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Wednesday, December 13, 2017

INTERTANKO submission to the European Commission on the Third maritime Safety Package

As reported in Weekly News No. 8 of 25 February 2005, the European Commission is in the process of preparing a so-called third maritime safety package. The main topics under consideration during the current second phase of this process are: classification societies, port state control, insurance – civil liability, and review of the Vessel Traffic Monitoring and Information Systems Directive.

Click here to download a copy of INTERTANKO's e-mail to Mr Fotis Karamitsos, Director DG TREN: Energy and Transport, attaching joint comments from INTERTANKO/INTERCARGO, which i.a.:

- urge the Commission to encourage Member States to ratify the relevant international Conventions faster than has hitherto been the case, and then ensure uniform and efficient implementation;

- urge an international approach to all subjects relating to regulation of shipping, also including maritime insurance;

- suggest that the European Union should consider providing appropriate protection with respect to competition laws for measures taken by insurance companies to deny insurance cover to inferior ships;

- object to the inflexible and at times counterproductive 25% Port State Control requirement;

- highlight the problems connected with additional reporting requirements for pilots,

- suggest a number of incentives for quality shipping;

- suggest better cooperation among PSC authorities and a wider role for shipping industry involvement;

- support harmonised high standards and uniformity of good training of inspectors across all PSC regimes;

- underline that the Commission's concern over the accumulation of functions by classification societies was mainly due to the fact that many flag state administrations do not have the required resources to undertake their statutory functions and thus it is not unreasonable that these have been delegated to classification societies. Any weakness under present conditions would thus appear to lie more with the flag states and not with the classification societies. A main point made is that the system works, and is probably far more cost-efficient than separation of the functions;

- express concern over ideas that that too much information may be sent and received cluttering both the mariner and the navigating systems;

- stress that there is a need for ice-class rules to be internationally harmonised through the International Association of Classification Societies (IACS) and then recognised by Flag Administrations;

- suggest improvements to the port reception Directive

- warn against mixing the concept of places of refuge with the issue of ship-to-ship transfers.

The Commission's plan is to complete the work on all the elements of the package, including the important impact assessments, in time to present proposals to the Council meeting of Transport Ministers in June. In view of the problems of translation bottlenecks in the European Union, it remains to be seen whether this timetable is realistic.

Contact: Kristian R. Fuglesang