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IMO Implementation of IMO Instruments

(III 1)
Summary Report

Introduction
The 1st session of the IMO Sub-Committee on Implementation of IMO Instruments (III 1) was held from 14 to 18 July
2014, at the IMO headquarters in London. This briefing summarises subjects discussed which are relevant to the work
of Lloyd's Register.
It should be noted that this was the first meeting of the renamed FSI Sub-Committee.

Summary of discussions
The following agenda items are relevant to the work of Lloyds Register.
Decision of other IMO Bodies (agenda item 2)
The Sub-Committee was informed of relevant decisions made and any actions taken by other IMO bodies. These were
considered under the relevant agenda items.
Responsibilities of Governments and measures to encourage flag states compliance (agenda item 3)
The Sub-Committee considered in detail FAL.5/Circ.39 on Interim guidelines for use of printed versions of electronic
certificates where concern was raised that although both the MSC and MEPC have agreed to the use of electronic
certificates and electronic signatures some MoUs were reported as accepting the certificates but imposing their own
conditions that were over and above the FAL Circular requirements.
It was acknowledged that this work is still under consideration at FAL and III 1 agreed to suggest to FAL that they
might like to take into account the challenges for port States whose current national legislation may limit acceptance
of printed versions of electronic certificates; and the verification by the PSCO of the authenticity of printed versions of
electronic certificates with the flag State.
The Sub-Committee encouraged port States and PSC regimes to work towards acceptance of printed versions of
electronic certificates as recommended in FAL.5/Circ.39.
Casualty analysis and statistics (agenda item 5)
III 1 considered the report of the Correspondence Group on Casualty Analysis and in particular the outcome of their
review of the Costa Concordia, Swanland and Danny F II maritime safety investigation reports.
With regard to the Danny F II (a ro-ro converted to a livestock carrier) the Sub-Committee noted that there are no
internationally accepted standards for livestock carriers or the management of the livestock trade. III 1 requested that
this issue is brought to the attention of the MSC.
Harmonisation of port state control activities (agenda item 6)
III 1 drafted guidelines for Port State Control officers related to the ISM Code. The draft MSC Circular will go to MSC
94 for onward consideration by HTW.
PSC Guidelines on seafarers hours of rest and PSC guidelines in relation to the Maritime Labour
Convention, 2006 (agenda item 7)
III 1 drafted guidelines for PSC inspections of certification of seafarers rest hours. The draft MSC Circular will go to
MSC 94 for onward consideration by HTW.
Lloyds Register Briefing Note III 1 Summary Report
July 2014

Lloyds Register Briefing Note III 1 Summary Report

July 2014

Development of guidelines on port State control under the 2004 BWM Convention (agenda item 8)
The Sub-Committee considered the report of the Correspondence Group on the Development of the Guidelines for
port State control under the BWM Convention which was established at FSI 21.
III 1 agreed on the principle of the four-tier inspection system and developed and agreed on the draft Guidelines that
will go to MEPC for approval.
Comprehensive analysis of difficulties encountered in the implementation of IMO instruments (agenda
item 9)
III 1 considered the proposal by a Member State that a unified approach concerning ships issued with multiple Load
Line Certificates should be developed for the guidance of port States and flag States and the benefit of ship owners.
The proposal was supported in principle by the as it was deemed that further consideration is needed a new
unplanned output will be submitted to the MSC.
It was also proposed that the status of exemptions should be indicated on the ILLC in a similar way to certificates
issued under other IMO Conventions such as SOLAS or MARPOL. Again, the proposal was agreed and a new
unplanned output is expected to be submitted to the MSC.
Review and update of the survey guidelines under the Harmonisation of Survey and Certification (HSSC)
and the non-exhaustive list of obligations under instruments relevant to the IMO Instruments
Implementation Code (III Code) (agenda item 10)
As part of its routine update of the HSSC survey guidelines, III 1 considered a proposal to align the survey windows
under the HSSC for cargo ship safety construction intermediate and renewal surveys for ships not subject to the ESP
Code with those for ships subject to it and consequently developed the text of draft amendments to SOLAS and the
Survey Guidelines under the HSSC. These will be sent to the correspondence group for finalisation.
Secondary Barrier Testing requirements for Gas Carriers
The Sub-Committee supported the proposed revisions to the Survey Guidelines on the secondary barrier testing
requirements for gas carriers.
Proposed amendments to the HSSC Guidelines with a view to providing clarity in the treatment of minor
deficiencies
The Sub-Committee had an in depth discussion and while the issue received some support ultimately it was
decided the proposed subheadings to paragraphs 4.8.1 and 4.8.2 of the Survey Guidelines under the HSSC would
not be appropriate as it would limit the scope of section 4.8 to detainable deficiencies. They did agree to the text
amendments to these two paragraphs as proposed but not the proposed additional paragraph 4.8.3 Minor
Deficiencies.
Consideration of IACS Unified Interpretations (agenda item 11)
The Sub-Committee considered the proposal by IACS for a Unified Interpretation on the keel laying date for fibrereinforced plastic (FRP). The UI was supported and the draft MSC.1 Circular will go to MSC 94 for approval.
Review of general cargo ship safety (agenda item 14)
The Sub-Committee considered relevant submissions on the development of port State control inspector training for
general cargo ships (RCO 20).
III 1 generally supported the information provided and encouraged the PSC regimes to promote knowledge transfer
in order to achieve the same reported level of expertise.

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