(+30) 2118501121

IMO Archives - SHIP IP LTD


The South African Maritime Safety Authority (SAMSA) has recently published two Marine Notices:

a) No. 8 of 2019, to advise of the global implementation of the MARPOL Annex VI limit of 0.50 mass per cent concentration (0.50% m/m) sulphur content in fuel oil, for all ships, from 1 January 2020; and

b) No. 9 of 2019, which provides a standard format for reporting fuel oil non-availability as provided in regulation 18.2.4 of MARPOL Annex VI that may be used to document if a ship is unable to obtain compliant fuel oil.

The following points may be of particular interest to our members:

1. Ships installed with exhaust gas cleaning systems (scrubbers) can continue to burn high-sulphur bunker fuel from 2020 and comply with the 0.5% sulphur limit and until further notice South Africa accepts all types of approved scrubbers.
2. South Africa has no restrictions on ships using LNG or Marine Biofuels when entering South African waters.
3. The International Bunker Industry Association has expressed confidence that low sulphur fuel oil will be available in South African ports by 1 January 2020.
4. Ships will be required to either use Annex VI compliant fuel oil when operating within South African waters or to install and use scrubbers.
5. If a ship is found not to be in compliance with the standards for compliant fuel oils, SAMSA will be entitled to require the ship to:

◦ present a record of the actions taken to attempt to achieve compliance
◦ provide evidence that it attempted to purchase compliant fuel oil in accordance with its voyage plan, and if it was not available where planned, that attempts were made to locate alternative sources of such fuel oil, and that despite best efforts to obtain compliant fuel oil, no such fuel oil was available for purchase.

6. SAMSA may also verify compliance by any methods available to it including but not limited to sampling and analysing fuel oil from a ship’s fuel oil tanks and lines and sampling and analysing air emissions from a ship’s plume.
7. A ship is unable to procure compliant fuel oil prior to entering South African waters, the master must notify SAMSA and the vessel’s own Flag Administration.

Source: The Standard Club


On 24 January, the IMO issued updated guidelines on fatigue.  This is just another in a long series of band aids that attempt to cover over the problem without providing a solution.  

Fatigue is a long-standing weakness in the maritime industry.  It is recognized as a major or contributing causal factor in the majority of maritime casualties.  As is well-known, fatigue is caused by a lack of sleep and relaxation.  These, in turn, are the result of too few people being tasked with too much work.  Guidance on how to recognize and manage fatigue is meaningless.

The root cause of fatigue among the personnel on merchant vessels is that those vessels are insufficiently crewed.  The minimum manning levels recommended by the IMO and mandated by flag administrations are inadequate and have been so for years.  No one ship operator can afford to crew its vessels above the minimum level because that would put those vessels at an economic disadvantage against its competitors.  All vessels operating in similar trades must increase their crew levels simultaneously.

Attempts at fatigue management
The IMO and the flag administrations have taken a helpful step in addressing the fatigue problem by establishing maximum work hours and minimum rest hours.

In 1997, the IMO adopted major amendments to the International Convention on Standards of Training, Certification, and Watch keeping for Seafarers (STCW Convention), along with the accompanying STCW Code.  Among other things, the Convention stated that each Administration shall, for the purpose of preventing fatigue, establish and enforce rest periods for watch keeping personnel.  The Code was more explicit, stating that watch keepers shall be provided a minimum of 10 hours of rest in any 24-hour period and not less than 70 hours of rest in each seven-day period.  The 2010 Manila Amendments to the STCW Convention and Code, which came into effect on 1 January 2012, expanded the rest requirement to a minimum of 77 hours in any 7-day period.  Administrations are further enjoined to require that records of daily hours of rest of seafarers be maintained in a standardized format to allow for monitoring and verification of compliance by the Administration and during port state control examinations.

The US National Transportation Safety Board (NTSB) has long-recognized the dangers presented by fatigue in the transportation sector.  It stated in a recent report: Because “powering through” fatigue is simply not an acceptable option, fatigue management systems need to allow individuals to acknowledge fatigue without jeopardizing their employment.  Likewise, the UK Maritime and Coastguard Agency (MCA) considers seafarer fatigue to be a potentially serious issue which is detrimental to safety at sea and the health of seafarers.

The Australian Transport Safety Bureau (ATSB) found the following:

Everyone has experienced fatigue at some point, but in the transport industry, where there’s often high pressure to deliver, fatigue can have very real, very dangerous implications.  Fatigue can have a range of adverse influences on human performance, such as slowed reaction time, decreased work efficiency, reduced motivational drive, and increased variability in work performance.  Fatigue can lead to lapses or errors associated with attention, problem-solving, memory, vigilance and decision-making.  Most people generally underestimate their level of fatigue.  Studies have found that people experiencing fatigue are not able to evaluate accurately their own fatigue level or their ability to perform. Instead, they tend to overestimate their abilities.

The time is overdue for flag administrations and port state control regimes to vigorously enforce those record keeping requirements.  There are suspicions that, on many ships, the watch keeping hours are under reported and the hours of rest are over reported.  Only detailed and careful review of those records can reveal the truth.

Crewing Levels
Only when the crewing level of ships is increased to an appropriate level will crew fatigue become manageable.

The IMO should immediately undertake a thoughtful analysis of vessel crewing requirements.  Technological advancements may have reduced the level of physical labor on ships, but it has had minimal impact on work hours.  For example, ECDIS, when operating properly, may have made it easier to identify where a vessel is located.  The watch officer is still expected, nay, required to verify this visually and by radar.  Instruments may tell the engineer that a motor has failed, but repairs must still be done manually.

Vessel owners and operators for years have pushed, successfully, for reductions in minimum crewing levels.  The time has come for flag administrations, port states, and the IMO to push back. Covering over the fatigue problem with yet more management guidance is not a solution.




The International Maritime Organization (IMO) is to address maritime corruption by including the issue in its work programme for the Facilitation Committee.

The decision to include an anti-corruption agenda came at the latest meeting of the IMO’s Facilitation Committee (FAL) in response to a submission from Liberia, Marshall Islands, Norway, United Kingdom, United States and Vanuatu.

The International Chamber of Shipping (ICS) co-sponsored the submission along with a number of other non-governmental organisations (NGOs).

“Corruption erodes trust in government and undermines the social contract. Corruption impedes investment, with consequent effects on growth and jobs. This is a global issue but we all need to work to eradicate corrupt practices,” Guy Platten, Secretary General of the International Chamber of Shipping, said.

According to the Maritime Anti-Corruption Networks anonymous reporting mechanism, which was set up in 2011, there have been over 28,000 incidents already reported.

“We are all aware that corruption in the maritime sector exists in many areas and as we have heard from the document introduction, corrupt practices, particularly with respect to the ship/shore interface, can lead to interruptions to normal operations, can incur higher operational costs for the shipowner and can have an impact on seafarers’ well-being,” Chris Oliver, Nautical Director at the International Chamber of Shipping, said.


In addition to the potential consequences for ship owners and seafarers, it should not be underestimated the impact it can have on trade, investment, social and economic development of ports, local communities and even Member States themselves,” Oliver concluded.




Facilitation (FAL) – enhancing the free flow of trade by ship

8 April 2019 – the electronic data exchange deadline

​Amendments to the Facilitation Convention were adopted in 2016 and they entered into force on 1 January 2017 (read more here).

The FAL Convention amendments make it mandatory for ships and ports to exchange FAL data electronically from 8 April 2019.  There is provision for a transitional period of at least 12 months, during which paper and electronic documents are allowed.

The FAL Convention encourages use of the so-called “single window” concept in which all the many agencies and authorities involved exchange data via a single point of contact. The maritime single window system allows for the streamlining of procedures, via electronic systems, for provision of information related to the arrival, stay and departure of the ship itself, and data on its crew, passengers and cargo, in accordance with the requirements of the FAL Convention.

IMO has been supporting Member States to prepare for electronic data exchange, with national and regional seminars and work shops.

A project is underway in Antigua and Barbuda to develop a  maritime single window. Following the installation of the first, basic system platform in 2018, testing and implementation has begun. If successful, the system, developed by Norway, could potentially benefit other countries of the Caribbean region and be rolled out to other regions of the world.

What is FAL?

When a ship comes in to port it may be the end of a voyage but it’s just the beginning of a whole range of administrative tasks that need to be done.

Customs declarations for cargo and ships’ stores; immigration clearance for crew and passengers and their baggage; import and export permits: these are just the tip of the iceberg. And when the ship leaves, it’s the same process all over again.

This is what we call Facilitation of International Maritime Traffic – or FAL for convenience.

Why does it matter?

FAL matters because, if it goes smoothly, shipments move more quickly, more easily and more efficiently. But if it goes badly, delays, inefficiencies and extra costs are inevitable.

Statistics show that countries with more efficient FAL infrastructure have better import and export figures. There’s a clear link between reducing red tape and competitiveness.

Efficient trade facilitation can help reduce transport costs and thereby contribute to sustainable development.



FAL Convention

A mandatory requirement for national governments to introduce electronic information exchange between ships and ports comes into effect from 8 April 2019. The aim is to make cross-border trade simpler and the logistics chain more efficient, for the more than 10 billion tons of goods which are traded by sea annually across the globe.

The requirement, mandatory under IMO’s Convention on Facilitation of International Maritime Traffic (FAL Convention), is part of a package of amendments under the revised Annex to the FAL Convention, adopted in 2016.

“The new FAL Convention requirement for all Public Authorities to establish systems for the electronic exchange of information related to maritime transport marks a significant move in the maritime industry and ports towards a digital maritime world, reducing the administrative burden and increasing the efficiency of maritime trade and transport,” said IMO Secretary-General Kitack Lim.

The Facilitation Convention encourages use of a “single window” for data, to enable all the information required by public authorities in connection with the arrival, stay and departure of ships, persons and cargo, to be submitted via a single portal, without duplication.

The requirement for electronic data exchange comes into effect as IMO’s Facilitation Committee meets for its 43rd session (8-12 April). Alongside other agenda items, the Committee will continue its ongoing work on harmonization and standardization of electronic messages. Phase one of the review of the IMO Compendium on Facilitation and Electronic business, including the data elements of the FAL Convention is expected to be completed and the revised Guidelines for setting up a single window system in maritime transport are set to be approved.

The Committee will also receive an update on a successful IMO maritime single window project, implemented in Antigua and Barbuda, with Norway’s support. The source code developed for the system established in Antigua and Barbuda will be made available to other interested Member States. A presentation on the system will be made during the Facilitation Committee.


The FAL Convention

The main objective of the IMO’s Convention on Facilitation of International Maritime Traffic (FAL Convention), adopted in 1965, is to achieve the most efficient maritime transport as possible, looking for smooth transit in ports of ships, cargo and passengers.

The FAL Convention, which has 121 Contracting Governments, contains standards and recommended practices and rules for simplifying formalities, documentary requirements and procedures on ships’ arrival, stay and departure.

Under the FAL Committee, IMO has developed standardised FAL documentation for authorities and Governments to use, and the FAL Convention urges all stakeholders to make use of them.


The IMO Standardized Forms (FAL 1-7)
The Facilitation Convention (Standard 2.1) lists the documents which public authorities can demand of a ship and recommends the maximum information and number of copies which should be required. IMO has developed Standardized Forms for seven of these documents.

They are the:

  • IMO General Declaration
  • Cargo Declaration
  • Ship’s Stores Declaration
  • Crew’s Effects Declaration
  • Crew List· Passenger List
  • Dangerous Goods

Five other documents are required, on security, on wastes from ships, on advance electronic cargo information for customs risk assessment purposes, and two additional ones under the Universal Postal Convention and the International Health Regulations.

Under the requirement for electronic data exchange, all national authorities should now have provision for electronic exchange of this information.




IMO Urges Users Of GPS-SPS To Check Their Systems Ahead Of GPS Roll-Over


Maritime users of the Global Positioning System Standard Positioning Service (GPS-SPS) are urged to check their systems ahead of the week counter roll over on 6 April 2019. Some outdated GPS receiver systems may cease to function properly – with potentially serious impacts on navigation.


The roll over occurs because the GPS system transmits time to GPS receivers using a format of time and weeks as a 10-bit value, which started from 6 January 1980, and can only count 1023 weeks. The previous roll over was on 21 August 1999, when systems reset and began counting towards week 1023 again. When the GPS system reaches week 1024, the system will revert back to week zero.


Some GPS receivers are known to be unable to make the transition from week 1023 to 1024. If the GPS receiver is outdated or has not been properly updated, the receiver will revert on 6 April 2019 to reading the week zero as August 1999. The internal clocks of these GPS receivers will experience a lack of absolute reference and may give the wrong time and position or may lock up permanently. Some of these GPS receivers are repairable with upgrades and others will become unusable.

Maritime users are advised to check the status of their receiver with their GPS manufacturer. IMO has issued a safety of navigation circular SN.1/Circ.182/Add.1 warning maritime users to take action for the roll over.

The GPS-SPS has been recognized by IMO as a component of the world-wide radionavigation system since 1996.





  • Flag State contact points for PSC matters, Casualty investigation services and Ships’ inspection services (including Secretariats of Memoranda of Understanding on Port State Control)
  • List of national operational contact points responsible for the receipt, transmission and processing of urgent reports on incidents involving harmful substances, including oil from ships to coastal states (see annex under Related Documents) – From January 2018 onwards, the official version of the updated list will be issued electronically and uploaded here on a quarterly basis (quarterly dates: 31 January, 30 April, 31 July and 31 October)
For ship inspection purposes, the only official version of the List of national operational contact points responsible for the receipt, transmission and processing of urgent reports on incidents involving harmful substances including oil from ships to coastal States annex is the updated version, which is issued electronically on a quarterly basis. The quarterly date for this official version is specified at the top of each page of the above list.
From January 2018 onwards, the quarterly dates for the official version of the updated list will be as follows:
31 January, 30 April, 31 July and 31 October. It will be available on the IMO website and can
be downloaded as stated in paragraph 5. In this connection, the next circular under this title
(MSC-MEPC.6/Circ.17) will be issued on 31 January 2019.


Updates from 1 November 2018 to 31 January 2019

Note: This summary page will appear on the Internet whenever changes or amendments
are received by the Secretariat before the printed copy of the list is re-issued.

Updates from 1 August 2018 to 31 October 2018

Updates from 30 April 2018 to 31 July 2018
Note: This summary page will appear on the Internet whenever changes or amendments
are received by the Secretariat before the printed copy of the list is re-issued.

The following updates are based on information from countries that notified us of additions,changes or amendments to MSC MEPC.6/Circ.16:

Updates as at 30 April 2018
Updates as at 31 January 2018











Autonomous Ships – Rolls-Royce has completed a research project it says demonstrates that the operation of autonomous vessels can meet, if not exceed, current collision avoidance (COLREG) rules.

The MAchine eXecutable Collision regulations for Marine Autonomous Systems (MAXCMAS) project included partners Lloyd’s Register, Warsash Maritime Academy (WMA), Queen’s University Belfast and Atlas Elektronik (AEUK).

The team found that use of newly developed algorithms allowed existing COLREGs to remain relevant in a crewless environment, finding that artificial intelligence-based navigation systems were able to enact the rules to avoid collision effectively, even when approaching manned vessels were interpreting the rules differently.

A key aspect of the research was the use of WMA’s networked bridge simulators. The simulators were used to analyze reactions from the crew when faced with a range of real-world situations and subsequently hone the MAXCMAS algorithms.

Rolls-Royce Future Technologies Group’s Eshan Rajabally, who led the project, said: “Through MAXCMAS, we have demonstrated autonomous collision avoidance that is indistinguishable from good seafarer behavior, and we’ve confirmed this by having WMA instructors assess MAXCMAS exactly as they would assess the human.”

During the development project, Rolls-Royce and its partners adapted a commercial-specification bridge simulator as a testbed for autonomous navigation. This was also used to validate autonomous seafarer-like collision avoidance in likely real-world scenarios. Various simulator-based scenarios were designed, with the algorithms installed in one of WMA’s conventional bridge simulators. This also included Atlas Elektronik’s ARCIMS mission manager Autonomy Engine, Queen’s University Belfast’s Collision Avoidance algorithms and a Rolls-Royce interface.

During sea trials aboard AEUK’s ARCIMS unmanned surface vessel, collision avoidance was successfully demonstrated in a real environment under true platform motion, sensor performance and environmental conditions.

“The trials showed that an unmanned vessel is capable of making a collision avoidance judgment call even when the give-way vessel isn’t taking appropriate action,” said Ralph Dodds, Innovation & Autonomous Systems Programme Manager at AEUK. “What MAXCMAS does is make the collision avoidance regulations applicable to the unmanned ship.”

The MAXCMAS technology and system has been thoroughly tested both at sea and under a multitude of scenarios using desktop and bridge simulators, says Rolls-Royce, proving that autonomous navigation can meet existing COLREG requirements.




The International Maritime Organization answers the questions of Government Europa on how the next generation of autonomous vessels can be regulated to ensure safety for all involved.

With a myriad of emergent new technologies on the horizon of the maritime industry, such as autonomous vessels, it is vital that regulations are established to ensure the safety, security and efficiency of a new generation of ships. In May, the International Maritime Organization (IMO) – responsible for regulating international shipping – initiated its work into analysing the safety, security and environmental aspects of Maritime Autonomous Surface Ships (MASS). Under this, IMO will look towards how such vessels can be addressed under the instruments of the organisation. The International Maritime Organization answers the questions of Government Europa on how the next generation of vessels can be regulated to ensure safety for all involved.

How could autonomous vessels transform Europe’s maritime activities? What kind of issues could it eradicate?

This is not really a question we can answer, as there are many variables in Europe’s maritime activities which are outside IMO’s sphere. IMO, as the global regulatory body, sets the regulations for safe, secure and efficient shipping and for prevention of pollution by ships.

It is important to remember that when we talk about integrating new technologies in shipping, we need to balance the benefits derived from new and advancing technologies against:

  • Safety and security concerns;
  • The impact on the environment;
  • International trade facilitation;
  • The potential costs to the industry; and
  • Their impact on personnel, both on board and ashore.

At 2017’s meeting of the Maritime Safety Committee (MSC), a plan to conduct a series of scoping exercises on MASS was scheduled. As the first stage of that scoping exercise was conducted in May, what safety implications have been identified as a result?

The scoping exercise at the moment is aimed at looking at the current regulations in relation to maritime autonomous surface ships. What we are looking at now is how the rules already adopted could be applied to a ship in various modes of autonomy. So, we are looking at each regulation and seeing whether it would apply to a ship in an autonomous mode, whether it would not apply at all, or do we need to have a new rule specifically for autonomous ships?




Following a lengthy process, the International Maritime Organization’s (IMO) member states finally agreed in April to require international shipping to decarbonize and at least halve its greenhouse gas emissions by 2050.

The agreement includes strengthening design requirements for each ship type, a relative reduction of 40 percent in CO2 emissions by 2030, and at least 50 percent reduction by 2050, and subsequently a path toward a complete phase-out.

Although the members agreed on the goals, concerns were raised over the lack of any clear plan of action to deliver the emissions reductions.

Kirsi Tikka, Executive Vice President, Senior Maritime Advisor, at the American Bureau of Shipping (ABS), in an interview with World Maritime News said that collaboration by all stakeholders as well as sufficient investment in technology development are needed.

“To meet the targets established in the initial IMO strategy for GHG reduction will require considerable development time and financial investment that may not deliver returns in the short term.”

Since the experiences of early adopters of technology in complying with environmental regulations have not always been positive, the industry “is unlikely to adopt new GHG reduction technologies until there is a full proof of functionality and ideally a cost/benefit analysis.”
Kirsi Tikka, Executive Vice President, Senior Maritime Advisor, ABS
Kirsi Tikka, Executive Vice President, Senior Maritime Advisor, ABS

Tikka continued that financing the R&D needed to deliver on the schedule established by the IMO strategy “will be a challenge for the industry – something of which the IMO is well aware.”

WMN: Would you agree that the compromise on the 50 percent reduction was the best the IMO could do for the moment?

Tikka: Given the apparently high degree of disagreement on strategy between member states going into the meeting it was a very positive result for the IMO, the industry and potentially, the environment. By agreeing to establish a global target for CO2 emissions reductions, the IMO has produced a result in line with the Paris Accords and has sent a clear message that eliminates the need for regional target setting.

Shipowners will start to collect emissions data according to the IMO Data Collection System in January 2019 and this data will provide the foundation for IMO discussions on the final shape of the GHG strategy from 2023, Tikka continued.

Despite the headlines concerning 50% reductions of 2008 levels by 2050, the targets for the greenhouse gas reduction “are not finalized and IMO will use the output from the IMO DCS and the fourth IMO Greenhouse Gas Study (in 2020) to further refine the targets.”

In the meantime, shipowners are probably more focussed on the implications of 2020 in terms of fuel strategy and operational profile, Tikka said.

“The IMO GHG agreement raises a lot of questions, to which there are for the moment, few answers: what kind of technology will be available? What fuel strategy – conventional or alternative – should they choose and what propulsion system will offer the best option?”


WMN: What is your take on the available solutions on the market? What is the way forward: alternative fuels, scrubbers or maybe innovative ship designs?

Tikka: I agree that there is a need for significant system and service development to transfer some of today’s promising technology into solutions that can be implemented and applied. These include fuel cell and battery technology, wind and solar power assistance and new fuels such as Gas-To-Liquids, methanol from biomass and other biofuels, but few are ready to go on the kind of scale needed to meet the GHG targets.

Vessel designs have already been optimized for economic efficiency in recent years and a step change in efficiency would require a radically different approach to design and/or use of materials. Since it is not feasible to replace the world fleet by 2030, we will need other fuel and operational measures such as optimizing speed for on-time arrival at port, to supplement any advances in design.

Speaking on the impact of CO2 reduction decision on ship speeds, Tikka informed that vessel speed has “a significant impact on required power and therefore on fuel consumption and CO2 emissions.”

As a result, ships in sectors that typically operate at higher speed “are likely to work at lower operational speeds in future. And maybe more importantly these speeds will need to be optimized for the most efficient utilization of the vessel in the logistics chain rather than the traditional approach of specifying the speed in the charter party.”

Tikka said that addressing the CO2 requirements “will certainly take a holistic approach across the industry.”

The leveraging of more real-time and accurate vessel performance data will form an integral aspect of achieving these improved efficiencies. Digital technology and improved connectivity will offer tools not only for reporting and improving vessel performance but also for optimizing the wider logistics chain, Tikka concluded.