register supports the outcome of CCC 1. However, the following items require attention:
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SOLAS amendments to make the IGF Code mandatory
There is a proposal to clarify that Gas Carriers using LNG as fuel should be subject to the IGF Code if the source of
LNG is not cargo (i.e., carried as fuel). It would not be appropriate to regulate gas as fuel on gas carriers as per the
IGF Code with respects to fuel tank location. Other requirements might be appropriate but these would require
evaluation on a case-by-case basis, at this time.
The IGF Code
- LNG Bunker Delivery Note: Lloyd’s Register finds interesting the idea of including a bunker delivery note format
in the IGF Code. It will help to ensure that the composition of the delivered gas is appropriate for the
consumers, and that the energy content meets propulsion and auxiliary power requirements. This proposal
would assist in avoiding potential safety issues associated with loading inappropriate fuel, and provide a
common standard for LNG bunkering.
- Tank location: Lloyd’s Register strongly supports the position submitted to CCC by the Bahamas, Canada and
the United States (CCC 1/4/2) stating:
- the proposed probabilistic calculation method should not be included within the IGF Code unless the
weaknesses indicated are addressed; and
- for the deterministic method, further consideration is required on limiting tank length and this should
account for the greater protection offered by the inboard location of the tank(s)
- With regard to the submission documents on tank location to MSC 94, Lloyd’s Register is of the following
views:
- MSC 94/11/7, limitation of tank length - We do not support the proposal. If the tank is located inboard of
B/5 then we consider a tank length limit is not required. However, a limit would be appropriate for tanks
located closer than B/5. Lloyd’s Register considers that limitation of tank length is necessary, which would
avoid designs where a large part of a ship’s side is in way of the fuel tank, thus limiting the likelihood of tank
impact in a collision.
- MSC 94/11/8 - An important observation in this paper is the difficulty of appraising fuel tanks of irregular
shape, where some parts of the tank may be closer to the side of the ship than other parts. Clarification of
the approach and limits/criteria are requested before finalising the prescriptive requirements. Lloyd’s Register
sees that this is another supporting evidence on the need to take the approach given in CCC 1/4/2 above.
- With regard to the submission on “Airlock” (MSC 94/11/14), Lloyd’s Register supports the proposals in
general as it provides clarities of the requirements.
Formal safety assessment, including general cargo ship safety (agenda item 13)
MSC 94 will consider:
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The outcome of III 1 on reporting of accidents and incidents
A proposed work method within IMO on FSA
Lloyd’s Register’s view
Lloyd’s Register shares the views given in the submission by the IACS on proposal on the work methods within IMO
and FSA, which requests insertion of the following in the Committee’s guideline on the work methods:
“When an FSA is carried out by a member government or an organization having consultative status at IMO, the
Organization will set up terms of reference for a working group, which is responsible for coordinating the
implementation of the results of an FSA study at IMO level”.
Piracy and armed robbery against ships (agenda item 14)
MSC 94 will consider
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An update on developments related to piracy and armed robbery against ships
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Any relevant submissions by Member Governments and international organizations on how best to reflect the
value of ISO PAS 28007 in IMO’s guidance on the use of PCASP and on piracy and armed robbery against ships;
and
Any other documents submitted by Member Governments and international organizations under this agenda item
Implementation of instruments and related matters (agenda item 15)
The MSC 94 will consider:
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Continued discussion on Guidance on Drafting of Amendments to the SOLAS Convention and Related Mandatory
Codes
Clarification on an audible alarm and a visual or other device which will alert the user of breathing apparatus for
firefighting outfit
Further development of the MSC.1/Circ.1483 on Interim guidance on drafting of amendments to the 1974 SOLAS
Convention and related mandatory instruments
Lloyd’s Register’s view
Lloyd’s Register supports the early conclusion of the Guidance on drafting amendments to the 1974 SOLAS Convention
and related mandatory instruments as it will assist in the finalization of the text of a mandatory instrument in a clearer
manner.
Work Programme (agenda item 18)
Various new work programmes are proposed. Inter-alia, Lloyd’s Register is particularly interested in the following:
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Development of safety requirements for the carriage of liquefied hydrogen in bulk
Proposal for a new, unplanned output to amend SOLAS regulation VI/2 - requirements for the retention of the test
certificates of group A cargoes
Reconsideration of the flashpoint requirements for oil fuel In SOLAS regulation II-2/4.2
Lloyd’s Register’s view
With regard to the “reconsideration of the flashpoint requirements for oil fuel In SOLAS regulation II-2/4.2”, Lloyd’s
Register, as a classification society, while it welcomes the proposals is also aware of the impact on the current
regulatory scheme as 60 Celsius has been used for a wide range of the fire safety requirement.
Any other business (Agenda item 20)
The Committee will consider:
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Thematic priorities for the Integrated Technical Co-operation Programme (ITCP) for 2016-2017
Information on developments on GISIS
In-service testing of automatic sprinkler systems on passenger ships – findings and proposed actions required to
assure effective operation in emergency situations
Bunker quality management framework in the Port of Singapore
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