Update on permanent means of access (PMA)

Reference is made to previous efforts of the Round Table (RT) Associations (ICS, BIMCO, INTERCARGO, INTERTANKO) to find the most efficient solution to correct through amendments some aspects of the SOLAS requirements for Permanent Means of Access (PMA). In principle, and in accordance with the IMO regulations, the RT needed Flag Administrations to sponsor one of its suggested alternatives. That action seems now to have been initiated by Greece, which last week submitted proposed textual amendments to the PMA provisions direct to the next session of the Maritime Safety Committee (MSC 78 in May 2004), for adoption at that session. It is understood that the proposals have been circulated to all SOLAS Member States under Circular letter 2509 dated 12 November 2003.

Consequently, the RT Associations have revised the short industry submission to next week’s IMO Assembly to reflect support for the Greek initiative. INTERTANKO members are urged to draw it to the immediate attention of their flag administration. The purpose of the paper is to ensure that the problems associated with PMA are understood by all IMO member governments, and it is hoped that it will receive widespread support at the Assembly.

The contacts and discussions RT Associations have had with Flag Administrations over the past two months suggest that there is now in fact considerable understanding of the difficulties to which the PMA provisions, as drafted, give rise, at least on the part of those governments approached by the industry. The decision of Greece to submit detailed amendments direct to MSC 78 is presumably based on the calculated expectation that there will be sympathy and support for reviewing the provisions at the next MSC (and probably at the 47th session of the Sub-Committee on Ship Design and Equipment which precedes it).

If that expectation proves misplaced, Greece and/or other administrations still have the option of making a formal objection to the current regulations by the deadline of 31 December this year, which was the RT initial alternative plan.

The RT Associations, probably in close cooperation with IACS and other interested parties, will develop their own technical proposals for improving the PMA requirements, and will now be able to comment on the text proposed by Greece. IMO can take a decision and adopt the amendments in May 2004 (MSC 78) or latest in December 2004 (MSC 79). According to IMO procedures, new amendments will come into force some 12 months after their approval/adoption. However, the received wisdom is that, if there is widespread agreement on the part of IMO Member States that the new provisions improve upon the existing text, it can be agreed by resolution that the new provisions will be applied immediately, in preference to those to be replaced. In this way, these amendments would be applicable from day one of the date of the enactment of the PMA requirements (January 2005).

We do recognise, however, that there will still be some ships that, by nature of their contract dates, will encounter problems with the pre-existing requirements. We will keep members informed of developments in May 2004, which might already indicate the final outcome of these amendments.

Click here to view the submission

For further details:

Contact: Dragos Rauta