IMO’s Sub-committee on Ship Design and Equipment (DE 50) – lifeboats and MSC.1/Circ.1206

Prior to its 50th session, the IMO’s Sub-committee on Ship Design and Equipment (DE) had been tasked by the Maritime Safety Committee (MSC 82 -Dec 2006) to advise and consider how MSC.1/Circ.1206 could be made mandatory prior to 2010. It was also asked to develop guidance for the use of Recognised Organisations in the inspection and servicing of life-saving appliances (LSA), and advise MSC 83 accordingly, since MSC 82 could not reach a firm decision on how and when MSC.1/Circ.1206 should be made mandatory.


The general understanding at the IMO is that Annex 1 (Servicing and Maintenance) of the circular will become mandatory in due course. The circular is not yet mandatory by reason of the general concern that there is a lack of available service inspectors/engineers, which, according to the circular, have to be authorised by the Original Manufacturer.


DE 50 decided to delegate consideration of this task to a working group, in which INTERTANKO participated and where we expressed the view that it was necessary to amend the circular in order to allow independent service providers to be eligible to carry out the necessary inspections and services, so that the circular could be made mandatory. This view was also supported by Dominica, Bahamas and the International Chamber of Shipping (ICS).


However, the majority of those present, including Norway, did not agree with our view and opined that the circular should not be amended. Finally, it was decided to urge the Original Manufacturers to set up the necessary service networks and to establish a Correspondence Group to develop guidelines for Recognised Organisations on how to approve independent service providers in cases where the Original Manufacturer’s services are not available (See paragraph 9 of Annex 1 in the Circular).

The Correspondence Group will report to DE 51 (2008).


INTERTANKO opposes the view that only the Original Manufacturer should be allowed to carry out the inspections and maintenance, since our members have experienced considerable difficulty in complying with this circular due to the lack of availability of Original Manufacturers’ inspectors/engineers. We are also confident that established, independent service providers, who are already available and have been in this business for many years, are fully competent to carry out this work, but are no longer permitted to do so.


Unfortunately, INTERTANKO does not believe that the outcome of DE 50 will decrease our members’ difficulties.


The report of DE 50 will be considered at MSC 83 in October this year, where INTERTANKO will consider raising our concerns yet again to draw the IMO’s attention to the difficulties our members are encountering.


INTERTANKO requests any members who experience difficulties in complying with the circular to notify and seek advice from their administrations, but also to keep INTERTANKO informed of the situation. In particular, INTERTANKO would appreciate information from its members on which ports and which manufacturers are creating the difficulties.


For background information on the circular, please click here.


For INTERTANKO’s best practice on how to comply with the circular, click here.


Contact: Fredrik Larsson