BIMCO provides an overview of the IMO Sub-committee on Implementation of IMO Instruments (III) 10th session to be held from 22 to 26 July 2024.
The meeting agenda includes several key items, such as inadequacy of port reception facilities, analysis of marine casualties and incidents investigation reports, and guidance on remote surveys. This article highlights some of the significant and relevant issues for BIMCO and its Members.
The Sub-committee on the Implementation of IMO Instruments (III) focuses on the effective and consistent global implementation and enforcement of IMO instruments related to maritime safety, security, and environmental protection.
The agenda for III 10, scheduled from 22 to 26 July 2024, encompasses a range of topics. The following are key items of interest to BIMCO and its Members:
Port Reception Facilities (PRFs)
A major topic will be PRFs. Data presented to the Sub-committee indicates improvements in PRF availability, with a decrease in reported cases and an increase in the response rate by port states.
However, challenges remain, particularly regarding the discharge of garbage ashore, which creates issues for ships with limited garbage storage capacity, BIMCO notes. The accumulation of excessive garbage onboard forces seafarers to store it in non-designated areas, increasing risks to seafarers and the environment and raising the likelihood of deficiencies, fines, or detentions by port state control authorities.
Additionally, there is a concern that reported information may not fully reflect reality, as not all instances of inadequate port reception facilities are reported to flag states. Awareness of reporting obligations is often limited in many ports.
Considering these factors, BIMCO will support all proposed actions aimed at assessing port states’ responses and enhancing reporting by ships, companies, and ports.
Accident investigations and lessons learned
During III sessions, accident reports are regularly reviewed for knowledge sharing and safety improvements. A significant outcome from the analysis submitted by InterManager to III 10 is the continued under-reporting of accidents. BIMCO advocates for timely, consistent reporting and thorough investigations of all accidents to enhance safety measures and prevent recurrence.
Furthermore, an interesting discussion is anticipated regarding concerns raised by Panama about onboard safety measures for various operations. Panama’s submission seeks a holistic approach, linking incidents and accidents to vessel managers, operators, and recognized organizations, and identifying areas for improvement such as maintenance plans, crew familiarization and training, and audit quality.
China has also submitted a document addressing the lack of mandatory requirements for fumigation onboard ships and associated risk mitigation. BIMCO shares the concern about insufficient attention to fumigation onboard and will monitor developments closely.
Updated survey guidelines under HSSC / Guidance on Remote Surveys
Work continues on updating HSSC survey guidelines and guidance for remote surveys. Significant developments include guidance on remote surveys, ISM Code audits, and ISPS Code verifications, including eligibility criteria, the use of remote technology, and the agreement of flag and port states on remote survey acceptance concerning PSC deficiencies. BIMCO will closely follow these developments.
Other considerations
China has raised the issue that shipping companies holding a Document of Compliance (DoC) for “other cargo ships” might manage various types of ships with differing technical, operational, and management requirements. China proposes revising the DoC forms in the ISM Code appendix and requiring additional verification when new ship types are added under “other cargo ship.”
As informed, BIMCO supports in principle the need to explicitly specify ship types under the “other cargo ship” category but suggests considering amendments to SOLAS Chapter IX and relevant IMO instruments to distinguish the ship types currently categorized as “other cargo ship.” BIMCO believes that the ISM Code adequately regulates the addition of new ship types and disagrees with the need for additional verification.
