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 Meeting of the IMO Sub-Committee on Flag State Implementation (FSI) 


The 20th session of the IMO Sub-Committee on Flag State Implementation (FSI) was held from 26 to 29 March 2012.

Among the issues considered at the session were the following:

The IMO Instruments Implementation Code

Prior to the meeting, the IMO Secretariat had made a draft IMO Instruments Implementation Code as well as a draft plan of how to make the Code mandatory in each individual IMO convention (SOLAS, MARPOL and Load Line).

At the meeting, agreement was reached about the draft Code as well as a timetable with a view to submitting these for approval by the Maritime Safety Committee (MSC) in May 2012 and the Marine Environment Protection Committee (MEPC) in the autumn of 2012. Thus, the original timetable is followed, which was originally adopted by the IMO Assembly so that the code for implementing mandatory IMO conventions can be made mandatory for all member States from 2015 following the final adoption by the Assembly in 2013.

The current code, which has until now been used in connection with the Voluntary Member State Audit System (VIMSAS), where Denmark was the first country to be IMO-audited in 2006, will still be used when carrying out voluntary IMO audits until the mandatory auditing system enters into force. Since 2005, 74 countries have joined the voluntary auditing system, of which 55 countries had been audited as of 1 February 2012.

The RO Code (Code for Recognized Organizations)

Prior to the meeting, a correspondence group had made a draft code for the recognition and authorization of classification societies (the RO Code). The IMO Secretariat had made a draft timetable for how to make parts of the code (Parts I and II) mandatory by means of the individual IMO conventions (SOLAS, MARPOL and Load Line). Part III on the monitoring of recognized organizations is recommendatory.

After having gone through the drafts, agreement was reached at the meeting to submit a final draft RO Code for approval by the Maritime Safety Committee in May 2012 as well as by the Marine Environment Protection Committee in the autumn of 2012.

The RO Code establishes a number of requirements for what the classification societies must meet if they are to be recognized and authorized to carry out surveys of ships on behalf of flag States.

Accident statistics and investigation

The working group on accident investigation continued its work drawing up updated guidelines for the making of marine accident reports and reporting to the IMO web-based information system GISIS. However, the work was not finalized at the meeting, for which reason it was decided to continue the work in the correspondence group until the next meeting of the Sub-Committee.

Furthermore, the working group considered a paper submitted by the United Kingdom on the fires on the car decks of the ro-ro ferries LISCO GLORIA, COMMODORE CLIPPER and PEARL OF SCANDINAVIA. Experience from these accidents shows that this type of ship, which is not covered by the new regulations on “safe return to port” that entered into force on 1 July 2010, may be especially vulnerable to fire on the car deck, which is normally filled with cargo. The evacuation of passengers in case of a fire on ships berthed where the normal means of access are not available was also debated. It was decided that the above-mentioned correspondence group should carry out further analyses of the accident reports and present the result to the next meeting of the Sub-Committee.

Port State control

The Sub-Committee initiated a revision of the guiding procedures on port State control pursuant to the STCW Convention and the ISM Code, respectively, as a consequence of the amendments to the STCW Convention as well as experience with inspections in connection with the ISM Code. This work is expected to be finalized at the next session of the Sub-Committee.

In addition, the issue of harmonizing the concentrated inspection campaigns worldwide was considered. At the meeting, there was general agreement that differences in the regional port State control regimes meant that a harmonization between the various regions of port State control would not be realistic. Consequently, the concentrated inspection campaigns will still be decided on by each individual regime; however, as so far, in close cooperation with the regions cooperated with (there is, for example, close cooperation between the Paris MoU and the Tokyo MoU).

Furthermore, a number of port State control organizations, among these the Paris MoU, had submitted information about the results of previous years’ inspections, including about the concentrated inspection campaigns. On the basis of the inspections, the Paris MoU, the Tokyo MoU and the US Coast Guard had in cooperation drawn up a joint paper for flag States whose ships had many defects and non-conformities or were detained. The Sub-Committee urged the relevant flag States to make an effort to increase the ships’ safety standards and, furthermore, urged the port State control regimes to contact both the flag States and the recognized organizations with a view to making the relevant parties increase standards.

The implementation of new regulations on ships under construction

In connection with the adoption and subsequent entry into force of new regulations in the SOLAS Convention, the Sub-Committee discussed how these regulations should be applied to ships under construction. Especially when new regulations were being applied to equipment already bought at the entry into force of the new regulations, it could constitute an additional cost in connection with the construction of the ships. As regards life-saving appliances, there was, however, general agreement to propose an interim period of 24 months to the Maritime Safety Committee, so that each individual member State could decide whether it would permit such an interim arrangement or not.