Good Afternoon All
Comments due by 19 December 2018.
You are receiving this email because AMSA has identified you as stakeholders for consultation in developing Australian delegation brief for the 6th session of IMO Sub-Committee on Ship Design and Construction (SDC 6) scheduled to be held from 040 - 08 February 2018 at IMO’s London headquarters. I have been circulating emails to you from the IMO intersessional correspondence group developing new mandatory instruments for safety of vessels carrying more than 12 industrial personnel (IP) on international voyages. SDC 6 will consider the report of the correspondence group. AMSA has significant interest in the work and has been actively engaged in this work.
On instruction from the Maritime Safety Committee (MSC) of IMO, SDC commenced work on developing a new SOLAS chapter XV and a mandatory code providing safety standards for vessels carrying more than 12 IP on international voyages. As a coastal State, Australia experiences a large number of foreign vessels carrying hundreds of so called IP to Australian offshore energy sector whose flag States do not 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. So we participated all working and intersessional correspondence groups since SDC 4, developing the new SOLAS chapter XV and the associated IP Code where made important contributions.
I am circulating the report of the correspondence group submitted to SDC 6 under this agenda item for your perusal and comments. As more documents (if submitted) are published by IMO, I will continue to circulate them progressively for your comments and inputs to the Australian delegation brief. AMSA will lead the Australian delegation at SDC 6 and will participate in a working group expected to be established during the meeting to progress the work. Outcome of this work will affect relevant stakeholders in the industry especially those who may be involved in construction and operation of vessels transporting industrial personnel to offshore energy sector. So your inputs will be valuable for us to take a position at SDC 6 that will serve Australia’s interest best.
SDC 6/6/1 – Report of the correspondence group (Norway)
This document reports on the outcome of the work carried out by the correspondence group that includes the draft new SOLAS chapter XV (Annex 1) and draft IP Code (Annex 2) so far developed by the group which will be further considered at SDC 6. Actions requested of the Sub-Committee are listed under paragraph 19 and you are invited to comment on the relevant sub-paragraphs.
MSC 99 decided that "the aggregated total maximum number of passengers, industrial personnel and special personnel which may be carried on board in order not to require compliance with the new code should be 12". While this gives the threshold of total number of different categories of persons that can be carried on board before the IP Code kicks in, it is not clear whether same aggregated total number should be considered for all different thresholds for requirements in the IP Code. At the same time, some members of the correspondence group questioned the inclusion of special personnel (SP) and passengers (in the threshold of 12) for application of the IP Code as originally it was meant for carriage of IP only. In AMSA, we believe SP are no different from IP and would like to see them included in the aggregate or to be more specific the definition of IP should capture SP. This will effectively bring all special purpose ships under the application of the IP Code ensuring their safety standards as SPS Code is practically dysfunctional internationally. Please refer to paragraph 6 and 19.1.
The other issue on which Australia has to take a position is detailed in paragraph 16. We concur with the group’s view to send relevant parts of the draft IP Code to appropriate sub-committees for their consideration and advice. And this should be done on priority basis so that there is no unnecessary delay in finalising the Code.
Any general comments on draft new SOLAS chapter XV and the draft IP Code are also welcome.
PRINCIPAL ADVISOR VESSEL SAFETY
82 Northbourne Avenue, Braddon ACT 2612
GPO BOX 2181, Canberra ACT 2601
p +61 2 6279 5650
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m +61 411 231 316
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