Sub-Committee on Implementation of IMO Instruments (III 8), 25-29 July 2022

Updating draft resolutions to support implementation  

The Sub-Committee, which reports to the Maritime Safety Committee (MSC) and the Marine Environment Protection Committee (MEPC), progressed the updating of three key IMO Assembly resolutions  on implementation: the Survey Guidelines under the Harmonized System of Survey and Certification; the Non-exhaustive list of obligations under instruments relevant to the IMO instruments implementation Code (III Code); and the Procedures for port State control (PSC). These will ultimately be forwarded for adoption by the IMO Assembly at its thirty-third session in late 2023 after approval by the Committees. 

Development of guidance on assessments and applications of remote surveys  

The Sub-Committee progressed its work on development of guidance on assessments and applications of remote surveys, the International Safety Management (ISM) Code audits and ISPS Code verifications, in particular with an agreement on a roadmap and methodology on the way forward. 

Given the urgent demand for guidance on remote surveys and ISM Code audits, the Sub-Committee agreed, in its roadmap, that amendments to Survey Guidelines under the HSSC and amendments to the Revised Guidelines on the implementation of the International Safety Management (ISM) Code, containing remote surveys and ISM audits, should be finalized next year at III 9, with a view to adoption at A 33 in 2023, subject to agreement of the Committees. 

In addition to the above, it was agreed to task a correspondence group with the agreed methodology to proceed on the basis of one document containing principles and common areas (part 3-0) and three guidance: Guidance on assessments and applications of remote surveys (part 3-1); Guidance on assessments and applications of remote ISM Code audits (part 3-2); and Guidance on assessments and applications of remote ISPS Code verifications (part 3-3). 

Procedures for PSC on the short-term GHG reduction measures 

The Sub-Committee discussed specific PSC issues related to the implementation of the short-term GHG reduction measures, set to enter into force on 1 November 2022.   

 Under the short-term measure, ships are required to calculate their Energy Efficiency Existing Ship Index (EEXI) following technical means to improve their energy efficiency and to establish their annual operational carbon intensity indicator (CII) and associated CII rating. Carbon intensity links the GHG emissions to the amount of cargo carried over distance travelled. 

Ships will get a rating of their energy efficiency (A, B, C, D, E - where A is the best). Administrations, port authorities and other stakeholders as appropriate, are encouraged to provide incentives to ships rated as A or B also sending out a strong signal to the market and financial sector. 

 A ship rated ‘D’ for three consecutive years, or ‘E’, is required to submit a corrective action plan, to show how the required index (C or above) would be achieved. 

 A Correspondence Group has been tasked with incorporating the various amendments supporting the enforcement of the short-term GHG reduction measure into the PSC procedures. Regardless, following extensive consideration, the Sub-Committee agreed that at this stage there was no support within the Sub-Committee for the proposed amendment to regard as a detainable deficiency the absence of implementation by the ship as planned at the time of the inspection of the three-year implementation plan and/or the plan of corrective actions for a ship rated as D for three consecutive years, or rated as E. The Sub-Committee agreed to advise the Marine Environment Protection Committee (MEPC 79) accordingly. 

Lessons learned 

The Sub-Committee agreed the lessons learned from marine casualties and incidents, for release on the IMO website.  https://www.imo.org/en/OurWork/IIIS/Pages/Lessons-Learned.aspx. 

Data collection and analysis to improve implementation 

 Having noted the existence of comprehensive sets of data already available in various GISIS modules, such as, and not limited to, Member State Audit, Marine Casualty Investigation, Port Reception Facilities and Port State Control, which may provide a good basis for identifying issues in implementation,  the Sub-Committee agreed to rename the output as ʺIdentified issues relating to the implementation of IMO instruments from the analysis of dataʺ with extension of scope of output subject to endorsement by the Committees. 

Harmonizing port State control (PSC) 

The Sub-Committee noted with appreciation reports from the regional port State control (PSC) regimes and the United States, on PSC activities, Concentrated Inspection Campaign (CIC), inspection rates and detentions, and invited them to continue submitting annual reports.