IMO III 9: Guidance on remote survey and ISM Code audits finalized

The 9th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 9) agreed on guidelines for remote surveys and ISM Code audits in extraordinary circumstances, and on updates to the survey guidelines under the Harmonized System of Survey and Certification (HSSC) and the procedures for port state control.

Meeting highlights

• Reviewed lessons learned from accident reports
• Finalized guidance on remote surveys and ISM Code audits under extraordinary circumstances
• Agreed on the amendments to the survey guidelines under the Harmonized System of Survey and Certification (HSSC)
• Agreed on the amendments to procedures for Port State
Control (PSC)

Remote surveys, ISM Code audits and ISPS Code verifications

III 9 finalized the development of guidance on the application of remote surveys and International Safety Management (ISM) Code audits for the situation that on-site attendance is not possible under extraordinary circumstances. The guidance for surveys will be included in the survey guidelines under the Harmonized System of Survey and Certification (HSSC), while the guidance for remote ISM Code audits will be included in the guidelines for administrations on implementation of the ISM Code. The amendments to these guidelines are expected to be adopted at Assembly 33 in December 2023.

Guidelines for remote International Ship and Port Facility Security (ISPS) verifications under extraordinary circumstances has not yet been developed, as there are concerns related to the application of remote techniques and protection of security-sensitive information. However, it was agreed that guidelines are needed, and a Correspondence Group will conduct further work on this issue.

Several delegations were of the view that a cautious approach is needed with respect to remote surveys and audits in ordinary circumstances. The established Correspondence Group will continue work on this issue.

Consideration and analysis of reports on alleged inadequacy of port reception facilities (PRF)

Administrations are required to report alleged inadequacies of port reception facilities to IMO’s Global Integrated Shipping Information System (GISIS), and the port authority is expected to revert with their comments. III 9 considered the reported difficulties encountered in 2022. Parties to MARPOL were urged to increase the level of reporting.

Lessons learned and safety issues identified from the analysis of marine safety investigation reports

Learning from accidents to avoid similar events in the future is important. III 9 reviewed lessons learned from several accidents, which will be published on the IMO’s website. Noting that lessons learned are not submitted for all accident investigation reports, III 9 agreed to issue a circular to remind member states to submit reports.

Based on lessons learned, III 9 developed a proposal for a new output on fall from heights, to be approved by the Maritime Safety Committee (MSC).

A questionnaire regarding collisions with fishing vessels was developed to gather information from member states on this subject.

Further, concerns regarding the unsatisfactory implementation of the ISM Code were considered, and the following was noted:

• A common safety issue was lack of risk assessment.
• A majority of accident investigations indicated that the ISM Code / SMS had not been fully implemented.
• In many cases, the ISM-related deficiency could have been detected during an inspection/audit.
• The problem was how the ISM Code is implemented, not with the ISM Code itself.

Man overboard from fishing vessels is a concern, and the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR) is invited to recommend to the ICAO/ILO Joint

Working Group on Harmonization of Aeronautical and Maritime Search and Rescue to determine the most effective and appropriate means for locating a person falling into the water from fishing vessels.

Member states and international organizations were invited to submit proposals for a new output for a comprehensive and holistic review of the Casualty Investigation Code to MSC.

Measures to harmonize port state control (PSC) activities and procedures

Amendments to the “2021 Procedures for Port State Control (Resolution A.1155(32))” were completed by III 9 and are expected to be adopted at Assembly 33 in December 2023.

The following amendments have been agreed on:

• Specification on the process of detention and suspension of PSC inspections due to clearly substandard conditions on the vessel
• Inclusion of 2022 “Guidelines for Inspection of Anti-fouling Systems on Ships (Resolution MEPC.357(78))” as an annex
• Update of “Guidelines for Detention of Ships under MARPOL Annex VI”, for example, but not limited to:
• Clarification was given for detainable deficiencies regarding Statement(s) of Compliance covering Fuel Oil Consumption Reporting and Operational Carbon Intensity Rating.
• Clarification was given that as part of a more detailed inspection, the PSCO may review the plan of corrective actions for the carbon intensity reduction measures for ships rated as D for three consecutive years, or rated as E. However, an ongoing/outstanding implementation of the corrective action plan is not a ground for a detainable deficiency.
• A clarification note was added that for “new ships”, the Statement of Compliance is needed only from 1 June the following year.

The “Guidelines for Port State Control under the BWM Convention (Resolution MEPC.252(67))” were reviewed. It was concluded that the BWM Convention has been amended and is currently being reviewed as part of the experience-building phase. Therefore, an update of the guidelines for PSC under BWM is expected and needs to be considered.

The review of the interim “Guidance on Control and Compliance Measures to Enhance Maritime Security (Resolution MSC.159(78))” will be carried out by a Correspondence Group.

Updated survey guidelines under the Harmonized System of Survey and Certification (HSSC)
The survey guidelines under HSSC were updated and are expected to be adopted at Assembly 33 in December 2023.

The “Non-exhaustive List of Obligations under Instruments Relevant to the IMO Instruments Implementation Code” were also updated according to the newest requirements. A Correspondence Group was established to continue updating the HSSC guidelines with respect to new regulations entering into force.

Guidance on implementation of Cape Town Agreement

The Cape Town Agreement sets minimum requirements on design, construction, equipment, surveys and certification of fishing vessels of 24 metres in length and over, or equivalent in gross tonnes. The agreement has now been ratified by 21 countries, and 22 are needed before the convention will enter into force. In addition, 3,600 fishing vessels are needed, and currently the number is about 2,600. The intention of the guidance is to support implementation of the Cape Town Agreement. A Correspondence Group was established to further work on the guidance, which is expected to be completed at III 10 in 2024.


DNV recommends that customers note the lessons learned from accident investigation reports, and the clarification related to port state control for the Fuel Oil Consumption Reporting and Operational Carbon Intensity Rating.

As III is a Sub-Committee, all decisions concerning rules, regulations and dates are subject to further consideration and approval by the Maritime Safety Committee (MSC), Marine Environment Protection Committee (MEPC) or by the Assembly.
Source: DNV

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