Dear All
 
SDC 4/8/1 – submitted by the US
Further to my below email sent on 9 December 2016, another document (SDC 4/8/1) has just been published by IMO submitted by the US on the subject. Commenting on document SDC 4/8 submitted by Germany, the US extended its general support on the draft format and text provided by Germany in the Annex of SDC 4/8. The US rightfully envisages that a correspondence group will be established at SDC 4 to develop the mandatory code addressing safety of more than 12 industrial personnel carried on international voyages. The  US has supported the basic lay out and general structure of the draft code proposed by Germany in SDC 4/8. However, it has also suggested some changes in the format and organization of the draft code. Finally the US has proposed the draft terms of reference for the correspondence group expected to be established at SDC 4. Generally I can support the proposed terms of references which needs more considerations. What they missed to include in the draft terms of reference is the development of the necessary SOLAS amendment to give effect to the code.
 
I am attaching this document (SDC 4/8/1) along with the documents I sent previously for your ready reference.
 
Considering the time constraints, I would much appreciate if you can send your valuable comments by Wednesday the 25 January 2017. Any comments on SDC 4/8 is still welcome by this date.
 
Regards
 
Zaman Qamruzzaman
PRINCIPAL ADVISOR VESSEL SAFETY
VESSEL STANDARDS
STANDARDS
 
82 Northbourne Avenue, Braddon ACT 2612
GPO BOX 2181, Canberra ACT 2601
p +61 2 6279 5650
f +61 2 6279 5966
m +61 411 231 316
e
w www.amsa.gov.au

Dear All
 
Fourth session of the IMO Sub-Committee on Ship Design and Construction (SDC 4) is scheduled to be held from 13 – 17 February 2017 at IMO’s London headquarters. As part of preparing the brief for Australian delegation, we will be circulating documents submitted to the meeting that may have your interest. As always, the timing of this SDC 4 meeting is not great because bulk of the documents will be published by IMO over our Christmas/New Year holiday period. This is something we don’t have any control over and have been living with it. This also means we may not be able to give the time we would like to give for your comments. We appreciate the fact that pre and post Christmas shutdown period is not the best time for anybody to get engaged in our consultation process. Nevertheless, we value your comments and your engagement have been helping us taking positions at IMO meetings to protect Australian interest. This email is the first one in a series of emails you can expect to receive on SDC 4 documents until end of January 2017.
 
Agenda item 8 deals with Mandatory instrument and/or provisions addressing safety standards for the carriage of more than 12 industrial personnel on board vessels engaged on international voyages. We have significant interest in this matter.
 
Background
On instruction from the Maritime Safety Committee (MSC) the Sub-Committee (SDC) will commence work on developing a new SOLAS chapter XV and a mandatory code providing safety standards for vessels carrying more than 12 industrial personnel on international voyages. Initially the Sub-Committee was instructed by the Committee (MSC) to develop guideline to address the safety of industrial personnel. Since SDC 1, Australia has been active at both SDC and MSC meetings and participated in all relevant correspondence and working groups. Australia’s position has been to have a mandatory permanent solution rather than a guideline not to allow accommodation barges/vessels carrying a large number of industrial personnel who are more like passengers and still be covered by the guideline. As a coastal State, Australia experiences a large number of foreign vessels carrying hundreds of so called industrial personnel to Australian offshore energy sector whose flag States do not even implement the 2008 Special Purpose Ships (SPS) Code.  This makes it very difficult to regulate them to ensure safety of the personnel who are more like passengers.  Australia submitted documents to MSC 95 and SDC 3 on the matter. MSC 95 agreed on a mandatory solution consistent with Australia’s position. We understand Australia’s industry supports mandatory measures and are keen to be involved in the development of a new mandatory code.

SDC 4/8 (pdf copy attached)
This is the only  document so far that has been published by IMO submitted by Germany under this agenda item. The document conatins the draft text of a new mandatory code addressing the carriage of more than 12 industrial personnel on board vessels engaged on international voyages. In accordance with general agreement at MSC 96, Germany used 2000 HSC Code and 2008 SPS Code  as the basis for development of the proposed draft Code. The draft is not fully developed and some headings are only proposed for populating. It is quite likely that the draft provided in the annex to this document will be used as the base document at SDC 4 to develop the Code.
 
Points to note in the draft Code are:
 
·         Industrial personnel is not directly defined rather require to be meeting the requirements of specific chapters referred. It should be worth noting here that definition of industrial personnel has been the most contentious issue on this matter so far.
·         The structure of the draft Code separates “High speed craft (HSC)” from “Conventional vessels” and applies 2000 HSC Code on the former. Conventional vessels are generally required to comply with SOLAS regulations.
·         Contrary to Australia’s concern, the draft Code doesn’t require HSCs carrying industrial personnel to comply with enhanced fire safety requirements comparable  to SOLAS requirements. Fire safety requirements in 2000 HSC Code were made lower than SOLAS requirements as no enclosed sleeping berths for  passengers were allowed in the Code. Australia has been taking a firm position on this and insisted that fire safety requirements need to be enhanced to SOLAS standards should the industrial personnel be accommodated (sleeping) on HSCs.
 
So far no proposal has been submitted by any on the new SOLAS Chapter.
 
A working group at MSC 97 prepared  a draft  MSC resolution providing Interim recommendations on the safe carriage of more than 12 industrial personnel on board vessels engaged on international voyages and the Committee adopted it. This was done because of some member governments could justify the urgent need for an interim solution while the mandatory instruments are being developed. I am attaching the report of the working group at MSC 97 (MSC 97/WP.7) containing the Interim recommendations for your reference as this may have some impact on the development of the mandatory instruments.
 
Please send your comments by December  23, 2016. Also please let me know if you don’t wish to receive these consultation emails.

Regards
 
Zaman Qamruzzaman
PRINCIPAL ADVISOR VESSEL SAFETY
VESSEL STANDARDS
STANDARDS
 
82 Northbourne Avenue, Braddon ACT 2612
GPO BOX 2181, Canberra ACT 2601
p +61 2 6279 5650
f +61 2 6279 5966
m +61 411 231 316
e
w www.amsa.gov.au

 

4-8 pdf        MSC97-WP7      4-8-1.PDF