News & Events


By | INTLREG NEWS | No Comments
The spread of the COVID-19 virus is causing significant issues in the shipbuilding industry, but English law has no general concept of force majeure, and this is a key factor in the relationship between shipyards and shipowners.

Shipyards are facing disruption to new building, repair and conversion projects due to the impact of the virus on their labour force and the ability of their subcontractors to meet their commitments to supply materials and equipment necessary for the completion of such projects.

As a result, shipyards in China, and elsewhere, have sought to invoke the force majeure provisions under their contracts with shipowners because of COVID-19 in order to obtain ‘no fault’ extensions of the delivery dates under these contracts.

This in turn has caused issues for shipowners who are now facing potential delays to the delivery of the vessels that they have contracted to buy, repair or convert, especially where those vessels are for delivery into a specific project or long term charter or the conversion works are linked to compliance with the 2020 low sulphur fuel cap.

Because most contracts are subject to English law, shipbuilding contracts must have an actual force majeure clause for the shipyard to claim force majeure and the burden of proof is on the shipyard.

On BIMCO’s website, members can read the full article that looks at force majeure provisions in standard form shipbuilding contracts and how these might operate in the context of COVID-19.

Any idea what a Ship Security Alert System is?

By | Maritime Knowledge, Maritime Training | No Comments
Although piracy follows a downward trend in the last decade, the threat of sailing in high risk areas still poses a psychological burden for crews. After the 9/11 attacks that changed the world, IMO requires every ship above 500 GT sailing the world’s oceans to have a Ship Security Alert System (SSAS) to enhance security. Have you ever wondered what this system is and how it works?
To provide knowledge to those designated to perform duties of CSO, SSO and other security duties on a managerial and operational level and ensure effective implementation of the ISPS Code, explain SSA process, SSP contents and measures per level, weapons recognition, devices, suspects & contingency planning, as per new STCW requirements,International Register Of Shipping (INTLREG) Conducts ISPS Code Training Course. For more details and registration of the course, Please contact

What is a Ship Security Alert System (SSAS)?

The Ship Security Alert System (SSAS), under the ISPS Code, is a system onboard designed to raise the alarm ashore in case of a security threat or security incident, so that help from security forces can be deployed to the scene.

Technically, the SSAS consists of a GPS receiver linked to a transmitter, a power supply, software and activation buttons.

When used, the activation button basically notifies the flag State of the ship without alerting ships or coastal states in the vicinity or giving any indication onboard.

Use of the ship security alert system is a recognition that security is political and requires different response to a distress or emergency onboard,

…IMO notes.

 Where is this alert sent to?

What makes the SSAS unique is the fact that it constitutes a silent ship security alarm system that does not issue any audio-visual signal on the ship or to nearby vessels, not even to security forces nearby.

In contrast, upon activated, the alert is sent directly to the ship owner or an SSAS management company. It is then directed to the ship’s flag state. Some flag administrations even require having direct notification upon activation.

As soon as the flag state is informed, it is obliged to immediately notify the state(s) and the international security centers in the vicinity of the ship’s location.

Then, local state authorities or already deployed antipiracy/antiterrorist forces will be able to provide appropriate military or law-enforcement forces to deal with the menace.

 What information does the SSAS provide?

Upon activated, the Ship Security Alert System sends the following details to the administration:

  1. Name and IMO number of the ship
  2. The Call Sign of the ship
  3. The ship’s position through Global Navigation Satellite System (GNSS)
  4. Date and time of the alert
  5. Maritime Mobile Service Identity.

 Where can we find an SSAS onboard?

Current regulatory framework foresees that there must be at least two security alert buttons onboard the ship, one on the bridge and another one in any other prominent location.

The whole crew onboard must be aware of at least one activation button location.

What happens if the button is pushed by accident?

The ISPS Code mandates that the SSAS activation points must be designed to prevent the unwanted initiation of the ship security alert.

A latch cover secures the button to prevent any accidental operation.

Anyone working in the vicinity of the SSAS button must be notified accordingly not to touch the button.

Once the SSAS button is pressed, the alert will be continuously transmitted to the administration unless it is reset or deactivated.

 What are the key challenges of the SSAS?

Although there are specialized security companies for SSAS monitoring, most shipping organizations for financial reasons prefer to assign a person within the company for this job, known as the Company Security Officer (CSO). This means that a CSO lies with a great deal of responsibility on his shoulders, and the ship crew must feel lucky if he/she is not in the shower or deep asleep.

In addition, it is known that the SSAS will not work in case of failure of main power or fault in the emergency backup power.

And as in any other task onboard, crew familiarization with the button location and the procedures to be followed is vital for cases of real emergency and should not be taken for granted.

About the ISPS Code

Under SOLAS Convention Chapter XI-2, IMO developed the International Ship and Port Facility Code (ISPS Code), a comprehensive set of measures to enhance the security of ships and port facilities.

The Code was adopted on 12 December 2002 on the aftermath of the 9/11 attacks in United States. ISPS Code came into force on 1st July 2004.

The Code is applicable to all vessels over 500 GRT operating on international trades, as well as the ports that service them.

Among others, the ISPS Code:

  • enables the detection and deterrence of security threats within an international framework
  • establishes roles and responsibilities
  • enables collection and exchange of security information
  • provides a methodology for assessing security
  • ensures that adequate security measures in place.

 Did you know?

The SSAS is the correspondent means of notification with the Emergency Transponder Code 7700 for aircrafts.




IMO Sub-Committee On PPR 7 Agrees Draft Amendments To MARPOL Annex I

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Prohibiting the use and carriage for use as fuel of heavy fuel oil by ships in the Arctic waters- draft MARPOL amendments agreed.

The Sub-Committee on Pollution Prevention and Response (PPR) agreed draft amendments to MARPOL Annex I (addition of a new regulation 43A) to introduce a prohibition on the use and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters on and after 1 July 2024.

The draft amendments will be submitted to the Marine Environment Protection Committee (MEPC 76) (19-23 October 2020) with a view to approval and circulation for adoption at MEPC 77 (spring 2021).

The prohibition would cover the use and carriage for use as fuel of oils having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s.

Ships engaged in securing the safety of ships, or in search and rescue operations, and ships dedicated to oil spill preparedness and response would be exempted.

Ships which meet certain construction standards with regard to oil fuel tank protection would need to comply on and after 1 July 2029.

A Party to MARPOL with a coastline bordering Arctic waters may temporarily waive the requirements for ships flying its flag while operating in waters subject to that Party’s sovereignty or jurisdiction, up to 1 July 2029.

Currently, a MARPOL regulation prohibits the use or carriage of heavy grade oils on ships in the Antarctic; and under the Polar Code, ships are encouraged not to use or carry such oil in the Arctic.

Meanwhile, the Sub-Committee established a correspondence group to further develop draft guidelines on measures to reduce risks of use and carriage of HFO as fuel by ships in Arctic waters. The draft guidelines would cover ship operation, ship construction and heavy fuel oil bunkering, infrastructure and communication, enhancement of heavy fuel oil spill preparedness, early detection and response, and drills and training.

Implementation of the IMO 2020 sulphur limit – verifying sulphur content of fuel on board – guidelines agreed

IMO 2020, the 0.50% limit for sulphur in ships’ fuel oil, has been in effect since 1 January 2020, cutting sulphur oxide emissions from ships operating worldwide. From 1 March 2020, the carriage ban on non-compliant fuel oil (except for ships with exhaust gas cleaning systems installed) will enter into force under MARPOL Annex VI, helping to support implementation of the global sulphur limit.

To support the safe and consistent sampling of fuel oil being carried for use, and the enforcement of the carriage ban, the Sub-Committee finalised draft guidelines which provide a recommended method for the sampling of liquid fuel oil intended to be used or carried for use on board a ship.

The draft 2020 Guidelines for sampling of fuel oil intended to be used or carried for use on board a ship will be forwarded to the next session of the Marine Environment Protection Committee (MEPC 75), which meets 30 March to 3 April 2020, with a view to adoption.

Revised guidelines on exhaust gas cleaning systems (scrubbers) agreed

The Sub-Committee finalised its work on revising the 2015 Guidelines for exhaust gas cleaning systems (EGCS, also known as “scrubbers”).

The revision is aimed at enhancing the uniform application of the guidelines, in light of recent technical developments and experience gathered from approvals and operation of such alternative compliance systems.

The draft 2020 EGCS Guidelines will be submitted to MEPC 75 for adoption.

The Guidelines specify the criteria for the testing, survey, certification and verification of EGCS under regulation 4 of MARPOL Annex VI to ensure that they provide effective equivalence to the sulphur oxide emission requirements of regulations 14.1 or 14.4 of MARPOL Annex VI, as applicable. They cover continuous monitoring requirements and discharge water quality criteria, including minimum pH, maximum PAHs (Polycyclic Aromatic Hydrocarbons) concentration; provisions to minimize suspended particulate matter, including heavy metals and ash, and to prevent discharge of nitrates beyond specified levels.

The Guidelines note that discharge water quality criteria should be reviewed in the future as more data becomes available. Guidance for voluntary discharge water data collection, by means of a recommended procedure for sampling, is included.

The Guidelines are expected to be applied to new exhaust gas cleaning systems installed after a date to be decided by the Committee.

Discharges from exhaust gas cleaning systems – evaluating and harmonising rules and guidance

The Marine Environment Protection Committee (MEPC) at its last session in May 2019 asked the PPR Sub-Committee to look into evaluating and harmonising rules and guidance on the discharge of liquid effluents from EGCS.

To assist the discussions, a report from a task team established by the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) was submitted. This report contains the conclusions of the task team in relation to the available evidence on the environmental effects of discharge water from EGCS, as well as recommendations on the data, tools and approaches that could be used as basis for conducting a risk assessment of the possible effects of discharges.

Following discussion in a working group, the Sub-Committee agreed to recommend to the MEPC that its future work should look at evaluation and harmonisation of rules and guidance on the discharge of discharge water from EGCS into the aquatic environment, including conditions and areas.

The scope of the work should include:

  • risk assessment (development of risk assessment guidelines for the evaluation of possible harmful effects of the discharge water from EGCS, taking into account existing methods and mathematical models);
  • impact assessment (to consider developing impact assessment guidelines);
  • delivery of EGCS residues (developing guidance on delivery of EGCS residues to port reception facilities, regarding volumes and composition of residues);
  • regulatory matters (including assessing state of technology for EGCS discharge water treatment and control, identifying possible regulatory measures, developing a database of local/regional restrictions/conditions on the discharge water from EGCS;
  • database of substances (establishing a database of substances identified in EGCS discharge water, covering physico-chemical data, ecotoxicological data and toxicological data, leading to relevant endpoints for risk assessment purposes).

The MEPC was invited to approve the planned scope of work and to consider involving GESAMP for scientific advice.

Reducing the impact on the Arctic of Black Carbon emissions from international shipping.

Black Carbon in the context of international shipping is the product of incomplete combustion of carbon-based fuels. Black Carbon emissions contribute to climate change as a ‘Short-Lived Climate Pollutant’.

IMO has been looking at how to measure and report on Black Carbon emissions, as part of its work to consider the impact on the Arctic of Black Carbon emissions from international shipping. A reporting protocol for voluntary measurement studies to collect Black Carbon data and Black Carbon measurement methods for data collection have already been agreed.

The Sub-Committee noted a number of submissions, including proposals to look at the aromatic content of blends of fuel oil. A high aromatic content, among other factors, could increase Black Carbon emissions from ships.

The International Standardization Organization (ISO) advised the Sub-Committee that it was already in the process of monitoring properties of very low sulphur fuel oil and high sulphur fuel oil and would provide feedback on their performance. ISO also advised the Sub-Committee that it would also consider whether it was possible to add a further measure to provide an approximate indication as to whether a fuel is more paraffinic or aromatic, based on the characteristics already included in the ISO 8217 standard, which specifies the requirements for fuels for use in marine diesel engines and boilers.

The Sub-Committee established a correspondence group to advance the development of a standardised sampling, conditioning, and measurement protocol, including a traceable reference method and an uncertainty analysis, taking into account the three most appropriate Black Carbon measurement methods (light absorption filter smoke number (FSN);  photo-acoustic spectroscopy (PAS); and laser induced incandescence (LII)), to make accurate and traceable (comparable) measurements of Black Carbon emissions; and investigate the linkages between the measurement systems and policy options.

Prohibiting cybutryne in anti-fouling systems 

The Sub-Committee finalised a proposed amendment to the IMO Convention for the Control of Harmful Anti-fouling Systems on Ships (AFS Convention), to include controls on the biocide cybutryne. The draft amendment will be forwarded to MEPC 75 for approval, with a view to adoption at MEPC 76.

The AFS Convention already prohibits the use of biocides using organotin compounds.

Revised guidance on commissioning testing of ballast water management systems agreed

Ballast water management systems (BWMS) may be used on ships to meet the requirements of IMO’s Ballast Water Management Convention, which has been in force since 2017 and aims to prevent the spread of invasive aquatic species in ballast water. An amendment to regulation E-1 of the BWM Convention, which is expected to be adopted by MEPC 75, mandates the commissioning testing of BWMS. The Sub-Committee completed its revision of guidance on this testing, which is intended to validate the installation of a BWMS by demonstrating that its mechanical, physical, chemical and biological processes are working properly.

Review of the Biofouling Guidelines

The Ballast Water Management Convention aims to prevent the spread of potentially harmful aquatic species in ballast water. But invasive species can also attach themselves to the outside of ships.

The Sub-Committee began its review of the IMO Biofouling Guidelines, which provide a globally consistent approach to the management of biofouling – the accumulation of various aquatic organisms on ships’ hulls.

The Sub-Committee identified key elements that require further attention and discussion, considered areas for potential revision of the Guidelines, and established a correspondence group on the review of the Biofouling Guidelines, to progress the relevant work and facilitate more effective deliberations at PPR 8.

IMO is executing the GEF-UNDP-IMO GloFouling Partnerships project which aims to drive actions to implement the Biofouling Guidelines. The project will also spur the development of best practices and standards for improved biofouling management in other ocean industries.

Marine plastic litter – draft circulars agreed

The Sub-Committee prepared a draft MEPC circular on Provision of adequate facilities at ports and terminals for the reception of plastic waste from ships and a draft MEPC circular on Sharing of results from research on marine litter and encouraging studies to better understand microplastics from ships.

A correspondence group was established to consider how to amend MARPOL Annex V and the 2017 Guidelines for the implementation of MARPOL Annex V (resolution MEPC.295(71)), to facilitate and enhance reporting of the accidental loss or discharge of fishing gear, as currently provided in regulation 10.6 of MARPOL Annex V, and consider the information to be reported to Administrations and the IMO, the reporting mechanisms and modalities.

This work is in the context of the IMO Action Plan to address marine plastic litter from ships, which aims to enhance existing regulations and introduce new supporting measures to reduce marine plastic litter from ships. The action plan was adopted by the MEPC in 2018.

The MEPC agreed actions to be completed by 2025, which relate to all ships, including fishing vessels. The action plan supports IMO’s commitment to meeting the targets set in the UN 2030 Sustainable Development Goal 14 (SDG 14) on the oceans.


Cleaning and disinfection practices on Ships in COVID-19 case

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As vital as the Maritime industry is to the world and its people, equally important is the work of the brave seafarers who perform one of the toughest jobs in the world by running those massive ships through the roughest seas and riskiest areas. INTLREG is concerned with health, safety and well-being of seafarers across the globe. To all our Seafarers who are still making sure all our vessels make it to their destinations, please read below  to make sure that you are taking the precautions and are safe.

Maintaining good hygiene onboard plays a major role against all seaborne diseases. Given the recent Coronavirus outbreak, crew members onboard more than ever need to be aware of the key practices for their safety and protection; routine cleaning, proper disinfection practices and appropriate treatment of waste produced from the COVID-19 are among those practices that can play an essential role in minimising the spread of the virus in case a suspected case of COVID-19 is found onboard.

Key tips for cleaning and disinfecting

In case of coronavirus emergency, it is advisable to clean all areas but apply disinfectant ONLY on surfaces/items with direct contact with person having presented COVID-19 symptoms, especially the areas which may have been occupied by the person etc. Do not use disinfection to the areas which are not relevant to potential transmission, such as floor, carpet, walls, etc.

Clean the hard, non-porous surface first with detergent and water, and then apply disinfectants according to the product instructions. Ensure correct concentrations and sufficient contact time for effective disinfection. Carefully remove porous materials, where possible, such as upholstery, rugs, and carpeting that have been in contact with the suspect case. Launder in accordance with the product instructions or dispose of the materials as described below.

Waste disposal containers in the area, where a person presenting COVID-19 symptoms has been in direct contact with surfaces/items and may be possibly contaminated, should be emptied prior to starting surface cleaning and disinfection. Waste disposal containers located in contaminated areas should be emptied by persons wearing PPE.

Key requirements for crew members in charge

Crew or personnel on board in charge of cleaning and disinfection should:

  1. Have knowledge of how to prepare correct dilutions and the contact time for the disinfectant being used
  2. Limit hand contact with the face, especially the nose and eyes
  3. Use PPE (disposable gloves, mask, gown) to be protected from direct contact with chemicals and against direct contact with secretions/blood/body fluids.
  4. Change PPE frequently, especially if they become damaged during cleaning and disinfection
  5. Use eye protection apparatus, if splashing is expected, prior to entering the contaminated areas
  6. Use additional barriers (e.g., leg covers, shoe covers) as needed
  7. If reusable heavy-duty gloves are used for cleaning and disinfecting, they should be properly disinfected after use
  8. Be familiarised with the appropriate disposal of contaminated PPE
  9. Used PPE should be disposed of in plastic bags, tied up, and labelled with a biohazard symbol. Do not shake the PPE while handling to prevent producing aerosols
  10. Hands must be washed using soap and warm water for a sufficient period of time (20 to 30 seconds) to remove any infectious material.

Moreover, all used PPE and all soiled items (used tissues, disposable masks, tubing, linen, pillows, blankets, mattresses not covered with an impermeable plastic covering, etc.) in the contaminated areas, should be treated as Bio hazardous waste (classified as Category A infectious waste UN 2814 for transportation) and stored in an impermeable plastic bag labelled biohazard. The bag should be tied up, not reopened and disposed according to the protocol of the ship for clinical waste. If incinerator is available on board, then waste must be incinerated. If waste must be delivered ashore, then special precautions are needed and the port authority should be informed before waste delivery.


Standard Club News: Scrubber installation delays in China due to novel coronavirus (nCoV) outbreak

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The race to get scrubbers retrofitted on ships ahead of the second part of IMO2020 regulations (ban on the carriage of non-compliant fuels which comes into effect on 1 March 2020) may result in a significant extension of the budgeted downtime for many vessels.

As ship queues for scrubber installation grow at Chinese repair yards, some members are now faced with delivery delays due to the impact of the novel coronavirus (nCoV) outbreak. The Chinese government has already extended the lunar new year holiday, but there are concerns that the workers may not return any time soon.

The club has received some queries from the members concerned to check whether such situation would fall within ‘force majeure’.

With the understanding the charter party is still on-going and the vessel is temporarily in a yard to install the scrubber, the fact that the ship is in every way fit to perform the charter party obligations, the member should have some grounds to argue that this falls within ‘force majeure’ depending on the terms of the governing charter party. However, under the common law there is no general definition of ‘force majeure’ – it has the meaning given to it by the contract which governs the relationship between the parties.

In determining whether the delays caused due to the ‘quarantine restrictions’ and ‘restraints of labour’ can classify as a ‘force majeure’, and whether this will become an ‘off-hire’ event or not is not so straightforward. There could be a risk for the member in breaching contractual obligations. As such, the club recommends its members to review their charter party terms, and put the relevant parties on notice of the fact that there could be delays due to the prevailing circumstances and conditions.

Members are also recommended to refer to the club’s article on ‘Novel Coronavirus outbreak in China‘ and ‘IMO-2020 knowledge hub‘ for further guidance on these topics. Standard Club is always on hand to assist and advise its members on these topics.


Coronavirus outbreak: Key protection measures for seafarers

By | Maritime Health | No Comments

The International Transport Workers’ Federation (ITF), USCG and Transport Malta, following the rest of the shipping industry, provide their advice to crew members on how to be protected by the coronavirus.

ITF Advice for crew members

  1. Encourage all onboard to practice hand and respiratory hygiene especially when coughing or sneezing.
  2. Crew should use hand sanitiser/wash hands following contact with any passenger or other crew.
  3. If on a layover in a country with a known coronavirus outbreak, crew are advised to remain in hotel accommodation as much as possible and practice hand and respiratory hygiene and safe food practices.

The following advice from the International Maritime Health Association is more specific to the maritime industry, seafarers and dock workers:

  1. Do not restrict embarkation/disembarkation of seafarers in non-affected ports
  2. Do not restrict necessary ship visits by port agents, chaplains, service personnel and others.
  3. Do not visit food markets in China and avoid provision of fish and poultry in China.
  4. Do not consume raw eggs, milk, meat.
  5. Observe strict food hygiene to avoid cross contamination
  6. Ensure facial protection is provided for all crew (5 pieces /per person)
  7. Provide influenza vaccination, alcohol-based hand sanitiser and facial protection for ship inspectors and other crew who travel to China.
  8. If a crew member on board falls sick and has been travelling to affected areas 2-12 days before embarkation, the person must stay in his/her cabin.
  9. If a crew member is sick on board a ship, fill out the maritime declaration of health and notify the relevant port authority and consult a healthcare providers in the next port.

In addition, the USCG issued more advise concerning the Coronavirus outbreak, as such:

  1. Vessel representatives are required to report sick or deceased crew/passengers within the last 15 days to the CDC under 42 CFR 71.21.
  2. The Coast Guard will continue to review all “Notice of Arrivals” in accordance with current policies and will communicate any concerns stemming from sick or deceased crew or passengers to their Coast Guard chain of command and the CDC quarantine station who will coordinate with local health authorities.
  3. Vessel masters shall inform Coast Guard boarding teams of any ill crew members on board their vessel prior to the Coast Guard embarking and Boarding Teams should verify vessel illnesses with CDC if concerns arise.
  4.  Local industry stakeholders, in partnership with their Coast Guard Captain of the Port, should review and be familiar with section 5310 Procedures for Vessel Quarantine and Isolation, and Section 5320 – Procedures for Security Segregation of Vessels in their Area Maritime Security Plan.
  5. Local industry stakeholders, in partnership with their Coast Guard Captain of the Port, should review and be familiar with their Marine Transportation System Recovery Plan.

Click below to learn more :


Global Shipping Body (ICS) issues guidance to shipowners in the face of the Corona Virus

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Global Shipping Body (ICS) issues guidance to shipowners in the face of the Corona Virus

The International Chamber of Shipping (ICS), the global shipping body representing 80% of the world’s merchant fleet, is advising its membership to take steps that limit the spread of the novel Corona Virus (2019-nCov). The instructions reflect advice given from the World Health Organisation (WHO), who stated that if certain measures are taken, there should be no “unnecessary restrictions of international traffic”, meaning ports and global shipping can continue to operate.

Guy Platten, the Secretary General of ICS commented:

“The shipping industry will always prioritise the health of our crew and members of the public above all else. We have recommended that all our members across the world follow the WHO measures. As an industry, we fully understand the importance of playing our role in halting the spread of viruses.

“By implementing the measures in their entirety, we are avoiding the needless closure of any port. Shipping can continue to be the conduit for 90% of world trade, ensuring the steady supply of medicine, food and fuel for consumers worldwide. We are thankful that the WHO has avoided a knee jerk reaction, which would do nobody any favours.”

Advice provided to shipowners highlights the need for:

  • Exit screening at ports in the affected areas to detect symptomatic travellers and prevent the exportation of the disease. This includes checking for signs and symptoms and keeping confirmed cases under isolation and treatment.
  • Implementing health information campaigns to raise awareness on how to receive assistance if someone is showing symptoms.
  • Collaborating with public health authorities for case management on board ships, should a traveller with symptoms be detected.

The ICS takes its responsibilities on safeguarding public health extremely seriously. It has shared WHO guidelines to its members on how best reduce the possibility of the spread of 2019-nCov.

The trade body has urged all members to fully adopt the guidelines. Doing so avoids the unnecessary closure of ports, that facilitate 90% of global trade, including the transportation of medicines that underpin the health industry, as well as food and fuel supplies.

Should the WHO recommendations change with the closure of specific ports for medical reasons, we would recommend that the port in question and shipowners follow this advice. ICS will continue to keep a close watch on the situation and will notify its members of developments.

2020 Regulatory Agenda: What you should know

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The year 2020 has been eagerly anticipated by the maritime industry for the switch to a low-sulphur fuel environment. However, from January 1st of 2020, there are other regulations that take effect as well apart from the IMO Sulphur cap.  Discussions during IMO Meeting and preparations have been ongoing and with immediate implementation, the first day of the year is expected to be dominated by many amendments to SOLAS Chapters, MARPOL Annexes and Code revisions.

The year ahead will inevitably be a year of change and challenges and much of what maritime professionals must be aware of involves the following issues:

SOLAS amendments

#1 Protection against noise (Amendments to SOLAS II-1/3-12)

Because of a discrepancy in the application of the Code on Noise Levels on Board Ships, there has been a necessary amendment through a minor modification, in paragraph 2.1 of Chapter II-1/ Regulation 3-12. Namely, according to MSC.409(97), the existing paragraph 2.1 is amended to read as follows:

“.1 contracted for construction before 1 July 2014 and the keels of which are laid or which are at a similar stage of construction on or after 1 January 2009; or’’

#2 Damage control drills for passenger ships (Amendments to SOLAS II-1/19, III/30 and III/37)

Amendments to SOLAS chapter II-1 regulation 19 and chapter III regulations 30 and 37 to mandate damage control drills were adopted. The requirements are operational in nature with drills required at regular intervals for all passenger ships. According to MSC.421(98), the drills will have to involve crew members who have damage control responsibilities. Additionally, drills will have to be recorded and should cover different damage scenarios.

#3 Fire integrity of windows on passenger ships (Amendments to SOLAS regulation II-2/20)

According to MSC.421(98), Amendments to SOLAS regulation II-2/20 were drafted to clarify the requirements in chapter II-2 for the fire integrity of windows on passenger ships carrying not more than 36 passengers and special purpose ships with more than 60 (but no more than 240) persons on board. The amendments explicitly require that for ships carrying not more than 36 passengers, windows facing survival craft and escape slides, embarkation areas and windows situated below such areas shall have a fire integrity at least equal to “A-0” class.

#4 Fire protection of domestic boilers (Amendments to SOLAS Chapter II-2/10.5)

The text of regulation II-2/ has been amended. Prior to the amendment domestic boilers of less than 175kW were not required to carry an approved 135l foam-type fire extinguisher. The 135l foam extinguishers are now not required for boilers that are protected by a fixed local water-based firefighting system. Namely, according to MSC.409(97), in paragraph, the last sentence is replaced with the following:

“In the case of domestic boilers of less than 175 kW, or boilers protected by fixed water-based local application fire-extinguishing systems as required by paragraph 5.6, an approved foam-type extinguisher of at least 135 l capacity is not required.”

#5 Evacuation analysis now mandatory (Amendments to SOLAS II-2/13)

Existing paragraph II-2/13.7.4 is deleted. New paragraphs II-2/ and II-2/ have been introduced which require escape routes to be evaluated to demonstrate that the ship can be evacuated in the required time. According to MSC.404(96), the evacuation simulation will be used to identify and eliminate congestion which may develop during abandonment and demonstrate that escape arrangements are sufficiently flexible to provide for the possibility that certain routes/areas may not be available as a result of a casualty.

#6 Helicopter facility foam firefighting appliances (Amendments to SOLAS Regulation II-2/18 and the FSS Code Chapter 17)

MSC.404(96) states that amendments to SOLAS II-2/18 have a new paragraph 2.3 to require a foam application system that complies with the new chapter 17 of the FSS Code. The new Chapter 17 of the FSS Code details the specifications for foam firefighting appliances for the protection of helidecks and helicopter landing areas as required by chapter II-2 of SOLAS. As per MSC.403(96), for helicopter landing areas, at least two portable foam applicators or two hose reel foam stations shall be provided, each capable of discharging a minimum foam solution discharge rate.

#7 Fire safety requirements for cargo spaces containing vehicles with fuel in their tanks for their own propulsion (Amendments to SOLAS II-2/20)

Cargo spaces on all ships used for the transport of motor vehicles

(a) with fuel in their tanks for their own propulsion, that are loaded/unloaded into cargo spaces which do not meet the requirements of SOLAS II-2/20, “Protection of vehicle, special category and ro-ro spaces”; and

(b) that do not use their own propulsion within the cargo space

are not required to comply with SOLAS II-2/20 provided the vehicles are carried in compliance with the appropriate requirements of regulation 19 and the IMDG Code, as defined in SOLAS VII/1.1, in accordance with MSC.421(98)

#8 Requirements for lifeboats and rescue boats, launching appliances and release gear (Amendments to SOLAS Regulations III/3 and III/20)

The SOLAS amendments and associated MSC Resolution (MSC.402(96)) include explicit mandatory text clarifying the requirements for the qualification, authorization and certification of service suppliers, procedures for maintenance and testing, and what should be carried out at each stage of testing (weekly, monthly, annually, and 5-yearly).

#9 Mobile Satellite Service (Amendments to Chapter IV)

Various regulations of Chapter IV and the Record of Equipment model form were amended to remove references to “Inmarsat” and replace with references to “a recognized mobile satellite service”. MSC.436(99) clarifies that as a recognized mobile satellite service is defined any service which operates through a satellite system and is recognized by the Organization, for use in the global maritime distress and safety system (GMDSS)

#10 Harmonization of survey periods of cargo ships not subject to the ESP Code (SOLAS XI-1/2)

New regulation of SOLAS Chapter XI-1 revised the SOLAS Safety Construction Renewal Survey window for cargo ships which are not subject to the Enhanced Survey Program Code, so as to be harmonized with the Renewal Survey window under the ESP Code. MSC.409(97) states ‘’ For cargo ships not subject to enhanced surveys under regulation XI-1/2, notwithstanding any other provisions, the intermediate and renewal surveys included in regulation I/10 may be carried out and completed over the corresponding periods as specified in the 2011 ESP Code, as may beamended, and the guidelines developed by the Organization, as appropriate’’

#11 Damage Stability Explanatory Notes (SOLAS II-1)

Explanatory notes correspond to the extensive revisions of SOLAS chapter II-1, adopted by resolution MSC.421(98).

#12 INS performance standards (SOLAS V/18 ) – from 1st of July, 2020

Integrated Navigation Systems should comply with the revised performance standards, as per MSC.452(99) and MSC.252(83)

Amendments/ Revisions of Codes

#1 FSS Code, Chapter 8 – Automatic Sprinkler, Fire Detection and Fire Alarm Systems

MSC.1/Circ.1516 includes a new provision for water quality testing for automatic sprinkler systems and new flow charts for the testing and replacement of sprinkler heads and water mist nozzles. The related amendment to Chapter 8 of the FSS Code adds a new requirement for special attention to be paid to the specification of water quality provided by the system manufacturer, to prevent internal corrosion and clogging of sprinklers.

#2 IGC Code – Applicable fire integrity of wheelhouse windows

The IGC code has been revised to align with the requirements given in the SOLAS regulation II-2/ The amendments remove the requirement for A-0 fire-rated wheelhouse windows. Namely, MSC.411(97) states:

“3.2.5 Windows and sidescuttles facing the cargo area and on the sides of the superstructures and deckhouses within the limits specified in 3.2.4, except wheelhouse windows, shall be constructed to “A-60″ class. Sidescuttles in the shell below the uppermost continuous deck and in the first tier of the superstructure or deckhouse shall be of fixed (non-opening) type.”

#3 IGF Code – Regulations for fire protection

The amendments remove the requirement for A-0 fire-rated wheelhouse windows, as per MSC.422(98)

#4 LSA Code – Amendments on winches and winch brakes

Corrections to the provisions relating to winch and winch brake test loads as prescribed in the LSA Code. MSC.425(98) clarifies that ‘’ Structural members and all blocks, falls, padeyes, links, fastenings and all other fittings used in connection with launching equipment shall be designed with a factor of safety on the basis of the maximum working load assigned and the ultimate strengths of the materials used for construction. A minimum factor of safety of 4.5 shall be applied to all structural members including winch structural components and a minimum factor of safety of 6 shall be applied to falls, suspension chains, links and blocks’’

#5 2008 Intact Stability (IS) Code – anchor handling, towing or lifting operations

The Introduction and Part A of the 2008 IS Code have been amended to include new definitions and clarification about the new criteria. The new criteria require an assessment of the ship’s intact stability when undertaking anchor handling, towing or lifting duties. The new criteria in Part B also require an assessment of the ship’s intact stability when undertaking towing and lifting operations.

Additional constructional matters are included in the amendments to part B of the 2008 IS Code covering the provision of a loading instrument, access to the machinery space, location of freeing ports, winch systems and on deck markings.

The footnote to title of chapter 2, General Criteria, of Part A of IS Code is deleted, to remove any misunderstanding that the referenced regulations of Part B become mandatory via a footnote.

#6 1994 and 2000 HSC Codes

New text to chapter 8 – Life Saving Appliances and Arrangements has been agreed. High-speed craft of less than 30m (2000 HSC Code) and 20m (1994 HSC Code) in length may be exempted from carrying a rescue boat, provided that the requirements in the sub-paragraphs of are fulfilled, and provided a person can be rescued from the water in a horizontal or near-horizontal body position (MSC.1/Circ.1185/Rev.1).

#7 2009 MODU Code – Installations in hazardous areas, Fire Safety, LSA and Operational procedures

Chapters 1, 6, 8, 9, 10, 13 and 14 of the 2009 MODU Code have been amended. As per MSC.435(98),  revisions to the text include defining the ‘H’ class fire protection standard, changes to the required drills, provision of a dedicated rescue boat and allowing multiple fixed monitors to be used as an alternative to the drill floor fixed pressure water-spraying system.

#8 IGC Code – Stability PC

An approved stability instrument capable of verifying compliance with the applicable intact and damage stability requirements is to be fitted onboard. The approval generally applies to the software using MSC.1/Circ.1229, but it may include hardware. This resolution revises the model form of the Certificate of Fitness for Carriage of Liquefied Gases in Bulk to reflect confirmation of this instrument or an accepted alternative during surveys.

#9 BCH & IBC Code – Stability PC

An approved stability instrument capable of verifying compliance with the applicable intact and damage stability requirements is to be fitted onboard. The approval generally applies to the software using MSC.1/Circ.1229, but it may include hardware. This resolution revises the model form of the Certificate of Fitness for Carriage of Dangerous Chemicals in Bulk to reflect confirmation of this instrument or an accepted alternative during surveys.

#10 FTP Code Revision – Fire protection provisions

The Code for Application of Fire Test Procedures, 2010, was revised by resolution MSC.437(99) to be consistent with SOLAS Chapter II which applies the same fire protection provisions for exposed floor coverings on passenger ships carrying not more than 36 passengers with those carrying more than 36 passengers.

#11 FSS Code Chapter 13 – Arrangement of Means of Escape

A revision has been made to distribution of persons, case 2 for passenger ship evacuation analysis, for the purpose of clarifying the distribution of crew in public places. In particular, MSC.410(97) mentions that ‘’Passengers in public spaces occupied to 3/4 of maximum capacity, 1/3 of the crew distributed in public spaces; service spaces occupied by 1/3 of the crew; and crew accommodation occupied by 1/3 of the crew’’

#12 International Maritime Dangerous Goods Code – Amendment 39-18

The IMDG Code amends the following classification categories:

  • Class 1: Explosives – hazard divisions for packages containing pyrotechnic substances are revised.
  • Class 3: Flammable liquids – the marking, labelling and testing of packages containing viscous liquids are revised.
  • Class 4: Flammable solids – revision of the classification of self-reactive substances.
  • Class 5: Oxidizing substances and organic peroxides – packing instructions and methods are revised. Class 8: Corrosive substances – a completely new Chapter 2.8 is adopted.
  • Class 9: Miscellaneous dangerous substances and articles, and environmentally hazardous substances – the marking and packaging of lithium batteries are consolidated. MSC.1/Circ.1588 recommends voluntary application of the amendments as of January 1, 2019.

#13 BCH Code – Model Form of Certificate of Fitness

Revised text has been added to the model form to correlate with recent amendments to paragraph 2.2.6 of the Code, which requires provision of an approved stability instrument onboard, or other approved methods for ensuring safe loading of cargoes.

#14 IBC Code- Model Form of Certificate of Fitness

Revised text has been added to the model form to correlate with recent amendments to paragraph 2.2.6 of the Code, which requires provision of an approved stability instrument onboard, or other approved methods for ensuring safe loading of cargoes.

#15 SPS Code Revisions

The form of the Record of Equipment for Compliance with the SPS Code (Form SPS) has been revised in the “Radio Facilities” section, to refer to the use of a “Recognized mobile satellite service ship earth station”, rather than referring to a “Inmarsat ship earth station”.

MARPOL Amendments

#1 Sulphur Content in Fuel Oil (MARPOL VI Regulation 14)

Sulphur content of any fuel oil used on board ships outside of Sox Emission Control Areas (Global Cap) shall not exceed 0.5% m/m on or after 1 January 2020.

#2 Ozone-depleting substances, Hydro chlorofluorocarbon (HCFC) Refrigerants (MARPOL Annex VI)

According to MEPC.176(58), regulation 12 of MARPOL Annex VI states that installations which contain hydro chlorofluorocarbons shall be prohibited:

  • On ships constructed on or after 1st January 2020 or
  • In the case of ships constructed before 1st January 2020 which have a contractual date of the equipment to the ship on or after 1st January 2020, or in the absence of a contractual delivery date, the actual delivery of the equipment to the ship on or after 1st January 2020. However, this does not apply to permanently sealed equipment where there are no refrigerant charging connections or potentially removable components containing ozone depleting substances.

#3 Energy Efficiency Design Index (EEDI) (New Chapter 4 of MARPOL Annex VI)

The CO2 reduction level includes three phases; Phase 2 starts on 01/01/2020.

The new chapter 4 Regulations on energy efficiency for ships to MARPOL Annex VI, makes mandatory the Energy Efficiency Design Index (EEDI), for new ships, and the Ship Energy Efficiency Management Plan (SEEMP) for all ships. Other amendments to Annex VI add new definitions and the requirements for survey and certification, including the format for the International Energy Efficiency Certificate.

EEDI reflects the amount of CO2 generated per tonne-mile (cargo carrying capacity). It constitutes a uniform approach to calculating a ship’s energy efficiency during design and building of new ships and will be used to control CO2 levels emitted for future ships by encouraging improvements in ship design.

#4 Ship Fuel Oil Consumption Database Guidelines (MARPOL VI)

These 2017 Guidelines provide guidance to assist:

  • Administrations in developing their program to verify ship’s fuel oil consumption data
  • The IMO Secretariat on the development and management of the IMO Ship Fuel Oil Consumption Database, and describe methods that will be used to anonymize ship data to ensure the completeness of the database.

Other Regulations

#1 At Berth Ocean Going Vessels Regulation

Regulation applies to container-ship, passenger-ship, and refrigeratedcargo ship fleets that visit the same California port at least:

  1. 25 times per year for container-ship and refrigerated cargo ship or
  2. 5 times per year for passenger ships.

Two options for compliance are provided:

  • Reduced onboard generation option: 80% of the fleet’s port visits must comply with regulations specifying a 3 hour or 5 hour total limit (dependent on power arrangements in port) for auxiliary diesel engine use while berthed.
  • Equivalent emissions reduction option: NOx and particulate matter emissions must be reduced by 80% from the fleet’s baseline.

#2 IRNSS performance standards [from 1st of July, 2020]

IRNSS is compatible with other navigation satellite systems worldwide. It comprises three major components: space segment, ground control segment and user terminals. According to MSC.449(99), the IRNSS receiver equipment should include the following minimum facilities:

  1. antenna capable of receiving IRNSS signals;
  2. IRNSS receiver and processor;
  • means of accessing the computed latitude/longitude position;
  1. data control and interface; and
  2. position display and, if required, other forms of output

#3 Ballast Water Management System Code Approval  [from 28th of October, 2020)

5 years later, with endless discussions, negotiations and multiple revisions of the G8, the IMO decided that a new BWMS Code (which is a revised G8) is to become mandatory for all BWMS that will be installed onboard ships after 28 October 2020. This means that in order to install a BWMS after 28 October 2020, that BWMS must be type approved following the BWMS Code.

Namely, BWM systems are to be approved in accordance with the new Code for Approval of BWMS, which incorporates and is technically consistent with the 2016 G8 Guidelines. Upon entry into force of the BWMS Code, the 2016 G8 Guidelines will be revoked. BWM systems installed before 28 October 2020 may be approved taking into account the earlier G8 Guidelines developed by the IMO.

Why IMO number is important for vessels?

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The IMO Ship Identification Number is a unique seven-digit number which remains unchanged through a vessel’s lifetime and is linked to its hull, regardless of any changes of names, flags, or owners.

In fact, the IMO number is a unique seven digit number that is assigned to propelled, sea-going merchant ships of 100 GT and above upon keel laying, with the exception of ships without mechanical means of propulsion; pleasure yachts; ships engaged on special service, such as lightships; hopper barges; hydrofoils, air cushion vehicles; floating docks and structures classified in a similar manner; ships of war, troopships as well as wooden ships.

The IMO number is a mandatory prerequisite for sailing through the SOLAS regulation XI/3 which was adopted in 1994; in fact, specific criteria for passenger ships of 100 gross tonnage and upwards and all cargo ships of 300 gross tonnage and upwards were agreed. Further to this, the records based on the IMO number also require an independent audit trail for each vessel.

The scheme was further applied to fishing vessels in 2013, and the eligibility criteria were amended in 2016 to cover smaller and non-steel hull vessels. In particular, the IMO number is assigned to the total portion of the hull enclosing the machinery space and can play the determining factor, should additional sections be added.

For new vessels, the IMO number is assigned to a hull during construction, generally upon keel laying. The SOLAS regulation XI-1/3 requires ships’ identification numbers to be permanently marked in a visible place either on the ship’s hull or superstructure. Passenger ships should carry the marking on a horizontal surface visible from the air and vessels should also be marked with their ID numbers internally.

This number remains unchanged and is never reassigned regardless of any changes concerning the ship’s owner, country of registration, name or transfer to other flags and should be inserted in the ship’s certificates. It is also important to note that this number is separate and different from the official number issued by the vessel’s flag administration which is only internally used and cannot replace the IMO number.

IMO notes that the IMO ship identification number scheme, which was introduced in 1987 through adoption of resolution A.600(15), can act as a measure aimed at enhancing “maritime safety, and pollution prevention and to facilitate the prevention of maritime fraud.” It aims at assigning a permanent number to each ship for identification purposes.

IMO numbers can be an essential tool in shipping because they help to improve monitoring, control, surveillance and enforcement of operations, as they allow flag states to accurately manage vessels under their authority; give national authorities information to help them police their waters more effectively; bring clarity and consistency to legal records; and help governments determine whether vessels are authorized to be in their waters.

All in all, having an IMO number is a prerequisite for selling and can be the best way to track and locate a vessel’s history since each number is unique and is the only identification that remains with a vessel from shipyard to scrapyard, regardless of all other modifications. Indeed, the IMO number is recognized by most governments and regional fisheries organizations and is considered the best available global identification system for ships.

IMO Navigation Rules at Straits of Malacca and Singapore

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Vessels navigating in the Straits of Malacca and Singapore are required to comply with the ‘Rules For Vessels Navigating Through the Straits of Malacca and Singapore’ adopted by the IMO Maritime Safety Committee 69 in 1998, in accordance with the provision of Resolution A.858(20), the MPA Singapore reminded.

In a new Port Marine Circular, the Maritime and Port Authority of Singapore reiterated to Masters and Bridge Resource Management teams, in particular those on board deep draught vessels (DDVs1 ) and very large crude carriers (VLCCs2 ) transiting in the westbound lane of the Traffic Separation Scheme and precautionary areas of the Singapore Strait, shall:

a) Allow for an under keel clearance of at least 3.5 metres at all times during the entire passage through the Straits of Malacca and Singapore.

b) As far as it is safe and practicable, proceed at speed of not more than 12 knots over grounds in the westbound lanes between positions 01°12·51’N, 103°52·15’E and 01°11·59’N, 103°50·21’E and between position 01°11·13’N 103°49·08’E and 01°08·65’N, 103°44·30’E. (Between South of St John’s Island to Raffles Lighthouse).

The IMO Circular SN/Cir.198 provides information on the ‘Rules For Vessels Navigating Through the Straits of Malacca and Singapore’:

  • Rule 1: Eastbound deep draught vessels shall use the designated deep-water routes.
  • Rule 2: Eastbound deep draught vessels navigating in the deep-water routes in Phillip Channel and Singapore Strait shall as far as practicable, avoid overtaking.
  • Rule 3: All vessels navigating within the traffic separation scheme shall proceed in the appropriate traffic lane in the general direction of traffic flow for that lane and maintain as steady a course as possible, consistent with safe navigation.
  • Rule 4: All vessels having defects affecting operational safety shall take appropriate measures to overcome these defects before entering the Straits of Malacca and Singapore.
  • Rule 5: In the event of an emergency or breakdown of a vessel in the traffic lane, the vessel shall, as far as practicable and safe, leave the lane by pulling out to the starboard side.
  • Rule 6:

(a) Vessels proceeding in the westbound lane of the traffic separation scheme “In the Singapore Strait” when approaching Raffles Lighthouse shall proceed with caution, taking note of the local warning system, and, compliance with Rule 18(d) of the International Regulations for Preventing Collisions at Sea, 1972, avoid impeding the safe passage of a vessel constrained by her draught which is exhibiting the signals required by Rule 28 and which is obliged to cross the westbound lane of the scheme in order to approach the single point mooring facility (in approximate position 01°11·42’N, 103°47·40’E, from Phillip Channel).
(b) Vessels proceeding in the traffic separation schemes when approaching any of the precautionary areas shall proceed with caution, taking note of the local warning system, and, in compliance with Rule 18 (d) of the International Regulations for Preventing Collisions at Sea, 1972, avoid impeding the safe passage of a vessel constrained by her draught which is exhibiting the signals required by Rule 28 and which is obliged to cross that precautionary area.
(c) Information relating to the movement of ships constrained by their draught as referred to in paragraphs (a) and (b) above will be given by radio broadcasts. The particulars of such broadcasts are promulgated by Notices to Mariners. All vessels navigating in the area of the traffic separation scheme should monitor these radio broadcasts and take account of the information received.

  • Rule 7: VLCCs and deep draught vessels navigating in the Straits of Malacca and Singapore shall as far as it is safe and practicable, proceed at a speed of not more than 12 knots over the ground in the following areas: a) At One Fathom Bank traffic separation scheme ; b) Deep-water routes in the Phillip Channel and in Singapore Strait; and c) Westbound lanes between positions 01°12·51’N, 103°52·15’E and 01°11·59’N, 103°50·21’E and between position 01°11·13’N 103°49·08’E and 01°08·65’N, 103°44·30’E.
  • Rule 8: All vessels navigating in the routeing system of the Straits of Malacca and Singapore shall maintain at all times a safe speed consistent with safe navigation, shall proceed with caution, and shall be in a maximum state of manoeuvring readiness.
  • Rule 9: (a) Vessels which are fitted with VHF radio communication are to participate in the ship reporting system adopted by the Organization. (b) VLCCs and deep draught vessels navigating in the Straits of Malacca and Singapore are advised to broadcast, eight hours before entering the traffic separation schemes, navigational information giving name, deadweight tonnage, draught, speed and times of passing One Fathom Bank Lighthouse, Raffles Lighthouse and Horsburgh Lighthouse. Difficult and unwieldy tows are also advised to broadcast similar information.
  • Rule 10: All vessels navigating in the Straits of Malacca and Singapore are requested to report by radio to the nearest shore authority any damage to or malfunction of the aids to navigation in the Straits, or any aids out of position in the Straits.
  • Rule 11: Flag States, owners and operators should ensure that their vessels are adequately equipped in accordance with the appropriate international conventions/recommendations.