The 10th meeting of the International Maritime Organization (IMO) Sub-Committee for the Implementation of IMO Regulations (III 10) was held from 22 to 26 July 2024. The Sub-Committee continued its work on remote inspection, ISM audit and ISPS verification. The Sub-Committee also considered the maritime safety investigation report and continued to revise the inspection guidelines and port State control procedures under the Harmonized System of Inspection and Certification.

Owners and managers, port state control and flag state related content

Conference focus

• Review lessons learned from incident reports

• Continue to develop guidance on remote inspection, ISM rule review, and ISPS verification

• Continue to revise the inspection guidelines under the Harmonized Inspection and Certification System (HSSC)

• Continued revision of Port State control (PSC) procedures

Remote inspection, ISM audit and ISPS verification

III 10 Continue to develop guidelines for the application of remote inspection and International Security Management (ISM) rules in general. The inspection guidelines will be incorporated into the inspection guidelines under the Harmonized Inspection and Certification System (HSSC), while the remote ISM Rule review guidelines will be incorporated into the ISM Rule Compliance Management Guidelines.

It was agreed that in addition to the interim audit when adding a new ship type to an existing DOC, the interim, initial, renewal and additional ISM rules company audit should be conducted on-site. The draft guidance recommends that remote annual reviews be opened up.

Given the sensitivity of the data, International Ship and Port Facility Security (ISPS) verification should be carried out on-site. Therefore, remote ISPS verification is only possible in exceptional circumstances.

The Conference established a communications group reporting to the III-11 Conference in 2025 to continue dealing with these matters.

Lessons learned from the analysis of maritime Safety investigation reports as well as safety issues

Iii.10 The work done to prevent fishing vessel collisions was considered. Of the countries involved in this effort, 50% require fishing vessels to be equipped with AIS, while more than 70% require VHF. However, less than 20% of the vessels involved in a collision were equipped with a functioning AIS or VHF at the time of the collision. Accordingly, the parties agreed to issue a draft MSC.1 circular, which recommends that national authorities expand the requirements for their domestic fishing fleets to be equipped with AIS and VHF to prevent collisions. The draft circular will be submitted to MSC 109 for approval in December 2024.

Iii.10 A draft text containing 34 examples of lessons learned from maritime incidents was considered and approved. The relevant text will be posted on IMO's website.

Iii.10 reviewed five recent incidents related to fumigation on board ships and recommended that the three MSC.1 circulars dealing with this issue be combined into one MSC.1 circular for effective implementation of the recommendations on the use of pesticides.

Measures to harmonize Port State control (PSC) activities and procedures

Ii.10 Considered and agreed to the amendments to the Port State Control Procedure 2023 (resolution A.1185(33)).

The retention deficiencies specified in Appendices 8 (ISM Rules), 9 (LRIT), 11 (Seafarers' certification, manning and rest periods) and 18 (MARPOL Annex VI) have been moved to Appendix 2 in order to consolidate the retention deficiencies under the different conventions in one place.

The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) and the Maritime Labour Convention (MLC) differ in terms of rest time provisions, including different requirements for when detention can be initiated. However, as most PSC Mous have developed PSC defect codes for work and rest periods, it has been concluded that there is no need to update the procedure at this time.

The interim review of the Guidance on Control and Compliance Measures to enhance maritime Safety (resolution MSC.159(78)) was completed. The parties decided to incorporate the circular into the process, which is expected to be completed at III-11 in 2025.

The pending changes to the procedure will be continued by the Communications Group and the next version will be adopted by the 34th General Conference in December 2025.

Inspection guidelines under the Harmonized Inspection and Certification System (HSSC) have been updated

III 10 Continue to update the inspection guidelines under the Harmonized Inspection and Certification System (HSSC). The Communications Group will continue to revise the inspection guidance relating to inspection items related to the International Code for the Safety of Vessels for Persons in the Carrying Industry (IP Code), as well as other updates resulting from amendments to the relevant mandatory instruments that took effect on or before 31 December 2025.

The revised guidelines are expected to be adopted by the 34th General Assembly in December 2025 and enter into force on January 1, 2026.

Other topics

Guide to the implementation of the Cape Town Agreement

The Cape Town Agreement (CTA) sets out minimum requirements for the design, construction, equipment, inspection and certification of fishing vessels of 24 metres or more in length or equivalent gross tonnage. The agreement has been ratified by 22 countries with a combined fleet of about 2,600 vessels. The number of countries is sufficient, but the total number of fishing vessels needs to reach 3,600. The guidance is intended to support the implementation of the CTA. Iii.10 The interim guidance was completed and MSC 109 will consider the guidance and adopt it as an MSC resolution in December 2024.

For existing fishing vessels, III-10 agrees that the implementation guidelines should address only the technical requirements of the CTA. MSC 109 deals with the applicability of Chapter I of the CTA. In addition, the parties agreed that Member States should develop measures to ensure that existing fishing vessels' compliance with the relevant parts of the CTA is documented.

In addition, III.10 also agreed that references to areas outside the IMO's jurisdiction, including illegal, unreported and unregulated (IUU) fishing and the Port State Measures Agreement (PSMA), should be removed from the implementation guidelines.

Review and analyze port Reception Facility (PRF) deficiency reports

Authorities are required to report inadequate PRF to IMO's Global Integrated Shipping Information System (GISIS), and port authorities are expected to respond. Action has been taken and progress has been made, with a reduction in underreporting and an improvement in port state response rates.

Suggestion

DNV advises customers to take note of lessons learned from incident investigation reports and work on remote inspection, audit and verification.

As III is a sub-committee, all decisions on rules, regulations and dates are subject to further consideration and approval by the Maritime Safety Committee (MSC), the Marine Environment Protection Committee (MEPC) or the General Assembly.

The Port State Control (PSC) Intensive Inspection Activity (CIC) will run from September 1, 2024 to November 30, 2024, focusing on "Crew wages and seafarers' employment agreements under the MLC." To help you prepare, we recommend that you attend the upcoming global webinar on August 20, which will focus on the questionnaire released by the Paris and Tokyo memorandums of Understanding in early August.