InterManager IMO Updates

Practitioners of ship management face an increasingly difficult challenge of having to cope with managing information flowing from an expanding regulatory agenda. In this section InterManager provides several value-adding info streams:

  • IMO circulars
  • Meeting Reports
  • Request for comments
  • Members contributions

Our high level view of what’s on happening on the regulatory radar screen will hopefully alert members to the new initiatives to watch out for and point you in the right direction if you need to find out more.

We are also keen to share information on how members are coping with new regulatory demands at the ‘coalface’ so to speak. We invite members and other interested parties to comment and contribute to this section of the InterManager website!

IMO Updates

IMO SUB-COMMITTEE ON SHIP DESIGN AND EQUIPMENT 13 – 17 February 2012

The IMO’s sub-committee on Ship Design and Equipment (DE) held its 56th session on 13 through 17 February 2012. Mrs Annelise Jost of Germany chaired the meeting very ably and was re-elected for the coming year. Her Vice Chairman, Dr Susumu Ota of Japan, was similarly re-elected. A number of Working Groups (WG’s) were formed and their main recommendations, as subsequently endorsed in Plenary, are as follows:
• Revision of the Revised Guidelines for Sewage Treatment Plants, also the standard specification for shipboard incinerators. The draft MEPC Resolution on 2012 Guidelines on the Implementation of Effluent Standards and Performance Test for STP’s were agreed in principle and should be applied from 1 January 2016. The previous possibility of ‘dilution compensation’ was re-included so that it can be evaluated at MEPC 64. It was also agreed that the capacity limit for shipboard incinerators should be increased from 1,500 kw to 4,000 kw and a recommendation made to MEPC 64 that this ‘extended’ range can be type approved under the existing Standard Specification for Shipboard Incinerators, whilst extending the target completion year to 2013.
• Protection Against Noise on board ships. A protracted and somewhat acrimonious discussion took place on Chapter 6 of this WG’s report, namely ‘Acoustic Insulation Between Accommodation Spaces’. The group had recommended that the ‘Sound Insulation Index’ figures and ‘Erection of Materials’ instructions be made mandatory. BAHAMAS argued that the Code should be divided into two sections, one recommendatory and the other mandatory, whilst FRANCE felt the current structure (mandatory only) to be suitable. Member governments then took sides. A particularly noteworthy comment by KOREA observed a discrepancy in the difference between laboratory and on board noise levels of 5db. The USA believed that, given the absence of installation instructions, the ‘Measurement’ guidance/instructions suggested by the WG would be difficult to implement. In forwarding the DE’s report, the Chairman stated that all proposals would be included, particularly the statements made by the BAHAMAS, FRANCE and the USA, seeking MSC’s guidance on how best to proceed.
• Development of Performance Standards for Recovery Systems for all Types of Ships. A much less contentious item. Most noteworthy among the 13 WG proposals endorsed by the committee included that of providing flexibility for lifeboat servicing as part of the development of a mandatory instrument; agreement to a road map for the development of a new framework of requirements for life-saving appliances; issuance of an invitation to governments for concrete proposals on the development of specific safety objectives and functional requirements for SOLAS chapter 11-1; a refusal to approve the IACS unified interpretation on the matter of infant-lifejackets in its current form and finally, an agreement to establish a correspondence group.
• Development of a Mandatory Code for Ships Operating in Polar Waters. There were approximately 100 participants in this WG, thus demonstrating its importance. Regarding Environmental issues, the group discussed at length to what extent the future Code should contain requirements on environmental protection in addition to that achieved by enhancement of safety. A majority felt that the Code should address both accidental and operational sources of pollution. However, in order to help resolve the divergence of views as to whether environmental protection provisions should be elaborated as part of the Code, two options were suggested. The first would continue to develop the environmental provisions in the Code within the CG in addition to holding a topic-related intersessional meeting. The second option would immediately divert some of the environmental matters to MEPC and its subordinate sub-committees. A great many opinions were expressed following which the Chairman ruled that an intersessional meeting was not sufficiently supported and therefore would not take place. In addition, she felt that DE should consider those matters pertinent to environmental protection which are not discussed in other bodies and that the preparatory work should be carried out by the re-established CG. Thus Chapter 15 (‘Environmental Protection’) is to be held in abeyance and not forwarded to MEPC ‘until we understand it ourselves’ following further discussion at DE 57. Chapters 1 through 14 and Annex 3 of the draft Polar Code on the other hand, were approved for forwarding to MEPC.
• Regulation on Plans and Procedures for Recovery of Persons from the Water. Following a debate on whether to place the new Regulation in Chapter III or Chapter V of SOLAS, the committee opted for the former and agreed to forward a draft resolution to MSC concerning the implementation of SOLAS regulation III/17-1 to ships other than those engaged on international voyages. IACS stated that, as the draft amendment will enter into force for existing ships in July 2014, if it has been inserted into ISM Documentation on board any existing ship, ISM audits taking place prior to that date should not penalise the ship.
• Other Items of Interest discussed in Plenary.
(1) The sub-committee invited parties interested in the thermal performance of immersion suits to prepare terms of reference for a correspondence group.
(2) It was agreed that there is an urgent need to further consider the application of existing IMO Instruments to Offshore Windfarm Construction Support Vessels and Service Craft and to clarify the application of relevant requirements concerning industrial personnel transported by sea.
(3) Concerns were expressed at the IACS UI (SC 248) on the greatest launching height for a free-fall lifeboat following which Member States/International Organisations were invited to submit comment and proposals to DE57.
(4) The Sub-Committee invited interested parties to prepare terms of reference for a correspondance group regarding the revision of testing requirement for lifejacket RJDs including a possible amendment to the LSA Code.

Captain Paddy McKnight


BLG 16

The IMO’s sub-committee on bulk Liquid and Gases(BLG) held its 16th session on 30 January through 3 February 2012. Mr S Oftedal (Norway) chaired the meeting and he was re-elected for the voming year. His Vice-Chairman, Dr R Zhang (China) was similarly re-elected.

Matters of greatest interest to Intermanager Members are as follows :

• BLG considered a Netherlands proposal from MSC89 that an additional regulation should be added to specifically prohibit production processes on board ships that result in new products. Observing that this proposal obviously stemmed from the PROBO KOALA tragedy, OCIMF reminded the meeting that the loss of life was not caused by processing on board, rather it was the disposal of residues on land thus indicating that it is the generation of waste which requires attention. IMCA expressed concern that the text of the proposed ban on production processing during the sea voyage would have the result of outlawing existing, accepted practises for the offshore industry and pleaded exemption for that sector. IBIA also requested that restrictions to blending operations should not apply to bunker barges. This matter will be further addressed at MSC90.
• It was stressed that when considering the operational phases as to when inserting media should be applied, FP had directed that the application of Inert gas to render the tank non-flammable should take place before the commencement of unloading.
• BRAZIL expressed concern on bio-fuel blends and the approval of Oil Discharge Monitoring Equipment (ODME). It was agreed that all interested parties should submit any relevant technical information for consideration at BLG 17.
• 33 Contracting Governments representing 24.46 percent of the world merchant fleet tonnage have now acceded to the Ballast Water Management Convention against the desired figure of 30/30. Regarding B/W sampling and analysis, two sets of draft guidance were put forward by the EC led correspondence group, one on sampling and analysis, the other on PSC guidance. This item was undoubted the most contentious of the whole meeting; it certainly took most time and resulted in an exact split between the EC led group and that of the large flags such as PANAMA and BAHAMAS though the latter group was given an excellent lead by ICS. The Chairman rightly observed that unless the concerns of the large flags were met, the Convention would not come into force and elected to take the item through to BIG 17.
• With respect to a Code of Safety for Ships using gas or other low-flash point fuels into properties similar to LNG, SIGTTO expressed concern with the CG’s report on the current draft of the IGF Code, from the point of view of design and operational aspects of the vessels. In particular, the location of accommodation above the fuel tank/containment system and gas containers/make up equipment. The sub-committee decided that in determining the location of such tanks, a risk-based approach should be pursued in lieu of deterministic. Also it was agreed that training requirements should be developed for inclusion on the STCW Convention. Both these matters were referred to the WG.
• Sampling of fuel oil used on board ships elicited a view from the Cook Islands that quality control of bunker fuel prior to delivery to ships could resolve the compliance problems related to fuel oils, though government reps were (understandably) not receptive to such a suggestion. BAHAMAS felt that the existing G/L’s for the sampling of fuel oil delivered to ships could not be used as a base document for development of guidance for the sampling of fuel oil used O/B ships as they entailed entirely different procedures and that it was not clear how samples of the fuel oil used on board would be handled and analysed. It was agreed to report back to MEPC but not to develop Guidelines/Guidance at this session of the BLG.
• It is noted that no documents on CASUALTY ANALYSIS had been submitted to BLG16. This is particularly shameful given OCIMF’s report that over the past 6 years, approximately 85 fire and explosion incidents have occurred on vessels carrying bulk liquids and gases.
• Black Carbon was discussed under AOB. A number of alternative definitions were advanced and a CG will be set up intersessionally to address the work plan for consideration of the impact on the Arctic.

Capt. Paddy McKnight


Expert Working Group meeting on reducing GHG 08/09 Feb 2011

please find below a brief summary of the expert Working Group meeting on reducing GHG emissions from ships (WG Ships) under the European Climate Change Programme (ECCP).

ECCP is the European Commission’s main instrument to bring together all relevant stakeholders, to discuss and prepare the further developments of the EU’s climate policy.

The forming of WG Ships is based on the commitment in the Climate and Energy legislation where the European Parliament and the Council have requested the European Commission to come forward with a proposal to include international maritime emissions in the EU’s reduction commitments should there be no sufficient international agreement addressing these emissions through the IMO and/or UNFCCC by the end of December 2011. The proposal is scheduled to be tabled in the first quarter of 2012.

WG Ships consists of:

  • experts from Member States
  • participants from the European Commission and the European Parliament
  • NGO representatives
  • representatives from shipping trade associations & organizations
  • representatives from some selected research institutes.

The first meeting was held in Brussels on 8th and 9th of February. The undersigned participated on behalf of InterManager.

The establishing of this expert group now was seen as an initiative by the EU Commission to step up the pressure on IMO to make progress in its regulatory efforts with regard to CO2 (MEPC 62 in July 2011).

All participants in the meeting agreed that a global regulatory regime was the preferred solution, but few were convinced that this would be the result. The danger of regional initiatives (with conflicting requirements) is significant. On behalf of InterManager I voiced the concern regarding a potential undermining of IMO’s authority as the main regulating body for international shipping.

Another crucial question is: What is sufficient progress? No representatives from EU were willing (able?) to give a clear answer.

Main topics in the first meeting were:

  • Scope (which emissions to cover)
  • Monitoring
  • Enforcement

None of these topics were concluded due to short time for meeting preparations. The topics will be discussed again in the next meeting after review of submissions in writing from the participants in the period up to the next meeting (April or May). Hence, there are little more to report at this point in time.

Best regards

Svein Sorlie


docx Expert Working Group meeting on reducing GHG 08/09 Feb 2011 (12.31 kB)

Downloads: 1
Date: 2011-06-03



What shipping needs from its cooks

More needs to be done with regard to maritime training catering personnel on ships”, said Cyprus Shipping Chamber Chairman Captain Eugen Adami in a keynote address to the SeaChefs seminar in Cyprus. “Today a cadet is on average 21 years when joining ship, by age 45 the first prolonged problems with diet related diseases appear, like high blood pressure, cholesterol etc. This cadet and officer actually served 18 years on board of our ships and was only 6 years on vacation. We made him actually sick”, Captain Adami says!!

He expanded on what owners expect from their catering staff: that they offer dishes based on dietary preferences of all crew and all cultures on board, i.e. no pork for Muslim crew. They offer a variety of menus taking into consideration all hygiene requirements and dietary and health practises. In short wholesome meals served in high quality.

What are the current problems? Adami sees three issues: ship managers are having difficulties finding qualified catering staff. Cooks have difficulties offering dishes other than their native dishes on vessels which are manned by European crew. There is a lack of skills: baking skills; a lack in communication skills (English knowledge); a failure in hygiene and safe working practises.

He is critical too of cost control and budgeting saying that the frequent discrepancies on board vessels and the manipulation of figures show that catering staff are just not fully aware of the importance of cost controlling and the accurate inventories and sensible provision requisitions.

Having pin-pointed the issues he says, “All Cooks and Stewards have to graduate from a accredited catering school. Companies have to develop refresher E-learning courses to keep all Cooks and Stewards regularly abreast with nutrition developments. In conclusion we need common minimum standards for the catering department. We see excellent opportunities for young Europeans to take up this profession and avoid painful unemployment in their home countries.”

This underscores the rational for the EU sponsored Sea-Chefs project led by Bernhard Schulte Ship Management to find answers to the burning issues and assist the industry to kick-start a new and long overdue certification for ships’ cooks.

A report on the Cyprus seminar by Captain Ralph Becker Heins of MSG MarineServe GmbH is attached.


pdf Seachefs Project Report (128.16 kB)

Downloads: 11
Date: 2011-06-07



Outcomes of Marine Environment Protection Committee (MEPC) Meeting 60th session: 22-26 March, 2010

At this meeting the MEPC found difficulty in making tangible progress on the issue of reduction in Greenhouse Gases due to the legacy of COP15 and the continuing divide between the developed and developing world which caused tension from time to time in the plenary sessions. Despite this, it was important for InterManager to be one of the many NGOs present in an almost unprecedented packed auditorium in order to keep a close eye on the technical, operational and commercial ramifications of the discussions taking place.

For this meeting 159 papers were tabled for consideration of which 100 referenced Green House Gases (GHG).

This report summaries outcomes.


pdf Summary of IMO MEPC 60 (77.44 kB)

Downloads: 0
Date: 2011-06-07



IMO IN BRIEF – MEPC – Session 60

What ship and crew managers should watch out for.

This Brief lists on one page the key points in the detailed debates and decisions at IMO that will impact on shipmanagers’ business in the years ahead. For more detail and background information see the posting titled Outcomes of Marine Environment Protection Committee (MEPC) Meeting 60th session: 22-26 March, 2010.


pdf IMO IN BRIEF - MEPC – Session 60 (78.91 kB)

Downloads: 1
Date: 2011-06-07



STCW set for major revision

Draft amendments to the STCW Convention, and its associated Code, have been approved by the Sub-Committee on Standards of Training and Watchkeeping (STW) and are ready for submission to a Diplomatic Conference in Manila, Philippines, 21-25 June 2010, for adoption.

The proposed amendments are the first major revision of the two instruments since those, completely revising the original 1978 Convention, adopted in 1995.

The attachment summaries the outcomes of the last sub-committee meeting before the Conference.


pdf InterManager STW41 Report (165.94 kB)

Downloads: 4
Date: 2011-06-07



IMO Council Elections

The status quo in IMO representation is retained in the current elections conducted at the IMO Assembly meeting in London. It continues the regime of a low level of representation across Africa and South America and an over representation amongst the EU.

The Council is the executive of IMO and is responsible, under the Assembly, for supervising the work of the Organization. Between sessions of the Assembly the Council performs all the functions of the Assembly, except the function of making recommendations to Governments on maritime safety and pollution prevention which is reserved for the Assembly.

The Council is elected by the Assembly for a two-year term.
Liberia contributes 8.6% to the IMO annual budget but failed to achieve sufficient votes to gain a position in the new Council.

Council members for the 2009-10 biennium in three categories of voting are as follows.

Category (a): 10 States with the largest interest in providing international shipping services:

China, Greece, Italy, Japan, Norway, Panama, Republic of Korea, Russian Federation, United Kingdom and United states

Category (b): 10 other States with the largest interest in international seaborne trade:

Argentina, Bangladesh, Brazil, Canada, France, Germany, India, Netherlands, Spain, Sweden

Category (c): 20 States not elected under (a) or (b) above which have special interests in maritime transport or navigation, and whose election to the Council will ensure the representation of all major geographic areas of the world:

Australia, Bahamas, Belgium, Chile, Cyprus, Denmark, Egypt, Indonesia, Jamaica, Kenya, Malaysia , Malta, Mexico, Nigeria, Philippines, Saudi Arabia, Singapore, South Africa, Thailand, and Turkey

The top ten contributors for 2008 were assessed as follows (the figures show the amount payable in £s and as a percentage of the total budget):

Panama – 4,683,032 – 19.20
Liberia – 2,100,248 – 8.61
Bahamas – 1,227,968 – 5.03
United Kingdom – 1,146,457 – 4.70
Greece – 1,000,898 – 4.10
Marshall Islands – 996,598 – 4.08
Singapore – 994,487 – 4.08
Japan – 841,854 – 3.45
China – 797,893 – 3.27
United States -790,016 – 3.24

The attached report covers key achievements of IMO in the last two years.


pdf Key points of opening address to 26th IMO Assembly (59.45 kB)

Downloads: 2
Date: 2011-06-07



Anti-Piracy Planning Chart

The UKHO has produced an Anti‐Piracy Planning Chart as part of an initiative driven by the EU Naval Force. The chart, numbered Q6099, covering the Gulf Of Aden, south of the Horn of Africa is designed to collate all relevant information for the area and to raise awareness. The chart has the transit corridors marked, UK Maritime Trade Operations (UKMTO) Dubai reporting boundaries, instructions to avoid becoming a victim and telephone numbers in the case that a ship is attacked.

The chart is to be provided free of charge.

Shipmanagers that wish to acquire the chart will need to contact: theMaritime Security Centre – Horn of Africa (MSC-HOA) postmaster@mschoa.org


pdf Anti Piracy Planning Chart Q6099 (1.79 MB)

Downloads: 5
Date: 2011-06-07



Bulletin 660 Iron Ore Fines – India

The Club’s earlier LP Bulletins 546 – 10/07 and 647 – 7/09 warn members of the serious risks that can be associated with the carriage of iron ore fines loaded in Indian ports. Reports of serious incidents continue and include two vessels loaded with this product that have capsized in the last two to three months. At the present time the Club is dealing with 12 current cases involving this commodity. This has increased its concern over safety when shipping iron ore from this area and has prompted this additional and strengthened warning to Members.


pdf Bulletin 660 Iron Ore Fines - India (252.78 kB)

Downloads: 0
Date: 2011-06-07



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