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Friday, September 21, 2018


At the International Maritime Organization’s headquarters in London last week, the 47th meeting of the Safety of Navigation sub-Committee (NAV 47) was convened. INTERTANKO was represented by Howard Snaith and Tim Wilkins attending two working groups and a drafting group covering Places of Refuge, Pilotage and VDRs.

Places of Refuge

Subsequent to the IMO's Marine Safety Committee (MSC) having addressed the issue of Places of Refuge, the NAV sub-Committee was charged with coordinating the work. The main focus for NAV was the establishment of specific titles for the three sets of Guidelines that were to be developed. These were formulated by a small working group established during the week in which INTERTANKO participated. Whilst placing highest priority on the safety and environmental aspects associated with this operation, the Working Group prepared a framework on guidelines covering:

1.  Actions a master should take when in need of a place of refuge

2.  The evaluation of risks associated with the provision of places of refuge

3. Actions expected of coastal states for the identification, designation and provision of such suitable places

In addition, the sub-Committee agreed that the guidelines should be based on the guidelines for a structure of an integrated system of contingency planning for ship board emergencies. Further input will be invited from the Communications, Search and Rescue sub-Committees as well as the Marine Environment Protection Committee (MEPC).

Pilotage revision of Resolution A.485 (XII) Annex 2

INTERTANKO submitted a joint Industry paper to NAV 47 together with OCIMF, BIMCO, SIGTTO, ICS, IFSMA and INTERCARGO proposing a revision to Resolution A.485 (XII) Annex 2, the Training and Certification of Marine Pilots, recommendations on operational procedures for Maritime Pilots other than deep sea Pilots.

Please click here to view the INTERTANKO joint submission NAV 47/6.   The industry representatives felt strongly that the only way to resolve the issue was to discuss the associated problems with the pilots before NAV 47 and to resolve any differences. Accordingly INTERTANKO instigated and hosted two industry meetings with the above industry representatives and IMPA (the International Maritime Pilots Association). Although industry and the pilots came very close to full agreement, we were under a time constraint for final submissions to NAV 47.  Accordingly IMPA submitted their paper NAV 47/6/1, please click here to view.

From the outset, the industry representatives expressed their willingness to discuss the differences in the Drafting Group that IMO had arranged for such a purpose during that week. However, the Chairman of NAV 46 instructed Plenary to use, as a basis for discussion, a paper that was the outcome of the NAV 46 Working Group NAV 47/J/3. To view please click here.  Consequently there was very limited discussion in Plenary of the joint submission NAV/47/6 by the sub-Committee. Subsequently INTERTANKO raised an objection to the effect that we were very disappointed that the content of this Joint Submission appeared not to be given sufficient recognition, particularly the pre-arrival exchange of information with the master.  Accordingly INTERTANKO, OCIMF, IFSMA, BIMCO, SIGTTO, INTERCARGO, ICS made the following statement:

“While accepting the Sub-Committee's decision to approve a revised Annex 2 to Resolution A.485 (XII), the Industry organisations wish to place on record their disappointment that in order to finalise the revision it has not been possible to address certain key issues.  Of particular importance to ship operators is the need to ensure a proper exchange of information between ships and pilots to enable ships' masters to prepare passage plans according to the recommendations in Resolution A.893(20), as well as for accident investigation. Although the Industry organisations would have preferred to see greater clarity given to the above and other aspects of the master/pilot relationship in the revised Annex 2, the organisations’ acceptance of the revised text is on the understanding that it nevertheless imposes a clear obligation on pilots to provide information essential to enable the Masters to complete their voyage plans”.

Please click here to view the full statement.

In summary the outcome of this issue from NAV 47 was the following drafted document that will be taken forward as the final revision of Annex 2 to Resolution A.485. This final document is shown in the report of the drafting group NAV 47/WP. Please click here to view this document.

As a concluding remark, INTERTANKO has now established some strong links with IMPA and the pilotage associations from Australia, the USA and Canada and we do see a positive way forward by continuing to enjoy a direct dialogue with these organisations and working together to improve safety matters concerning pilotage.  For further information, please contact Howard Snaith by e-mail:

Vessel Data Recorders (VDR)

The feasibility study requested by IMO into the retrofitting of VDRs to existing cargo ships is underway and due to be completed by 2004. There were several papers submitted by the UK, Japan and a combined paper submitted by Germany, Finland and Sweden.

INTERTANKO has been very active in carrying out its own study into the retro-fitting of VDRs to existing cargo vessels both with regard to cost effectiveness and the interfacing practicalities involved in such work. Accordingly, INTERTANKO has met and discussed with various VDR and AIS manufacturers to aid this work and we have also been assisted by some of our members.

Although our studies are not fully complete we have established that the approximate cost of retrofitting a VDR is in the region of US$100,000, depending upon where the fitting is performed and the interfacing required. However, as a very large part of this cost is actually for the protective capsule, our studies have also being directed at the utilisation of existing equipment such as AIS coupled with voice and radar inputs to a data collecting unit without a protective capsule.

Accordingly INTERTANKO has developed close links with Germany, Finland and Sweden based on their paper submitted to NAV 47. Please click here to view this paper NAV 47/7/4.

INTERTANKO supported this proposal and submitted a verbal interjection in Plenary.  Please click here to view the statement.

INTERTANKO also made the following very important point to NAV 47, namely that this was an appropriate moment for INTERTANKO to remind the sub-Committee of the current revision of MARPOL 13G relating to the phase out of single hull tankers. We would like it recorded that INTERTANKO draws the attention of the sub-Committee to this fact and asks that this be taken into account when completing the feasibility study for retro-fitting VDRs to existing vessels, and that appropriate exemptions are made which exclude mandatory carriage for such vessels that will be phased out.

INTERTANKO was thus invited by the Chairman of NAV 47 to submit these comments formally to the next session of MSC, which we will, of course do.

For further information, please contact Howard Snaith by e-mail: or Tim Wilkins by e-mail: