I. Overview of the meeting

The 109th session of the Maritime Safety Committee of the International Maritime Organization (IMO) will be held from 2 to 6 December 2024 in a combination of online and offline format. The meeting was chaired by Ms. Mayte Medina from the United States and was attended by representatives of Member States, representatives of United Nations programmes, specialized agencies and other bodies, and observers from intergovernmental and non-governmental organizations.

The meeting established three working groups, one drafting group and one expert group to work in parallel with the Plenary, including the MASS Working Group, the GHG Safety Working Group, the Workload Working Group, the Drafting Group for Amendments to Mandatory Instruments and the FSA Expert Group.

After five days of deliberation, the Conference adopted seven resolutions and 24 circulars, as detailed in Annexes 1 and 2.

Ii. Agenda of the meeting

A total of 20 topics will be discussed at this meeting, which are as follows:

1. Adoption of the agenda of the meeting;

2. Decisions of other bodies of the International Maritime Organization;

3. Amendments to mandatory instruments;

4. Overview of target-based standards for new ship construction;

5. Develop a goal-based instrument on Autonomous Surface Vessels at Sea (MASS);

6. Safety regulatory framework for greenhouse gas emission reduction from ships;

7. Revision of the Maritime Cyber Risk Management Guide (MSC-FAL.1/Circ.3/Rev.2) and identification of next steps to strengthen maritime networks;

8. Strengthening maritime safety measures;

9. Piracy and armed robbery against ships;

10. Unsafe mixed migration at sea;

11. Comprehensive security assessment;

12. Ship systems and equipment (SSE10 report);

13. Navigation, communications and search and rescue (NCSR11 report);

14. Transport of goods and containers (urgent matters for CCC10);

15. Implementation of IMO instruments (III10 report);

16. Pollution prevention and response (PPR11 report);

17. Safety of internal transit;

18. Application of the working methods of the Committee;

19. Work plan;

20. Election of the President and Vice-Presidents for 2025;

21. Other matters;

22. Consideration of the report of the conference on MSC109.

Three main contents

1. Amendments to Mandatory Instruments (Item 3)

# 01 Amendments to the IGC Rules

The Meeting considered and adopted an amendment to Chapter 16 of the IGC Rules (Section 16.9.2) to allow the use of ammonia as fuel on liquid ammonia carriers, which will enter into force on 1 July 2026. In addition, the meeting adopted an MSC circular encouraging voluntary early implementation of Chapter 16 of the revised IGC Rules.

# 02 Amendments to the IGF Rules

The meeting considered and adopted amendments to the IGF Rules, which will enter into force on January 1, 2028. The amendments, which are based on the IGF Code's experience since it came into force in 2017, include requirements for common piping design, bunker suction Wells, boundary-oriented fire protection of the bunker, safety functions of the gas supply system, hazardous zone demarcations, and ventilation.

2. Development of a goal-based Instrument on Autonomous Surface Vessels at Sea (MASS) (Agenda item 5)

The MASS Working Group was established to continue the drafting of the draft non-mandatory MASS rules, and the roadmap for MASS rule-making was updated.

# 01 Progress on the draft non-mandatory MASS rules

After discussion, the Working Group finalized the provisions of Chapter 7 (Risk assessment), Chapter 12 (Connectivity) and Chapter 18 (Remote control) of the draft non-mandatory MASS Rules, and began discussions on chapter 8 (Operating environment), Chapter 23 (Search and rescue) and Chapter 28 (Emergency response), but was unable to finalize them.

With regard to Chapter 8 (Operating environment), the Working Group considered our proposal document MSC 109/5/5 and agreed in principle on the value of the ConOps (Operational Concepts) framework proposed in the proposal to help users better understand the concept, but there is still more work to be done. It was decided that the next step would be for my country to take the lead, with the participation of interested delegations to refine it and submit proposals at the next session with a view to finalizing the ConOps framework, to be annexed to the MASS Rules.

With regard to Chapter 12 (Connectivity), the Working Group discussed the difference between that chapter and the "Communications" chapter, agreed that the scope of the connectivity chapter should cover only ships and remote operations centers (ROC), and adjusted that chapter to Part 3 of the MASS Rules.

With regard to chapter 23 (Search and Rescue), the Working Group considers that MASS, like traditional ships, should be obliged to conduct search and rescue; MASS shall provide assistance or rescue in accordance with its ability; This chapter shall contain provisions concerning the ship and its equipment, arrangements and procedures, and may also contain the duties and duties of the master.

For Chapter 28 (Emergency response), it was decided that Chapter 28 (Emergency response) would not be retained, and the relevant requirements would be integrated into Chapter 8 (Operating environment), Chapter 11 (Safe Operations Management), etc.

The reintroduction of the term "equivalent" was also discussed, but no agreement was reached and it was decided that it would be considered again in the experience building phase after the adoption of the non-mandatory MASS rules.

# 02 Updated goal-based MASS rulemaking roadmap

The meeting updated the MASS rulemaking roadmap based on the current progress of discussions, including:

Postpone the finalization and adoption of the draft non-mandatory MASS Rules to MSC 111 (May 2026);

(2) Invite the relevant sub-committees to review the non-mandatory MASS Rules after the draft rules have been finalized and adopted;

(3) MSC 112 (December 2026) will develop a framework for the experience building period for the implementation of non-mandatory MASS rules;

(4) The formulation of mandatory MASS rules will begin in 2028, and the mandatory rules will be adopted by July 2030 at the latest and enter into force on January 1, 2032.

3. Safety Regulatory Framework for greenhouse gas emission reduction from Ships (Agenda item 6)

The meeting established a working group to further update the list of alternative fuels and new technologies that support the reduction of greenhouse gas emissions from ships.

# 01 Additional information on alternative fuels

At this stage, updating the list of alternative fuels and new technologies focuses on gathering as much information as possible for each entry. The meeting considered the IACS proposal and agreed to add a table describing the physical properties of the fuel to the list for each alternative fuel.

# 02 Replaceable power lithium battery container energy storage cabinet

The meeting considered China's proposal on the regulatory gap analysis of replaceable power lithium battery container energy storage cabinets and its application prospects, and recognized the potential of lithium battery energy storage cabinets as a technology to reduce carbon emissions in shipping. Agreed to include "replaceable power lithium battery container storage tank" in the list of alternative fuels and new technologies currently being developed.

# 03SOLAS, IGF rules and low flash point fuels

The meeting considered a UK proposal to clarify how the IGF rules apply to gaseous fuels. Currently, the IGF rules apply to low-flash point fuels as defined in Article II-1/2.29 of the SOLAS Convention. Since there is no flammable vapor present during the phase transition of ammonia from liquid to gas, it needs to be clarified whether ammonia is within the scope of the IGF rules. At the meeting, it was confirmed that the draft Interim Guidelines for the Use of Ammonia as Fuel in Ships developed by the CCC Sub-Committee would apply to anhydrous ammonia, whether in liquefied or gaseous form. In response, the Working Group was instructed to prepare draft amendments to SOLAS Article II-1/2.29, including amendments to Articles 2 (definition), 56 (scope of application) and 57 (requirements for vessels using low flash point fuels) to clarify the application of the IGF rules to gaseous fuels. The draft amendment was approved by this meeting with a view to adoption at the MSC110 meeting in June 2025 and is expected to enter into force in 2027.

4. Revision of the Maritime Cyber Risk Management Guide (MSC-FAL.1/ CIRC.3/REV.2) and identification of next steps to enhance maritime cyber security (agenda item 7)

MSC 108 approved a revised draft of the Maritime Cyber Risk Management Guide (MSC-FAL.1/Circ.3/Rev.3) and agreed to submit it to the Committee on Facilitation of Transport (FAL) for simultaneous approval.

The meeting reviewed the document on cyber incident response planning, decided not to include references to the EU and UK guidelines in the revised guidance, and encouraged Member States and international organizations to provide relevant references to the IMO Secretariat to update the content on the IMO Public website.

Measures to strengthen maritime cyber security are needed to protect commercial ships and port facility operations from rising cyber threats and risks. The need for a working group with a wide range of cybersecurity experts to develop a cybersecurity framework and implementation roadmap was highlighted, with discussions planned for the development of cybersecurity standards for ships and port facilities at the MSC 110 meeting. In addition, the Commission invited member States and international organizations to submit proposals to strengthen maritime cybersecurity and decided to extend the target completion year for this output to 2026.

5. Integrated Security Assessment (item 11)

The meeting established an FSA expert group and completed the drafting of the draft amendments to the FSA Guidelines (MSC-MEPC.2/Circ.12/Rev.2) and the related draft MSC Circular. The meeting approved the FSA Panel report in general and approved the revised Integrated Security Assessment Guidelines (FSA Guidelines) (MSC-MEPC.2/Circ.12/Rev.3), which will be submitted to MEPC 83 for simultaneous approval.

6. Marine Systems and Equipment (SSE 10 Report) (Item 12)

The meeting considered and generally approved the SSE 10 report, including the following:

1. Approve the amendments to paragraph 8.3.5 (Personal life-saving Equipment) and Annex 1 (Equipment records) of the International High Speed Craft Safety Code 1994 (HSC Code 1994) and the International High Speed Craft Safety Code 2000 (HSC Code 2000). The above draft amendments will be adopted in MSC 110 and are expected to enter into force on January 1, 2028.

2. Approves the uniform interpretation of SOLAS resolutions III/20.8.4, 20.11 and MSC.402(96), clarifying that SOLAS Resolutions III/20.11 and MSC.402(96) also apply to inflatable lifeboats.

3. Approves uniform interpretation of SOLAS Chapter II-2 and IBC Rules regarding cargo steam piping and cargo tank degassing piping requirements for liquid cargo ships, effective January 1, 2026.

4. Approve the uniform interpretation of SOLAS Chapter II-2, which relates to SOLAS Section II-2/11.1.4.1, Category A machine space cover, and SOLAS Sections II-2/4.5.3.2.2 and 11.6.3.2 cargo tank ventilation modes.

Approved MSC.1/Circ.1276/Rev.2, Revised Uniform Interpretation of SOLAS Chapter II-2, correcting the oversight of SOLAS Article II-2/9.7.5.1.

Approves the uniform interpretation of SOLAS Chapter II-1 with respect to the application of SOLAS Section II-1/26.2 of the requirement of "Reliability of individual significant propulsion components" to electric propulsion vessels, effective January 1, 2026.

7. Adopts the amendment to paragraph 6.14.1.1 of the revised Recommendation for testing life-saving Equipment (resolution MSC.81(70)) and approves the following four circulars, all with an effective date of 15 August 2025.

(1) MSC.1/Circ.1628/Rev.3 Revised standardized Report Form for Evaluation and testing of life-saving equipment (personal life-saving equipment);

(2) MSC.1/Circ.1630/Rev.3 Revised standardized life saving Equipment Evaluation and Test Report Form (survival craft);

(3) MSC.1/Circ.1631/Rev.3 Revised standardized Report Form for Evaluation and testing of life-saving equipment (rescue boats);

4) MSC.1/Circ.1632/Rev.3 Revised standardized Report Form for Evaluation and testing of life-saving equipment (launching and boarding equipment).

Approved the revised MSC.1/Circ.677/Rev.1 Standard for the design, testing and Positioning of Equipment to prevent the entry of flames into tanker cargo tanks, effective December 4, 2026.

Approved the draft amendment to Article II-2/11 of SOLAS to implement consistent provisions for passenger and cargo ships and submitted to MSC 110 for adoption.

7. Navigation, communications and Search and Rescue (NCSR 11 report) (agenda item 13)

The meeting considered and generally approved the NCSR 11 report, including the following:

1. Approves the draft General Assembly resolution on charges for distress, emergency and secure communications for mobile satellite services recognized in the Global Maritime Disaster and Safety System (GMDSS), amends and repeals resolution A.707(17), and recommends A.34 for adoption.

(2) Approve the amendments to the International Aviation and Maritime Search and Rescue Manual (IAMSAR), the application date of which has been set for 1 January 2026.

3. Endorses the Sub-Commission's approval of SAR.7/Circ.16, which amends and replaces SAR.7/Circ.15, on the list of documents and publications to be held by the Maritime or joint Rescue Coordination Centre.

4. Adopted resolution MSC.509 (105) /Rev.1 on the development of performance standards for the Digital Navigation Data System (NAVDAT).

5. Approves the draft General Assembly resolution on standards for the provision of mobile satellite communications systems in the Global Maritime Disaster and Safety System (GMDSS), revising and revoking resolutions A.1001 (25) and MSC.1/Circ.1414, and recommends A.34 for adoption.

6. Pilot embarkation facilities

(1) Approve the draft amendments to SOLAS Article V/23 and the Appendix (Certificates);

(2) Approve the draft resolution on performance standards for pilot embarkation and disembarkation devices;

(3) Approve the corresponding draft amendments to the 1994 and 2000HSC Rules;

(4) Approve the draft amendments to the Special Purpose Vessels Safety Code 2008 and the Fishermen and Fishing Vessels Safety Code 2005;

(5) Agree to amend the draft notification of MSC.1/Circ.1428 on the necessary pilot mobility arrangements for pilots and other personnel, the effective date of which is fixed on MSC 110.

7. Approval of other circulars

(1) Guidelines for the effectiveness of the installation and use of radio equipment on board ships (MSC.1/Circ.1460/Rev.5);

(2) IALA Maritime buoy System (SN.1/Circ.297/Rev.1);

(3) IALA's Risk Management Toolbox for navigational and Vessel Traffic Services (SN.1/Circ.296/Rev.1).

8. Approves the difficulties and risks associated with setting up radar displays to correctly display SAR radar transponder signals (SN.1 Circular).

8. Cargo and containers (CCC 10 report) (item 14)

The Meeting considered the urgent matters identified in the report of CCC 10 and took the following action:

(1) Approval of the Interim Guidelines for the Safety of Ships Using Ammonia Fuel;

2. Adoption of an updated work plan for the development of guidelines for new alternative fuels;