Review of IMO Sub-Committee on Implementation of IMO Instruments

InterManager provided the following briefing of the meeting, informing about the important decisions taken during the Sub-Committee. Among others and with regards to the development of new entrant training manual for PSC personnel, the Sub-Committee decided that such training manual should be developed after finalisation of IMO Model Course 3.09 on Port State Control.

Inadequacy of Port Reception Facilities

The Sub-Committee considered document III 7/3/1 (China) on difficulties with reception facilities for exhaust gas residues (EGCS) encountered by port States. In discussion, it was noted that some of the concerns and proposals in China’s document had already been addressed in the 2022 Guidance regarding the delivery of EGCS residues to port reception facilities, as well as, MEPC.1/Circ.899. The Sub-Committee encouraged Member States to submit their best management practices to future sessions of III.

The Sub-Committee also agreed to recommend to MEPC that the Secretariat be requested to undertake a review of the full functionality and inter-operability of the PRF module in GISIS, with a view to looking into the resources required to develop and implement the data transfer mechanism outlined in document MEPC 77/14 (Austria et al.).

Safety issues from analysis of marine safety investigation reports

The Correspondence Group report contained information on the analysis of 33 marine casualties and incidents listed in document III 8/4/1 (Secretariat) and outcomes were noted as follows:

• Two safety issues were identified; safety issues during PSC inspection, and safety risk related to how containers are secured on deck;
• Two further safety issues, namely man overboard from fishing vessels and pilot ladder deficiencies;
• Collisions and occupational accidents, further analysed as the types of casualties which occur more frequently than others; and,
• Progress made on the procedure for identifying safety issues.

Following plenary discussion, the Sub-Committee established the virtual Working Group (WG 1) under appropriate (extensive) terms of reference, and in consideration of the Group’s report, approved it in general, and in particular:

• Approved the findings of the CG based on the analysis of individual marine safety reports and GISIS, including changes to the text of casualty analyses;
• Will bring certain observations to the attention of Administrations, by means of an III.3 circular, with the object of improving future marine safety investigations;
• Approved draft text of lessons learned from marine casualties and their release on the IMO website;
• Invited MSC to note discussion on document III 8/4 regarding how containers should be secured at sea and direct the CG to develop a proposal for a new output aimed at preventing loss of containers at sea;
• Invited MSC to consider developing a new output on guidelines addressing identified safety issues of seafarers exposed to risk of falls from height, with the HTW Sub-Committee as the coordinating body;
• Invited the NCSR, SSE and HTW Sub-Committees to note the analysis contained in document III 8/4, Annex 3 concerning ‘Man Overboard’ from Fishing Vessels;
• Invited MSC 106 to bear in mind Annex 4 of the CG’s report when discussing the proposal for a new output to amend SOLAS regulation V/23 to improve the safety of pilot transfer arrangements;
• Agreed an updated procedure for identifying safety issues, for submission to MSC;
• Invited the marine safety investigating States to upload MSI reports of the ships involved in very serious casualties for further referral to the CG;
• Invited CCC to consider document III/4/5 in relation to the existing output in its work of revising resolution A.1050(27) for entering enclosed spaces aboard ships;
• Endorsed the Group’s recommendation regarding allocation for more resources to upgrade the functionalities of the MCI 2 module in order to enhance reporting and engage on data feeds into the new module;
• Forwarded to MSC the proposal related to HTW 8 and the guidance framework for the application of casualty cases and Lessons Learned to seafarers’ education and training;
• Invited the Secretariat to ensure a wider visibility of public casualty investigation reports so as to ease accessibility of training institutes; and,
• Re-established the CG on Analysis of Marine Safety Investigation Reports under the specified terms of reference.

Training manual for PSC personnel

Following discussion, the Sub-Committee decided that the training manual for new entrant PSC personnel should be developed after finalisation of IMO Model Course 3.09 on Port State Control.

Having considered the relevant part of DG 1’s report on Measures to Harmonise PSC Activities and Procedures Worldwide, with respect to Development of an entrant training manual for PSC personnel, the Sub-Committee duly took note.

Action plan to address marine plastic litter from ships

The Sub-Committee was advised that MEPC 73 had adopted the Action plan to address marine plastic litter from ships (resolution MEPC.310(73)) and agreed that the measures therein will be reviewed at MEPC 74, based on follow-up proposals and also approved the scope of work for the III Sub-Committee in relation to marine plastic litter from ships. It was also noted that:

• MEPC 76 approved MEPC.1/Circ.893 on Provision of adequate facilities at ports and terminals for the reception of plastic waste from ships and MEPC.1/Circ.894 on Sharing of results from research on marine litter and encouraging studies to better understand microplastics from ships;
• MEPC 77 adopted resolution MEPC.341(77) on Strategy to address marine plastic litter from ships; and, noted the updated status of each action contained in the Action Plan and encouraged submissions to future sessions regarding those actions which require proposals to progress the work as set out in MEPC 77/WP.9;
• PPR 9 invited interested Member States and international organisations to submit documents with best practices related to response to, and the clean-up of, plastic pellets transported by ship to a future session; and, established the CG on Marine Plastic Litter from ships to develop draft amendments to the 2017 Guidelines for the implementation of MARPOL Annex V to support implementation of the contemplated amendments being developed to enhance the reporting of lost fishing gear;
• MEPC 78 had agreed that a goal-based requirement under MARPOL Annex V for the mandatory marking of fishing gear should be developed by the PPR Sub-Committee.

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