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Tuesday, June 19, 2018

IMO IS SIGHTING A FINAL DEAL ON THE CONDITION ASSESSMENT SCHEME

The three-day IMO Intersessional meeting on the Condition Assessment Scheme (CAS) commenced on 30 January. The scope of work for the meeting was to complete as much as possible of the drafting of the CAS so as to be able to present it as a proposed package to MEPC 46 (in April 2001) for formal approval.

The scope of work for the meeting was to complete as much as possible of the drafting of the CAS so as to be able to present it as a proposed package to MEPC 46 (in April 2001) for formal approval. The CAS is considered by the EU to be a necessary and integral part of the new amendments to Regulation 13G of MARPOL. 

It is the considered opinion of the INTERTANKO delegation that the outcome of the Intersessional drafting work was close to the initial objectives.  However it appears that the next MEPC meeting will be left to decide on a very difficult issue.  This issue is the extent to which the direct involvement of an Administration or to what extent its obligations could be delegated for the Verification of the Final CAS Report.  

NOTE: the Intersessional meeting will end late Friday afternoon and this report should be read as a provisional assessment as of Thursday evening.

 The main principles discussed and the degree of completion achieved were as follows:

Acceptance criteria – IMO Resolution A.744(18) is the instrument to be used (i.e. IMO Guidelines for the Enhanced Survey Program). Any further improvements to this instrument (now made mandatory through SOLAS) would automatically add to the acceptance criteria for CAS. Agreed.

Survey Planning – The Survey Plan should have a standard format. IACS and INTERTANKO agreed to work out a draft as soon as possible.

Time for Owners’ Notification to Administration, submission of the Questionnaire and submission of the Survey Planning – There was an initial proposal for 12, 6, and 3-months ahead of the commencement of the survey for each of the identified obligations, respectively.  INTERTANKO suggested that these periods, especially the notification to the Administration, may be too long and may be impractical for scheduling and planning of the survey. The issue is still to be discussed. 

Validity of CAS Certification when changing Flag – It appears that there would be a period of grace between the change of Flag and the moment the new Flag evaluates the documentation of the CAS Survey. The gaining Flag, if satisfied with the assessment, might issue a new Statement of Compliance the validity of which would expire at the same time as the one it replaces. This needs to be agreed by MEPC 46. 

Second Opinion – This is a difficult issue within the draft CAS. EU countries wish to have a second opinion on the outcome of the work done by the Recognised Organisation (RO) i.e. Class on their behalf. So, the following text was suggested as part of the Verification of the CAS activity:

The surveyor involved in the verification and monitoring procedures, acting directly for the Administration, shall have no connection with any RO responsible for CAS program on that vessel.

In practical terms, this paragraph says that a classification society performs a CAS on a vessel and a second classification society checks the work done by that classification society. It was discussed whether alternatives other than a second classification society were available.

IACS has made a strong statement that none of the IACS Members would be available to provide this second opinion on the work done by another fellow IACS Member. They also highlighted the legal problems when a “second opinion” contradicts the first opinion.

This was left to MEPC 46 for a final decision.

Category 3 – The question as to whether or not to include Category 3 tankers (under 20,000 dwt) under CAS obligations was deferred to MEPC 46. In general there is not much support for this proposal.  However, some EU countries are insistent.

Annual audit – There was a suggestion by IACS to include in CAS a mandatory Annual Audit on tankers subject to CAS. The proposal was removed from this document. However, it will be recommended to MEPC and to MSC for consideration under the SOLAS provisions.

An updated report on this Intersessional meeting will be provided in the Weekly NEWS next week.

For further information please contact Mr. Dragos Rauta – dragos.Rauta@intertanko.com