IMO MSC 109: Key outcomes

The Maritime Safety Committee (MSC) met for its 109th session at the IMO Headquarters in London from 2 to 6 December 2024, where interim guidelines on the safety of ammonia-fuelled ships were approved. This marks another key step towards the wider adoption of ammonia as a marine fuel.

According to DNV, amendments to the IGC Code to enable the use of ammonia cargo as fuel were adopted while the IGF Code was amended to improve the safety of ships using natural gas as fuel. MSC 109 further approved draft SOLAS amendments to enhance the safety of pilot transfer arrangements, and progress was made on the new safety code for Maritime Autonomous Surface Ships.

Amendments to mandatory instruments

Ammonia cargo as fuel (IGC Code)

MSC 109 adopted amendments to Paragraph 16.9.2 of the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) to enable the use of ammonia as fuel on ammonia carriers. An MSC circular to encourage the voluntary early implementation of the amendments to Chapter 16 was approved. The amendments will enter into force on 1 July 2026.

Safety of ships using natural gas as fuel (IGF Code)

MSC 109 adopted amendments to the International Code of Safety for Ships Using Gases or Other Low-flashpoint Fuels (IGF Code), based on experience with the code since its entry into force in 2017. The amendments include:

• Clarified application provisions
• Alignment with the IGC Code on suction wells for fuel tanks extending below the lowermost boundary of the tank
• Alignment with the IGC Code on discharge from pressure relief valves to discharge to tanks under certain conditions
• Clarified requirements for fire insulation for deck structures in relation to fuel tanks on open deck
• Clarified requirements for hazardous ducts through non-hazardous spaces and vice versa
• Updated requirements for the hazardous zone radius for fuel tank vent mast outlets, increasing to 6 metres for zone 1 and 4 metres for zone 2

The amendments will enter into force on 1 January 2028.

Goal-based new ship construction standards

Goal-based standards (GBS) for the new construction of bulk carriers and oil tankers are, conceptually, the IMO’s rules for class rules. Under the GBS, IMO auditors use guidelines to verify the construction rules for bulk carriers and oil tankers of class societies acting as Recognized Organizations (Resolution MSC.454(100)).

Initial GBS verification of Biro Klasifikasi Indonesia (BKI)

BKI has requested GBS verification of their ship construction rules for bulk carriers and oil tankers. MSC 109 agreed that the BKI rules comply with the GBS, provided non-conformities and observations are rectified and verified in a new audit.

North Atlantic wave data (IACS Recommendation No. 34, Revision 2)

MSC 109 noted that IACS is currently undertaking a review of its Common Structural Rules (CSR) for bulk carriers and oil tankers to reflect advances in data, materials, technologies and calculation methodologies. The CSR are implemented in the individual class rules of the IACS members, which are subject to compliance with the GBS. MSC 109 further noted that IACS has now issued a revision of the North Atlantic wave data to ensure more scientific data as a basis for the rule formulas in the CSR. The new scatter diagram in Revision 2 of IACS Recommendation No. 34 shows the probability of occurrence of different sea states and is based on wave data from advanced hindcast wave models combined with ships’ AIS data for all SOLAS vessels in the period from 2013 to 2020. MSC 109 agreed that an observation from the initial CSR audit in 2015, that the scatter diagram in Revision 1 of IACS Recommendation No. 34 was based on past statistics, was now considered addressed. MSC 109 further invited IACS to provide more information about the assumptions, modelling, and technical background for Revision 2 of IACS Recommendation No. 34, and agreed that the GBS audit of the revision to follow should be carried out in conjunction with the consequential rule changes in the CSR.

Maritime autonomous surface ships (MASS)

The prospect of autonomous ships operating internationally with little or no human intervention has revealed the need for a regulatory framework for such ships, including their interaction and co-existence with conventional manned ships. The current regulatory framework generally assumes manning and human intervention. The IMO has agreed to develop a non-mandatory, goal-based code for cargo MASS, potentially entering into force as a mandatory code upon experience with its application. The purpose of the code is to provide a framework to address both the remote control and the autonomous operation of key functions. The non-mandatory MASS Code is planned to be finalized by 2026, followed by an experience-building phase after its adoption. A mandatory code is expected to enter into force on 1 January 2032, at the earliest. MSC 109 finalized the chapters of the MASS Code on risk assessment, remote operations, and connectivity. The chapters on remote operation and connectivity will apply depending on the mode of operation and the functionality being applied, which, for example, would allow for a manned MASS with a periodically unmanned bridge, without the support of a remote operation centre. The search and rescue obligations of a MASS to assist persons in distress were considered but not concluded. The non-mandatory MASS Code will be progressed in a Correspondence Group until MSC 110 (June 2025).

New technologies and alternative fuels

Identification of gaps in current IMO instruments

MSC 109 continued its consideration of potential alternative fuels and new technologies to support the reduction of GHG emissions from ships from a safety perspective. The intention is to identify safety obstacles, barriers, and gaps in the current IMO instruments that may impede the use of various alternative fuels and new technologies. MSC 109 agreed to add “swappable traction lithium-ion battery containers” to the list of alternative fuels and new technologies. The list already includes fuels and technologies such as ammonia, hydrogen, fuel cell power installations, nuclear power, solar power, wind power, lithium-ion batteries, and supercapacitor energy storage technology. Recommendations to address each of the identified barriers and gaps in the IMO regulatory framework will be considered in a Correspondence Group until MSC 110 (June 2025).

Application of the IGF Code

MSC 109 agreed on draft amendments to SOLAS to clarify that the IGF Code applies to ships using gaseous fuels, whether they are low-flashpoint or not. The term “gaseous fuels” was added to the definitions in SOLAS Regulation II-1/2 and to the application provisions of SOLAS Regulations II-1/56 and 57. The draft amendments are expected to enter into force on 1 January 2027, subject to adoption by MSC 110 (June 2025).

Maritime cyber risk management

MSC 109 recognized the importance of cybersecurity standards for ships and port facilities and invited proposals on the next steps to enhance maritime cybersecurity.

Formal safety assessment

MSC 109 agreed to draft modifications to the Revised FSA Guidelines (MSC-MEPC.2/Circ.12/Rev.2). The draft modifications include an updated threshold for the cost–benefit assessment and improved guidance for the ranking of costefficient risk control options. In addition, the guidelines have been editorially reviewed to increase clarity and take into account experience gained.

Ship systems and equipment

• Life jacket requirements in the High Speed Craft Codes
• Maintenance of inflated rescue boats
• Arrangement of gas-freeing piping/ducts on tankers
• Crowns and casings of machinery spaces of category A
• Secondary means of venting cargo tanks of tankers
• Reliability of essential propulsion components
• Average mass of a person during lifeboat testing
• Retro-reflective materials on life-saving appliances
• Pressure-vacuum valves on cargo tanks in tankers
• Minor correction to MSC.1/Circ.1276/Rev.1
• Correction of references to structural fire protection tables

The amendments are expected to take effect on 1 January 2028.

Navigation, communications, search and rescue – check repo

Digital navigational data system (NAVDAT)

MSC 109 adopted performance standards for the NAVDAT system and amendments to Resolution MSC.509(105) on “Provision of radio services for the Global Maritime Distress and Safety System (GMDSS).” NAVDAT is intended for broadcasting digital data, including maritime safety information (MSI) and search and rescue (SAR)-related information on medium frequency (MF) and high frequency (HF) bands from shore to ships.

Mobile satellite communication services in the GMDSS

MSC 109 approved a revision of the “Criteria for the provision of mobile satellite communication systems in the Global Maritime Distress and Safety System (GMDSS)” (Resolution A.1001(25)) based on experience gained when open for multiple recognized mobile satellite providers in the GMDSS. The new resolution will cover both new and already approved GMDSS Mobile Satellite Service providers. The resolution is expected to be adopted by the Assembly in December 2025 and enter into force immediately thereafter.

Safety of pilot transfer arrangements

MSC 109 approved a draft revision of SOLAS Regulation V/23 and associated performance standards for pilot transfer arrangements. The intention is to ensure safe arrangements for pilots and other personnel embarking and disembarking ships in all conditions of draught and trim.

The draft amendments are expected to enter into force on 1 January 2028, subject to adoption by MSC 110 (June 2025). The requirements will be applied retroactively. A draft MSC circular open for voluntary early implementation of the amendments was approved.

Improvement of security and integrity aspects of AIS

MSC 109 approved a revision of the performance standards for the shipborne Automatic Identification System (AIS) (Resolution MSC.74(69)) to prevent the unauthorized entry or tampering of a ship’s identity information in the AIS.

Validity of radiocommunications equipment

MSC 109 approved a revision of MSC.1/Circ.1460/Rev.4 to clarify that:

•  The mandatory VHF/DSC equipment required by SOLAS Regulation IV/7 on radio equipment (including the required duplicated equipment for maintenance purposes) should comply with the latest channel arrangements in Appendix 18 of the Radio Regulations by the first radio survey scheduled on or after 1 January 2028, or earlier.
• Ships should always be able to communicate with shore facilities in their area of operation, noting that some administrations may already have implemented the new channels.

Carriage of cargoes and containers

Ammonia as fuel

MSC 109 approved draft interim guidelines for the safety of ships using ammonia as fuel.

Ships carrying liquefied gases in bulk (IGC Code)

MSC approved draft amendments to the IGC Code to incorporate the large number of Unified Interpretations developed since the latest major review of the code, which entered into force in 2016. The primary objective of the draft amendments is to remove ambiguity and promote the consistent implementation of the IGC Code requirements.

Implementation of IMO instruments

Lessons learned and analysis of marine safety investigation reports

MSC 109 approved an MSC circular to recommend that national administrations expand requirements for the carriage of AIS and VHF for the domestic fishing fleet to prevent collisions.

Guidance on implementation of Cape Town Agreement

MSC 109 approved interim guidance to support implementation of the Cape Town Agreement. The Cape Town Agreement (CTA) sets minimum requirements on the design, construction, equipment, surveys, and certification of fishing vessels of 24 meters in length and over, or equivalent in gross tonnes. The agreement has now been ratified by 22 states, with a combined fleet of about 2,600 fishing vessels. The number of states is sufficient, but a combined fleet of 3,600 fishing vessels is needed.

Work programme

MSC 109 agreed on the following new work items:

Sub-Committee on Navigation, Communications, Search and Rescue

Very high frequency (VHF) voice communications

MSC 109 agreed to the development of a transition scheme for the introduction of digital technology for VHF voice communications.

S-100 Electronic Chart Display and Information System (ECDIS)

MSC 109 agreed to the development of guidance to establish a framework for data distribution and global IP-based connectivity between shore-based facilities and ships for ECDIS S-100 products.

Any other business

Maintenance of radiocommunication equipment

MSC 109 recalled that the modernization of the GMDSS requirements in SOLAS Chapter IV was not intended to bring substantive changes to the radio installations on existing ships. MSC 109 confirmed that for operating in sea area A3, a single MF/HF radio installation is accepted as a means to comply with the requirements of a primary MF radio installation and a duplicated MF/HF radio installation simultaneously. Footnote 6 of COMSAR.1/Circ.43/Rev.2 was amended to reflect this confirmation.

In addition, the International Maritime Organization (IMO) Secretary – General, Arsenio Dominguez, on his MSC 109 closing remarks highlighted the further progress on the MASS Code where necessary adjustments have been made to the Road Map on the draft MASS Code and expressed his gratitude for the Committee’s diligent efforts to ensure a high-quality Code.

Arsenio Dominguez continued by commenting on the adoption of the resolution on Guidance on implementation of CTA 2012. He said that the Committee adopted the resolution on Interim Guidance to assist in the implementation of the Cape Town Agreement of 2012, which will facilitate the entry into force of the Agreement and provide guidance for unified implementation. Furthermore, the Secretary mentioned the adoption of amendments to mandatory instruments, the adopted amendments to the IGC and the IGF Codes.

Dominguez pointed out the progress on the matter of consideration of new technologies and alternative fuels for the development of a safety regulatory framework to support the 2023 IMO GHG strategy. The Secretary highlighted that further progress on this important matter is expected at the next session. In relation to this, the Interim Guidelines for the safety of ships using ammonia as fuel were approved at the MSC 109 session, based on consideration by CCC 10.

Moreover, on the issue of amendments to the Committees’ Method of Work, the Secretary mentioned the review of the Committee’s Method of Work addressing the workload issue.

I look forward to the positive changes this will introduce in the work of your Committee, and I encourage you to implement these improvements effectively. 

source : safety4sea