Overall situation

The 10th meeting of the Integrated Compliance Subcommittee (III) of the International Maritime Organization (IMO) was held in London, UK, chaired by Mr. Regi John (UK), Vice Chairman of Subcommittee III. This meeting has a total of 18 agenda items. In addition to the plenary session, the conference also established three working groups and one drafting group, including:

Analysis Working Group for Maritime Safety Investigation Report

Measures to coordinate global Port State Control (PSC) activities and procedures, as well as PSC demonstration training course working groups

✿ Working Group for the Development of Inspection and Certification Coordination System (HSSC) Inspection Guidelines, Non exhaustive Obligation List, Remote Inspection, Audit and Verification Guidelines, and Implementation Guidelines for the Cape Town Agreement

Drafting Group for Comprehensive Audit Summary Report Analysis (CASRs)

Key topics for discussion

（1） Deliberation and Analysis of the Report on the Shortage of Port Reception Facilities (PRFs) (Issue 3)

The meeting reviewed the report on the use of port reception facilities in 2022 and 2023 (III 10/3), with a total of 68 cases reflecting insufficient port reception facilities. Compared with 2022, member states have taken positive actions, reduced the number of defects, and increased the number and response rate of port states. At the same time, parties to the MARPOL Convention are urged to report or update data through the PRF module under the Global Integrated Shipping Information System (GISIS). The meeting requested the improvement of the evaluation method for the insufficient PRFs in the report, clarifying the responsibilities of all parties, and forming a more prominent method in GISIS to display the port state information that has not been feedback.

（2） Lessons learned and safety requirements from analyzing maritime investigation reports (Topic 4)

1. Analysis of Maritime Safety Investigation Report and Communication Team Report

The meeting reviewed the analysis of 37 maritime investigation reports on 36 accidents and agreed to publish them on the Maritime Accident Investigation Module (MCI) under GISIS. The 34 lessons learned were also agreed to be published on the IMO website. Adopt the suggestion to continue improving the Maritime Accident Investigation (MCI) function of GISIS. Encourage flag states to improve the quality of ISM audits based on common issues identified in the analysis of lessons learned.

2. Analysis of Maritime Safety Investigation Report and GISIS Upgrade

The meeting reviewed the latest upgrade work and progress made on the GISIS accident database (III 10/4/2). Agree to identify safety issues from casualty data analysis reports and research, support the adoption of data-driven methods in IMO decision-making and policy-making processes, and submit this recommendation for review by MSC 109. In addition, a comprehensive review of GISIS is expected to begin in September 2024.

3. Suggestions on preventing collisions between fishing boats

The meeting deliberated on the proposal to expand the requirements for domestic fishing fleets to carry Automatic Identification Systems (AIS) and Very High Frequency (VHF) by the administrative departments of member states. Agree to submit the draft MSC. 1 circular letter on "Recommendations to Governments on Preventing Collisions between Fishing Vessels" to MSC 109 for review and approval.

4. Safety issues identified through analysis of investigation reports on maritime accidents related to the use of fumigants

The meeting reviewed the proposal (III 10/4/4) on "Safety issues identified from the analysis of investigation reports on 5 maritime accidents related to the use of fumigants", and decided to invite the CCC subcommittee to further review the document information and relevant discussion suggestions when promoting the safe use of fumigation insecticides in ship cargo holds.

（3） Measures to Coordinate Global Port State Control (PSC) Activities and Procedures (Issue 5)

The meeting reviewed the proposals related to the 2023 PSC Procedure (Resolution A.1185 (33)), and the subcommittee fully considered the opinions of all parties and approved the revised drafts of Appendices 2, 8, 9, 11, and 18 of the 2023 PSC Procedure, agreeing to further develop the draft PSC Guidelines. The revised draft of the 2023 PSC Procedure and PSC Guidelines will be submitted for review and approval in III 11, and submitted for review and approval in A 34.

1. Coordinate global PSC activities and program communication group reports

The meeting reviewed the report of the Communications Group (III 10/5), which reported on the main work of the past year, including a comprehensive review of the 2023 PSC Procedure and the Interim Guidelines for Strengthening Control and Compliance Measures for Maritime Security (Resolution MSC. 159 (78)). Agree to develop the PSC Guidelines in accordance with Appendix 8 of the 2023 PSC Procedure and further refine the draft guidelines, which are applicable to ships under Chapter XI-2 of the SOLAS Convention and Part A of the ISPS Code.

The meeting reviewed the revision proposal regarding the detention of ships in the appendix of the 2023 PSC Procedure and agreed to adjust the content on detention defects in the appendix to Appendix 2 as the sole basis for the detention defects of ships in the PSC Procedure. Agree to add a new chapter in Appendix 18 regarding the requirement of 'inability to obtain fuel conformity declaration'. The meeting also discussed the issue of vessel detention defects caused by the lack of daily rest time records (STCW Code A-VIII/1.7), and suggested that the HTW subcommittee consider that the application of Article X and Annex I/4 of the STCW Convention may bring problems and further clarify the applicability of relevant provisions.

2. Global PSC Inspection Data Cooperation

The meeting reviewed the Secretariat's document (III 10/5/3), which provided a revised draft of the IMO Model Agreement on data cooperation. It was found that the content of the revised Model Agreement is generally acceptable, but given that the ownership of PSC data belongs to the authorities of each member country, it should ultimately be decided by the authorities of PSC member countries. Additionally, attention should be paid to the uniqueness of PSC mechanisms in different regions, and there should be some flexibility in the content of the agreement.

3. Reports and information from the Secretariat and PSC memoranda

The meeting reviewed the 2023 annual reports submitted by 9 regional PSC memorandum organizations and the United States Coast Guard, the results of the Central Inspection (CIC), and information related to recent PSC activities. As well as the inspection data and performance of flag states and accredited organizations provided by the Paris Memorandum, Tokyo Memorandum, Mediterranean Memorandum, and the United States Coast Guard, we request that PSC memorandum organizations continue to provide relevant information to assist flag states in selecting accredited organizations with excellent performance.

（4） Revision of PSC Demonstration Course 3.09 (Topic 6)

The meeting reviewed the revised draft of "Model Course 3.09 on Port State Control". There are no further opinions on the structural framework of the demonstration course, and it is agreed to add the content of the Maritime Labour Convention to the demonstration course. Considering that some course content needs to be negotiated with the International Labour Organization (ILO) and the comments submitted in the Paris Memorandum at the meeting need further processing, the meeting agrees to postpone the matter. At the same time, we will adhere to the principle of "quality first" and restart the review in accordance with the "Guidelines for the Development, Review, and Validation of Demonstration Courses (MSC-MEPC. 2/Circ. 15/Rev. 2)", expand the membership of the review group, comprehensively and extensively solicit relevant revision opinions to optimize and improve the content of the demonstration course revision. At the same time, we will develop a roadmap for submitting the demonstration course, and plan to submit the final revised draft of the demonstration course to the Secretariat for discussion at the next meeting before December 6, 2024.

In addition, considering that once the demonstration training courses come into effect, the Hong Kong Convention and the Polar Rules should also be included.

（5） Identify and implement issues related to IMO documents from data analysis (Topic 7)

In January 2023, IMO launched an IT project aimed at enhancing data analysis to support IMO's policy-making and decision-making. The project includes six modules of GISIS: Maritime Casualties and Accidents (MCI), Port State Control (PSC), Member State Audit (MSA), Fuel Consumption Database, Port Reception Facilities (PRFs), and Global Maritime Distress and Safety System (GMDSS).

The meeting encourages member states to enhance their ability to fulfill their obligations by regularly updating the data of the GISIS module and providing feedback to improve the utilization rate of GISIS. At the same time, considering that data is an important foundation for conducting analysis, member states are urged to improve the quality of GISIS reports and ensure the completeness and accuracy of data.

The subcommittee invites member states, international organizations, and the Secretariat to continue submitting more data analysis on this topic to help IMO better formulate policies within its work framework.

（6） Analysis of the Comprehensive Review Summary Report (Topic 8)

The meeting approved the Comprehensive Audit Summary Analysis Reports (CASRs), which contain lessons learned from 82 audits conducted under the International Maritime Organization Member State Audit Scheme (IMSAS) between 2016 and 2022. The sub committee requests the relevant committees and sub committees to pay attention to the four main reasons why member states have failed to effectively implement mandatory IMO instruments, and initiate a review and review of the applicability and effectiveness of SOLAS V/7.3, VII/3, and STCW VIII/2 provisions, and report to MSC.

The meeting reviewed the Secretariat's document (III 10/7) on the work carried out in identifying discretionary clauses in mandatory instruments of the International Maritime Organization that satisfy or are similar to those of the competent authority. It was agreed to establish a long-term working mechanism to identify clauses that satisfy or are similar to those of the competent authority through a mutually agreed method, and to establish and maintain a comprehensive list of clauses that satisfy the competent authority. At the same time, the subcommittee invites interested member states and international organizations to provide suggestions on methods and mechanisms for compiling and maintaining lists, in order to formulate and implement guidelines related to the use of "satisfactory to the competent authority" or similar expressions.

（7） Review and Update HSSC Inspection Guidelines (Topic 9)

1. Communication Group Report

The meeting reviewed the report of the Communication Group (III10/9) and approved the footnote analysis, GAP gap analysis, revision suggestions for inspection items of SOLAS II-1/3-8 towing and mooring equipment in the "2023 HSSC Inspection Guidelines" (Resolution A.1186 (33)) conducted by the Communication Group, as well as the revised draft of the "2023 HSSC Inspection Guidelines" completed based on mandatory documents by December 31, 2025, and agreed to merge all revised content and submit it to A34 for review and approval in a comprehensive version. And it was decided to establish a communication team to continue GAP analysis, develop "IP Code" inspection items, identify remote inspection items, determine the scope of various convention inspection certificates and records, and continue to revise the "2023 HSSC Inspection Guidelines" based on the latest achievements of MSC and MEPC.

2. Suggestions for revising Part II of the Ship Energy Efficiency Management Plan (SEEMP) in accordance with the confirmation letter format

The meeting reviewed the proposal (III10/9/2) regarding the revision of Part II of the Ship Energy Efficiency Management Plan (SEEMP) in accordance with the Confirmation Form (MEPC. 1/Circ. 876), and agreed to submit this document, along with the communication group's recommendations, to MEPC for further review.

（8） Deliberation on the Non exhaustive Obligation List of IMO Mandatory Documents Related to Rule III (Issue 10)

Due to time constraints, the meeting was unable to review the revised draft of the Non exhaustive List of Obligations for 2023 (Resolution A.1187 (33)) and the identification lists in documents III 10/9 (Attachment 7) and III 10/INF.3. The review has been postponed to the next meeting (III 11). And it was decided to establish a communication group to continue revising the "2023 Non exhaustive Obligation List" based on the latest achievements of MSC and MEPC.

（9） Deliberation on the Development of Guidelines for Remote Inspection, ISM Code Review, and ISPS Code Validation (Topic 11)

The meeting reviewed the draft guidelines Part A and Part B, Parts I and II, determined the wording of the guidelines' names, and removed the content in Part A regarding the elimination of PSC defects. Agree to add temporary audits to the restrictions of Part B-II, and clarify that except for the DOC temporary audits of newly added ship types that can be conducted remotely, other DOC temporary audits should be conducted on-site. The meeting considered the communication group's suggestion to pay attention to network security and sensitive issues in ISPS remote verification, and agreed that remote verification should only be used in extreme situations. Decided to establish an inter meeting communication group to review the relevant chapters on RIT in the draft guidelines and develop requirements for the application of RIT. Based on the results of this conference, the communication team will develop a joint MSC-MEPC communication letter and revise the draft guidelines for HSSC Inspection Guidelines, ISM Implementation Guidelines, as well as remote inspection, ISM audit, and ISPS verification guidelines in accordance with the roadmap determined in III 8.

The meeting decided that China will continue to serve as the coordinator of the inter meeting communication group for the HSSC Inspection Guidelines, Non exhaustive Obligation List, and Remote Inspection, Audit, and Verification Guidelines.

（10） Develop guidelines to assist regulatory authorities in implementing the 2012 Cape Town Agreement (Issue 14)

The meeting reviewed the legal opinions provided by the Communication Group report (III 10/14) and the Secretariat document (III 10/14/1) on the scope of application of the Cape Town Agreement to existing ships. Agree to submit the scope of application of existing vessels to MSC for further review, agree to delete the parts that are not applicable, such as illegal, unreported, and unregulated (IUCN) fishing and remote inspections, agree to change the name of the draft guidelines for assisting competent authorities in implementing the 2012 Cape Town Agreement to temporary transitional guidelines, and plan to submit them for review at the 109th session of MSC.

（11） Other

The sub committee evaluated the workload, analyzed the ongoing and annual outputs within the scope of responsibilities, made suggestions on whether each output should be included in the annual agenda, and also proposed modification suggestions for the sub committee's responsibilities. At the same time, it is recommended to flexibly arrange the working group for analyzing the maritime safety investigation report, and convene it in the form of an inter meeting working group one week before or immediately after the meeting.

1. Suggestions on the Fifth Meeting of the FAO/ILO/IMO Joint Working Group

The meeting reviewed relevant documents, and the subcommittee suggested that a cautious approach should be taken when considering the implementation of PMSA (Port State Measures Agreement) and cooperation or coordination with fisheries departments to maintain the distinction between PSC inspections and PSMA inspections for high seas fishing, in order to ensure that the safety of fishing vessels is not affected. And call on member states that have not yet joined the 2012 Cape Town Agreement, 1995 STCW-F, and 2007 ILO C.188 to take necessary measures to promote the early entry into force of the 2012 Cape Town Agreement.

2. Suggestions on Updating the Appendix of the ISM Code and the Implementation Guidelines of the ISM Code

The meeting reviewed relevant documents, and the subcommittee suggested that interested member states and international organizations continue to submit proposal documents.

3. Election of Chairman of Subcommittee III

Comrade Xie Hui of the Chinese delegation has been successfully elected as the Chairman of Subcommittee III for 2025.

Remind the industry of precautions

1. Maritime accident investigation

Pay attention to the maritime accident investigation and analysis report and 34 lessons learned published on the IMO website, mainly involving collisions, grounding, fires, explosions, electric shocks, enclosed spaces, personnel falling into water, high-altitude falls, etc.

2. PSC inspection

Pay attention to the revisions regarding the detention of ships in Appendix 2, 8, 9, 11, and 18 of the 2023 PSC Procedure, as well as the addition of a new chapter in Appendix 18 regarding the requirement of "inability to obtain a fuel conformity declaration", and the relevant content of the further developed draft PSC Guidelines.

3. Preventing collisions between fishing boats

Pay attention to the review and approval status of MSC 109's draft MSC. 1 circular letter on "Recommendations to Governments on Preventing Collisions between Fishing Vessels".

4. Newly revised HSSC Inspection Guidelines and Remote Inspection, ISM Audit, and ISPS Validation Guidelines

Pay attention to the newly revised content of the '2023 HSSC Inspection Guidelines' approved at this meeting.

Note the joint MSC-MEPC circular on the development of guidelines for remote inspection, ISM audit, and ISPS verification, as well as the discussion on the draft guidelines for remote inspection, ISM audit, and ISPS verification at this meeting.

5. Guidelines for Implementing the 2012 Cape Town Agreement

Pay attention to the review and approval status of MSC 109 on the draft implementation guidelines for assisting regulatory authorities in fulfilling the 2012 Cape Town Agreement.