IMO Instruments Implementation Subcommittee Meeting: July 31 – August 4, 2023

Credit: Ritz Carlton Yacht Collection

Sub-Committee on Implementation of IMO Instruments (III 9), 31 July – 4 August 2023. The Sub-committee finalized the draft text of the III Code Implementation Guidance.

Implementation Support Resolutions

The Sub-Committee, which reports to the Maritime Safety Committee (MSC) and the Marine Environment Protection Committee (MEPC), finalized the updating of four key IMO Assembly resolutions on implementation:

  • the draft Survey Guidelines under the Harmonized System of Survey and Certification, 2023;
  • the draft 2023 Non-exhaustive list of obligations under instruments relevant to the IMO instruments implementation Code (III Code);
  • the draft Procedures for port State control (PSC), 2023; 
  • the draft 2023 Guidelines on the implementation of the ISM Code by Administrations. 

III Code Implementation Guidance 

The Sub-committee completed the III Code Implementation Guidance draft, designed to aid Member States in implementing the III Code and audit standards of the IMO member state Audit Scheme (IMSAS).

Guidance for Remote Surveys

The Sub-Committee finalized part of a package of work on guidance on assessments and applications of remote surveys, ISM Code audits and ISPS Code verifications, as contained in draft Survey Guidelines under the Harmonized System of Survey and Certification (HSSC) and Guidelines on implementation of the ISM Code, with a view to adoption by A 33 (26 November-6 December). 

  • Casualty Investigation Code 

The Sub-Committee discussed a comprehensive review of the Casualty Investigation Code, focusing on enhancing the quality and timeliness of safety investigation reports. They received strong support for this review and invited Member States and international organizations to propose a comprehensive review output to the Maritime Safety Committee.

  • Casualty analysis 

The Sub-Committee considered the report of the Correspondence Group on Analysis of Marine Safety Investigation Reports, containing information based on the analysis of the 27 marine casualties and incidents.  

  • Lessons learned  

The Sub-Committee approved the text of Lessons Learned from marine casualties and their release on the IMO website: Lessons-Learned. The Sub-Committee highlighted the importance of submitting the Lessons Learned while uploading marine safety investigation reports.  

Risks Of Falls  

The Sub-Committee considered the proposal developed by the Correspondence Group for a new output on guidelines addressing the identified safety issues of seafarers exposed to risk of falls from height and agreed to forward to the MSC a proposal to develop guidelines addressing safety issues related to risks of falls from height. 

Preventing The Loss

The Sub-Committee considered the proposal developed by the Correspondence Group related to the development of measures to prevent the loss of containers at sea.  

The Sub-Committee agreed to forward the proposal along with analysis to the Sub-Committee on Carriage of Cargoes and Containers (CCC) for further consideration, under the CCC agenda item “Development of measures to prevent loss of containers at sea” in its biennial agenda for 2024-2025.  

Fishing vessels – person overboard   

The Sub-Committee invited the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR) to recommend that the ICAO/ILO Joint Working Group on Harmonization of Aeronautical and Maritime Search and Rescue (JWG 30) should determine the most effective and appropriate means for locating a person falling into the water from fishing vessels and take further action to address the safety issue. 

Data Analysis

  • Sub-Committee reviewed 10 documents.
  • Encouraged submissions of data analyses.
  • Sought proposals for effective analysis in support of IMO’s regulatory work and policy development.

Port State control (PSC) 

The Sub-Committee noted that information provided by all 10 PSC regimes revealed that 63,761 inspections were carried out in 2020, 74,574 in 2021 and 81,346 in 20222.  

In 2020, 1,530 detentions were reported, 1,746 in 2021 and 2,160 in 2022. The overall detention rate increased from 2.34% in 2021 to 2.66% in 2022.  

The Sub-Committee considered the regulatory basis for port State control, roles and responsibilities of Contracting Governments in their right to exercise port State control, and the supporting role of IMO.

Cape Town Agreement 

  • Progressed in drafting guidance for Cape Town Agreement implementation.
  • Assigned a correspondence group to finalize the text.
  • Noted 21 Contracting States and 2,603 fishing vessels (≥24 meters) on high seas.
  • Agreement needs 22 States and 3,600 vessels to enter into force.

Sub-Committee Highlights

Joint FAO/ILO/IMO Ad Hoc Working Group 

The Sub-Committee considered the matter on the preparation of the fifth joint FAO/ILO/IMO Ad Hoc Working Group on Illegal, Unreported and Unregulated (IUU) Fishing and Related Matters (JWG 5), which is expected to convene at the beginning of 2024.

Marine plastic litter from ships  

With a view to progressing the work under this agenda item, the Sub-Committee invited interested Member States and international organizations to submit documents to III 10 on work on marine plastic litter assigned to it by MEPC. 

Analysis of GISIS module on port reception facilities 

The Sub-Committee noted analysis of data contained under the Port Reception Facilities (PRF) module of GISIS.  

PRF Inadequacies by waste type 2018 to 2022 shows that 93% of reported inadequacies relate to MARPOL Annex V (garbage). More than half (58%) of the reports state no facility available, while 14% report unreasonable charge for use of the facilities. 

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Source: IMO


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