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Thursday, September 20, 2018

THE EYES OF THE WORLD MARITIME COMMUNITY ON IMO THIS WEEK

The 75th session of the Maritime Safety Committee (MSC) was convened at the IMO Headquarters in London 15 to 24 May. In his opening speech, the Secretary-General, Mr Bill O’Neil, said that many important developments had occurred since the last meeting with terrorist attacks in New York and Washington having shaken the entire world. He reiterated that IMO’s response was swift, firm and decisive – shipping should not be allowed to become a soft target for international terrorism. Arguments, such as the non-existence of an internationally accepted definition of terrorism and IMO’s apolitical character were brushed aside and an action plan was put in place almost immediately after the tragic events.

There were a large number of items on the agenda and the members’ interests were represented by a five-man delegation from the Secretariat, Dragos Rauta, Howard Snaith, Gunnar Knudsen, Tim Wilkins and Tim Gunner.

This 75th session involved long hours and a tremendous amount of work and at the time of writing there are still two days before the session is closed. A detailed report from the INTERTANKO delegation follows.

Maritime Security

The fact that 62 submissions, most of which were substantive, were submitted for consideration at this meeting is a clear indication of the interest and concerns that this issue has generated among Governments and industry associations. A considerable time had to be spent in Plenary for presentation of key papers before the Working Group on Maritime Security could commence its work on detailed proposals for revised regulations.

INTERTANKO found it beneficial to address these non tanker-specific tasks through close interaction with other industry players to strengthen the industry positions on the various topics under consideration.

Among the central items is the accelerated AIS implementation, which has developed into a discussion of long- versus short-range tracking of ships. Focus has been placed on the frequency and mechanisms of reporting/polling and that tracking should be automated and without cost to ship operators. INTERTANKO and others have focused on the potential need for the system to be occasionally switched off for safety and commercial reasons. In the latter case the motive could, for instance, be protection of a confidential market fixture which may call for the vessel's movements not to be immediately monitored.

The Industry has repeatedly reiterated that onboard access for port personnel requires identification regulations at least as stringent as those that will be applicable to seafarers. The latter will be dealt with through an IMO/ILO project. INTERTANKO sees the frequent cases of unidentified personnel gaining unimpeded access to ships as a major threat to vessels' safety and finds that ships are particularly vulnerable when in port. Other industry partners share this view.

To ensure that a complete proposal of amendments to SOLAS Chapter XI and the International Ship and Port Facility Security (ISP) Code can be presented to the Diplomatic Conference on Maritime Security for adoption in December 2002, it has been decided that a second Intersessional Working Group shall be convened the week starting 9 September 2002.

At the time of writing, two full days of deliberations remain. INTERTANKO will expand on this preliminary report as soon as the official conference documents have been made available.

Contact: Gunnar A. Knudsen, e-mail:gunnar.knudsen@intertanko.com

Resolution A.485 Training & Certification of Maritime Pilots

INTERTANKO has been actively involved in the ongoing debate within IMO over the last three years regarding the revision of Resolution A.485 covering the Training & Certification of Maritime Pilots. These previous discussions took place during earlier sessions of the Navigation sub-Committee and Standards of Training & Certification sub-Committee. This session of the Marine Safety Committee (MSC) approved the final version of this revised resolution.

However, INTERTANKO/ICS/OCIMF made the following collective verbal statement in Plenary:

"Although IMPA, (International Maritime Pilots Association) and Industry have enjoyed a continued dialogue to try and resolve differences with this resolution and whilst Industry does not have any objections to the content of A.485 annex I & II, Industry was still nonetheless disappointed that some matters remained unresolved, in particular the requirements under A.893 for a passage plan berth to berth.

In this regard the Shipping Industry is in the process of finalising a guide for masters and pilots to ensure that best practices are followed, and when this is completed it will be presented to IMO".

Considerable effort has been made to incorporate Pilotage Associations in the production of this guide to best practice. However, these efforts have been unsuccessful.

Therefore INTERTANKO and the joint Industry Associations will proceed to produce this Industry Guide and members will be advised when it has been completed.

Contact: Howard Snaith, e-mail:howard.snaith@intertanko.com

Emergency Escape Breathing Devices (EEBD)

The issue of Emergency Escape Breathing Devices (EEBDs) was raised by the INTERTANKO CTOAG and there have been ongoing discussions on it within IMO, in particular in the Fire Protection sub-Committee. The main concern is related to the interpretation of the requirements by the Flag Administration, in particular the question of how chemical tankers would fit into these proposed requirements. Due to the current requirements under the IBC/BCH Codes for Escape sets, confusion has also arisen regarding the location of EEBDs and the number of spares required.

Accordingly MSC agreed that the matter would be referred back to FP for clear and correct interpretation. This will enable INTERTANKO to address the issue and table the above concerns.

Contact: Howard Snaith, e-mail:howard.snaith@intertanko.com

Lifeboat Circular

INTERTANKO raised the matter of lifeboat accidents in DE/44 (Design & Equipment Sub Committee) in 2001 in conjunction with ICS, OCIMF & SIGTTO. (The Joint Lifeboat Accident Report is available here:) INTERTANKO was successful in having this matter placed on the DE agenda as a high priority item. As part of the ongoing work in DE (in which INTERTANKO is participating) this MSC session considered the issue of the unacceptably high number of lifeboat accidents that have occurred over recent years, as well as the crews that have been injured, sometimes fatally, while participating in lifeboat drills/inspections, and approved an MSC circular on the matter. The circular highlights the circumstances surrounding the accidents, calls on Member Governments to take the necessary action to prevent further accidents and offers guidance on how to prevent them. As this circular has only just been approved it is not yet available in its final form. However, we will advise members as soon as it is available from the IMO.

Contact: Howard Snaith, e-mail:howard.snaith@intertanko.com

Emergency Towing Arrangements for Tankers

The current guidelines pertaining to Emergency Towing Arrangements on Tankers are contained in resolution MSC.35(63), which can be viewed here . However, this MSC session adopted the amendments to regulation 3-4, which has now been replaced by the following text:

QUOTE

Regulation 3-4 Emergency Towing Arrangements on tankers

1. Emergency Towing arrangements shall be fitted at both ends on board every tanker of not less than 20,000 DWT

2. For tankers constructed on or after 1 July 2002

.1 the arrangements shall at all times be capable of rapid deployment in the absence of main power on the ship to be towed and easy connection to the towing ship. At least one of the emergency towing arrangements shall be pre-rigged ready for rapid deployment; and

.2 emergency towing arrangements at both ends shall be of adequate strength taking into account the size and deadweight of the ship and the expected forces during bad weather conditions. The design and construction and prototype testing of emergency towing arrangements shall be approved by the administration, based on the guidelines developed by the organisation

3. For tankers constructed before 1 July 2002 the design and construction of emergency towing arrangements shall be approved by the Administration based upon the guidelines developed by the organisation *

* refer to the guidelines on emergency towing arrangements for tankers adopted by the maritime committee by resolution MSC.35(63) as may be amended

UNQUOTE

Contact: Howard Snaith, e-mail:howard.snaith@intertanko.com

Multiple Inspections

INTERTANKO submitted a letter to IMO at the end of 2001 regarding multiple inspections. Our letter and those submitted by other industry associations can be viewed here.

IMO addressed this issue at this MSC session. It was very encouraging to note that the only Industry submission commented upon by IMO was that of INTERTANKO, in particular our suggestion that a Global database of information created by a pool of responsible industry players could reduce the current number of inspections by an estimated 75% to 9 inspections a year (not only those of a commercial nature but also P&I Clubs, ISM Audits, PSC, USCG TVEL/LOC inspections, Class surveys, Independent Vetting Inspections operating outside of recognised industry systems such as SIRE and CDI, and terminal Inspections).

IMO further called upon PSC regimes to report back to MSC 80 regarding the impact of the ISM Code in order to allow them more time to fully assess its impact upon shipping safety. IMO further commented that it was in the commercial sector of vetting inspections that the Industry had the greatest scope to reduce the current high number of inspections. It was generally accepted that the proliferation of inspections was due to a lack of confidence in the inspection authorities. Accordingly IMO called upon Industry to form an inter-industry group to address a reduction in the number of commercial vetting inspections, such that a duplication of effort would be avoided.

IMO further called upon the PSC regimes to work in greater harmony and share inspection data.

A further comment made was that despite all the information contained in SIRE reports and all the statutory information contained in CDI reports being available to PSC regimes under confidentiality agreements via EQUASIS, SIRE was only receiving 4 hits a month by PSC authorities to access this information. IMO therefore requested the PSC authorities to address this apparent shortcoming.

Contact: Howard.Snaith, e-mail:howard.snaith@intertanko.com

COMSAR - Continued use of VHF Channel 16

There was considerable debate regarding proposals to remove the requirement to keep a listening watch on VHF Channel 16. COMSAT sub-committee have a proposal on their agenda to remove VHF 16 from the listening watch requirements and replace this by DSC (GMDSS automatic distress alerts). COMSAR decided that by 2005 VHF 16 should be replaced by other more efficient methods. However, it was agreed at this session of MSC that 2005 may be extended as appropriate and as determined by MSC to ensure that port Administrations did indeed have adequate alternatives in place.

Oil Mist Detection

The United Kingdom was successful in raising a new agenda item onto the work programme of MSC, which will be dealt with by FP/47 (Fire Protection sub-Committee) Their paper (MSC/75/22/3) can be downloaded from here .This deals with research undertaken by the UK Government into the incidence of low pressure fuel systems in response to a request from the UK Marine Accident Investigation Branch (MAIB). The results of this study indicate that most engine room fires are a result of the formation of Oil Mist. The UK did not propose a mandatory requirement for fitting Oil Mist detectors but requested the development of an MSC Circular to provide guidelines for the manufacture and installation of such equipment, to supplement the fire detection systems that are currently required.

This MSC session approved that this would be placed on the MSC work programme as a high priority item through the Fire Protection sub-Committee with a completion date of 2004.

Contact: Howard Snaith e-mail:howard.snaith@intertanko.com

Technical provisions for means of access for inspections

It has long been recognised that the only way of ensuring that the condition of a ship’s structure is maintained to conform with the applicable requirements is for all its components to be surveyed on a regular basis throughout its operational life. This ensures that the ship is free from damage such as cracks, buckling or deformation due to corrosion, overloading or contact damage and that thickness diminution is within established limits. The provision of a suitable means of access to the hull structure for the purpose of carrying out overall and close-up surveys and inspections is essential and such means should be considered and provided for at the ship design stage.

The issue was first raised at DE 45 where both regulation and technical provisions were considered. However due to the shortage of time between DE 45 and MSC 75, INTERTANKO believed that inadequate time had been allowed for industry to consider the totality and implications of the technical provisions which will become mandatory.

Pursuant to this, INTERTANKO made a submission at MSC 75 requesting deferral to MSC 76 so that industry could consider the totality of the proposed technical provision requirements and take into account existing industry studies relating to areas of corrosion in the cargo block.

INTERTANKO’s submission was well received in Plenary resulting in industry being allowed the time requested to review the provisions and report to MSC 76 with proposals.

For further information and details on the technical provisions, please

Contact: Dragos Rauta e-mail:dragos.rauta@intertanko.com or Tim Gunner timjg@online.no