NK T1241e

Subject
Summary of the Outcomes of MSC 103
Technical
Information
No. TEC-1241
Date 3 August 2021
To whom it may concern
The 103rd session of the Maritime Safety Committee (MSC 103) was held from 5 to 14 May 2021 as a
web conference due to the pandemic of COVID-19. Since the minutes, resolutions and circulars of the
meeting were recently released from the IMO, a summary of the decisions taken at MSC 103 is
provided as below for your information.
1. Adopted mandatory requirements

Mandatory requirements were adopted at MSC 103 as follows:
(1) Water level detectors on multiple hold cargo ships (See attachment 1)
Amendments to SOLAS regulation II-I/25-1 were adopted to require water level detectors on
multiple hold cargo ships other than bulk carriers and tankers for cargo holds located below
the freeboard deck, and intended for dry cargoes.
Applied: on or after 1 January 2024
(2) Amendments to SOLAS chapter III, LSA Code and resolution MSC.81(70) (See attachment
1, 4, 5)
Amendments to SOLAS regulation III/33, paragraph 4.4.1.3 of LSA Code and the "Revised
recommendation on testing of life-saving appliances" (resolution MSC.81(70), as amended)
were adopted, to exclude free-fall lifeboats from the scope of application of the requirements
to launch lifeboats with the cargo ship of 20,000GT and above making headway at speeds up
to 5 knots in calm water. As for early implementation of the amendments to SOLAS chapter
III and LSA Code, refer to below item 2. (2).
(3) Amendments to 2011 ESP Code (See attachment 2)

Amendments to 2011 ESP Code, which replace the provision of thickness measurements at
the first renewal survey of double hull oil tankers, were adopted.
(To be continued)
NOTES:
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ClassNK Technical Information No. TEC-1241
(4) Amendments to chapter 9 of the FSS Code (See attachment 3)

Amendments to chapter 9 of the FSS Code were adopted in respect of fault isolation
requirements for cargo ships and passenger ship cabin balconies fitted with individually
identifiable fire detector systems.
2. Approved guidelines etc.

The following guidelines etc. were approved during MSC 103.
(1) Amendments to the Guidelines for the maintenance and inspections of fixed carbon dioxide
fire-extinguishing systems (MSC.1/Circ.1318) (See attachment 6)
Amendments to the Guidelines for the maintenance and inspections of fixed carbon dioxide
fire-extinguishing systems (MSC.1/Circ.1318) were approved during MSC 103, aiming to
clarify the hydrostatic testing regime for high-pressure CO2 cylinders.
(2) Early implementation Circular on the amendments to SOLAS chapter III and LSA Code (See
attachment 8)
With regard to above item 1.(2), the Circular to urge Administrations' early implementation
on the amendments to SOLAS chapter III and LSA Code to exclude free-fall lifeboats from
the scope of application of the requirements to launch lifeboats with the cargo ship of
20,000GT and above making headway at speeds up to 5 knots in calm water, was approved.
3. Others
(1) Consideration of requirements for Maritime Autonomous Surface Ships (MASS) (See
attachment 7)
Taking into account recent investigation of automation surrounding a ship, it has been
discussed at MSC on conventional requirements of safety and environmental protection
relating to MASS.
At this session, it was reported that the Regulatory Scoping Exercise (RSE) has been
accomplished. In result of RSE, potential gaps between the current IMO instruments and
requirements for MASS, and priorities for further work, were identified. In conclusion, it
was agreed to consider a separate MASS instrument from existing IMO instruments.
(2) Consideration of safety matters on use of low sulphur fuel

Triggered from the global 0.5% sulphur limit, which entered into force on 1 January 2020,
consideration of safety matters on use of low sulphur fuel was initiated, in order to develop
SOLAS requirements in addition to requirements of MARPOL.
In conclusion at MSC 103, it was agreed to develop mandatory requirements and guidelines
to address situations where the oil fuel supplied may not comply with SOLAS regulation
II-2/4.2.1 with a target completion date of 2023.
(To be continued)
2
For any questions about the above, please contact:
NIPPON KAIJI KYOKAI (ClassNK)

External Affairs Department, Administration Center Annex, Head Office
Address: 3-3 Kioi-cho, Chiyoda-ku, Tokyo 102-0094, Japan
Tel.: +81-3-5226-2038
Fax: +81-3-5226-2734
E-mail: [email protected]
Attachment:
1. RESOLUTION MSC.482(103)
6. MSC.1/Circ.1318/Rev.1
7. MSC.1/Circ.1638
8. MSC.8/Circ.2
3
Attachment 1. to
MSC 103/21/Add.1
Annex 1, page 1
ANNEX 1
RESOLUTION MSC.482(103))
(adopted on 13 May 2021)
AMENDMENTS TO THE INTERNATIONAL CONVENTION FOR THE

SAFETY OF LIFE AT SEA, 1974 (SOLAS 1974)
THE MARITIME SAFETY COMMITTEE,
RECALLING Article 28(b) of the Convention on the International Maritime Organization

concerning the functions of the Committee,
RECALLING ALSO article VIII(b) of the International Convention for the Safety of Life at
Sea, 1974 ("the Convention"), concerning the amendment procedure applicable to the annex
to the Convention, other than to the provisions of chapter I,
HAVING CONSIDERED, at its 103rd session, amendments to the Convention proposed and
circulated in accordance with article VIII(b)(i) of the Convention,
1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to

the Convention, the text of which is set out in the annex to the present resolution;
2 DETERMINES, in accordance with article VIII(b)(vi)(2)(aa) of the Convention, that

the said amendments shall be deemed to have been accepted on 1 July 2023, unless, prior
to that date, more than one third of the Contracting Governments to the Convention, or
Contracting Governments the combined merchant fleets of which constitute not less than 50%
of the gross tonnage of the world's merchant fleet, have notified the Secretary-General of their
objections to the amendments;
3 INVITES Contracting Governments to the Convention to note that, in accordance

with article VIII(b)(vii)(2) of the Convention, the amendments shall enter into force
on 1 January 2024, upon their acceptance, in accordance with paragraph 2 above;
4 REQUESTS the Secretary-General, for the purposes of article VIII(b)(v) of

the Convention, to transmit certified copies of the present resolution and the text of
the amendments contained in the annex to all Contracting Governments to the Convention;
5 REQUESTS ALSO the Secretary-General to transmit copies of this resolution and

its annex to Members of the Organization which are not Contracting Governments to
the Convention.
I:\MSC\103\MSC 103/21/Add.1
MSC 103/21/Add.1
Annex 1, page 2
ANNEX
AMENDMENTS TO THE INTERNATIONAL CONVENTION FOR THE

SAFETY OF LIFE AT SEA, 1974 (SOLAS 1974)
CHAPTER II-1
CONSTRUCTION – STRUCTURE, SUBDIVISION AND STABILITY, MACHINERY
AND ELECTRICAL INSTALLATIONS
Part B-4
Stability management
1 The following new regulation 25-1 is added after existing regulation 25 with the
associated footnotes:
"Regulation 25-1
Water level detectors on multiple hold cargo ships other than bulk carriers and
tankers
1 Multiple hold cargo ships other than bulk carriers and tankers constructed
on or after 1 January 2024 shall be fitted with water level detectors* in each
cargo hold intended for dry cargoes. Water level detectors are not required
for cargo holds located entirely above the freeboard deck.
_____________________________
*
Refer to the Performance standards for water level detectors on bulk carriers and single
hold cargo ships other than bulk carriers (resolution MSC.188(79)), as may be
amended.
2 The water level detectors required by paragraph 1 shall:
.1 give audible and visual alarms at the navigation bridge, one when
the water level above the bottom of the cargo hold reaches a height
of not less than 0.3 m, and another at a height not less than 15% of
the depth of the cargo hold but not more than 2 m; and
.2 be fitted at the aft end of the cargo holds. For cargo holds which are
occasionally used for water ballast, an alarm overriding device may
be installed. The visual alarms shall clearly discriminate between
the two different water levels detected in each hold.
3 As an alternative to the water level detector at a height of not less than 0.3 m
as per sub-paragraph 2.1, a bilge level sensor* serving the bilge pumping
arrangements required by regulation 35-1 and installed in the cargo hold
bilge wells or other suitable location is considered acceptable, subject to:
.1 the fitting of the bilge level sensor at a height of not less than 0.3 m
at the aft end of the cargo hold; and
.2 the bilge level sensor giving audible and visual alarm at the
navigation bridge which is clearly distinctive from the alarm given
by the other water level detector fitted in the cargo hold.
I:\MSC\103\MSC 103/21/Add.1
MSC 103/21/Add.1
Annex 1, page 3
_________________
* Refer to the Performance standards for water level detectors on bulk carriers and single
hold cargo ships other than bulk carriers (resolution MSC.188(79)), as may be
amended."
CHAPTER III
LIFE-SAVING APPLIANCES AND ARRANGEMENTS
Part B
Requirements for ships and life-saving appliances
Regulation 33 – Survival craft embarkation and launching arrangements
1 Paragraph 33.2 is replaced by the following:
"2 On cargo ships of 20,000 gross tonnage and upwards, davit-launched lifeboats
shall be capable of being launched, utilizing painters where necessary, with the ship
making headway at speeds up to 5 knots in calm water."
***
I:\MSC\103\MSC 103/21/Add.1
Attachment 2. to
MSC 103/21/Add.1
Annex 2, page 1
ANNEX 2
RESOLUTION MSC.483(103)
AMENDMENTS TO THE INTERNATIONAL CODE ON THE ENHANCED PROGRAMME

OF INSPECTIONS DURING SURVEYS OF BULK CARRIERS AND OIL TANKERS, 2011
(2011 ESP CODE)

RECALLING ALSO resolution A.1049(27), by which the Assembly adopted the

International Code on the Enhanced Programme of Inspections during Surveys of Bulk
Carriers and Oil Tankers, 2011 ("2011 ESP Code"), which has become mandatory under
chapter XI-1 of the International Convention for the Safety of Life at Sea, 1974
("the Convention"),
RECALLING FURTHER article VIII(b) and regulation XI-1/2 of the Convention concerning the
procedure for amending the 2011 ESP Code,
HAVING CONSIDERED, at its 103rd session, amendments to the 2011 ESP Code proposed
and circulated in accordance with article VIII(b)(i) of the Convention,
1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to

the 2011 ESP Code, the text of which is set out in the annex to the present resolution;
2 DETERMINES, in accordance with article VIII(b)(vi)(2)(bb) of the Convention, that the

said amendments shall be deemed to have been accepted on 1 July 2022 unless, prior to that
date, more than one third of the Contracting Governments to the Convention, or Contracting
Governments the combined merchant fleets of which constitute not less than 50% of the gross
tonnage of the world's merchant fleet, have notified the Secretary-General of their objections
to the amendments;
3 INVITES Contracting Governments to the Convention to note that, in accordance

with article VIII(b)(vii)(2) of the Convention, the amendments shall enter into force
on 1 January 2023 upon their acceptance in accordance with paragraph 2 above;
4 REQUESTS the Secretary-General, for the purposes of article VIII(b)(v) of

the Convention, to transmit certified copies of the present resolution and the text of
the amendments contained in the annex to all Contracting Governments to the Convention;
5 REQUESTS ALSO the Secretary-General to transmit copies of this resolution and

its annex to Members of the Organization which are not Contracting Governments to
the Convention.
I:\MSC\103\MSC 103/21/Add.1
MSC 103/21/Add.1
Annex 2, page 2
ANNEX
AMENDMENTS TO THE INTERNATIONAL CODE ON THE ENHANCED PROGRAMME

OF INSPECTIONS DURING SURVEYS OF BULK CARRIERS AND OIL TANKERS, 2011
(2011 ESP CODE)
ANNEX B
CODE ON THE ENHANCED PROGRAMME OF INSPECTIONS DURING

SURVEYS OF OIL TANKERS
Part A
CODE ON THE ENHANCED PROGRAMME OF INSPECTIONS DURING

SURVEYS OF DOUBLE-HULL OIL TANKERS
ANNEX 2
MINIMUM REQUIREMENTS FOR THICKNESS MEASUREMENTS AT RENEWAL

SURVEYS OF DOUBLE-HULL OIL TANKERS
1 In the table for "Minimum requirements for thickness measurements at renewal

surveys of double-hull oil tankers", the column for "Renewal Survey No.1" is replaced by the
following:
"1 Suspect areas"
***
I:\MSC\103\MSC 103/21/Add.1
Attachment 3. to
MSC 103/21/Add.1
Annex 3, page 1
ANNEX 3
AMENDMENTS TO THE INTERNATIONAL CODE FOR FIRE SAFETY SYSTEMS

(FSS CODE)

RECALLING ALSO resolution MSC.98(73), by which it adopted the International Code for Fire
Safety Systems ("the FSS Code"), which has become mandatory under chapter II-2 of the
International Convention for the Safety of Life at Sea, 1974 ("the Convention"),
RECALLING FURTHER article VIII(b) and regulation II-2/3.22 of the Convention concerning
the procedure for amending the FSS Code,
HAVING CONSIDERED, at its 103rd session, amendments to the FSS Code, proposed and
1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to the

FSS Code, the text of which is set out in the annex to the present resolution;
2 DETERMINES, in accordance with article VIII(b)(vi)(2)(aa) of the Convention, that the

amendments shall be deemed to have been accepted on 1 July 2023 unless, prior to that date,
more than one third of the Contracting Governments to the Convention, or Contracting
tonnage of the world's merchant fleet, have notified their objections to the amendments;
3 INVITES Contracting Governments to note that, in accordance with

article VIII(b)(vii)(2) of the Convention, the amendments shall enter into force
4 REQUESTS the Secretary-General, in conformity with article VIII(b)(v) of the

Convention, to transmit certified copies of the present resolution and the text of the
amendments contained in the annex to all Contracting Governments to the Convention;
5 REQUESTS ALSO the Secretary-General to transmit copies of this resolution and its
annex to Members of the Organization which are not Contracting Governments to the
Convention.
I:\MSC\103\MSC 103/21/Add.1
MSC 103/21/Add.1
Annex 3, page 2
ANNEX
AMENDMENTS TO THE INTERNATIONAL CODE FOR FIRE SAFETY SYSTEMS

(FSS CODE)
CHAPTER 9
FIXED FIRE DETECTION AND FIRE ALARM SYSTEMS
2 Engineering specifications
2.1 General requirements
1 The following new paragraph 2.1.8 is inserted after existing paragraph 2.1.7:
"2.1.8 In cargo ships and on passenger ship cabin balconies, where an individually
identifiable system is fitted, notwithstanding the provisions in paragraph 2.1.6.1,
isolator modules need not be provided at each fire detector if the system is arranged
in such a way that the number and location of individually identifiable fire detectors
rendered ineffective due to a fault would not be larger than an equivalent section in a
section identifiable system, arranged in accordance with paragraph 2.4.1."
***
I:\MSC\103\MSC 103/21/Add.1
Attachment 4. to
MSC 103/21/Add.1
Annex 4, page 1
ANNEX 4
AMENDMENTS TO THE INTERNATIONAL LIFE-SAVING APPLIANCE CODE

(LSA CODE)

RECALLING ALSO resolution MSC.48(66), by which it adopted the International Life-Saving

Appliance (LSA) Code ("the LSA Code"), which has become mandatory under chapter III of
the International Convention for the Safety of Life at Sea, 1974 ("the Convention"),
RECALLING FURTHER article VIII(b) and regulation III/3.10 of the Convention concerning the
procedure for amending the LSA Code,
HAVING CONSIDERED, at its 103rd session, amendments to the LSA Code proposed and
1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to the

LSA Code, the text of which is set out in the annex to the present resolution;
2 DETERMINES, in accordance with article VIII(b)(vi)(2)(aa) of the Convention, that the

amendments shall be deemed to have been accepted on 1 July 2023 unless, prior to that date,
more than one third of the Contracting Governments to the Convention, or Contracting
tonnage of the world's merchant fleet, have notified their objections to the amendments;
3 INVITES Contracting Governments to note that, in accordance with

article VIII(b)(vii)(2) of the Convention, the amendments shall enter into force
4 REQUESTS the Secretary-General, in conformity with article VIII(b)(v) of the

Convention, to transmit certified copies of the present resolution and the text of the
amendments contained in the annex to all Contracting Governments to the Convention;
5
REQUESTS ALSO the Secretary-General to transmit copies of this resolution and its annex to
Members of the Organization which are not Contracting Governments to the Convention.
I:\MSC\103\MSC 103/21/Add.1
MSC 103/21/Add.1
Annex 4, page 2
ANNEX
AMENDMENTS TO THE INTERNATIONAL LIFE-SAVING APPLIANCES CODE

(LSA CODE)
CHAPTER IV
SURVIVAL CRAFT
4.4 General requirements for lifeboats
1 Paragraph 4.4.1.3.2 is replaced by the following:
".2 except for free-fall lifeboats, be capable of being launched and towed when
the ship is making headway at speeds up to 5 knots in calm water."
***
I:\MSC\103\MSC 103/21/Add.1
Attachment 5. to
MSC 103/21/Add.1
Annex 7, page 1
ANNEX 7
AMENDMENTS TO THE REVISED RECOMMENDATION ON

TESTING OF LIFE-SAVING APPLIANCES (RESOLUTION MSC.81(70))

RECALLING ALSO that the Assembly, when adopting resolution A.689(17) on Testing of
life-saving appliances, authorized the Committee to keep the annexed Recommendation on
testing of life-saving appliances under review and to adopt, when appropriate, amendments
thereto,
RECALLING FURTHER that, since the adoption of resolution A.689(17), the Committee has
amended the Recommendation annexed thereto by resolutions MSC.54(66) and MSC.81(70),
and by circulars MSC/Circ.596, MSC/Circ.615 and MSC/Circ.809,
RECOGNIZING the need to ensure that the references in the Revised recommendation on
testing of life-saving appliances (resolution MSC.81(70)) are kept up to date,
1 ADOPTS the Amendments to the Revised recommendation on testing of life-saving

appliances (resolution MSC.81(70)), set out in the annex to the present resolution;
2 INVITES Contracting Governments to the SOLAS Convention to bring the above

amendments to the attention of all parties concerned.
I:\MSC\103\MSC 103/21/Add.1
MSC 103/21/Add.1
Annex 7, page 2
ANNEX
AMENDMENTS TO THE REVISED RECOMMENDATION ON TESTING

OF LIFE-SAVING APPLIANCES (RESOLUTION MSC.81(70))
PART 1– PROTOTYPE TESTS FOR LIFE-SAVING APPLIANCES
5 LIFERAFTS – RIGID AND INFLATABLE
5.17 Additional tests applicable to inflatable liferafts only
Material tests
1 Paragraph 5.17.13.2.2.7.1 is replaced by the following:
".1 Test for porosity
A specimen of the fabric should be prepared and tested in accordance with

ISO 15372:2000, paragraph 6.2.9.2."
2 Amend paragraph 5.17.13.2.2.8, as follows:
".2.2.8 Oil resistance
.1 When tested by the method prescribed below, after exposing the

outer surface to oil IRM 901, for 2 h at 20± 2°C, there should be no
separation of coating from textile and no residual tackiness when
two exposed faces are pressed together. The coating should not
smear when rubbed with a single pass of the finger.
.2 The test should be carried out not less than 16 h after vulcanization
or curing.
.3 The apparatus, preparation of specimens and test procedure

should be in accordance with ISO 15372:2000/Amd 1:2021,
paragraph 6.2.5. Each coated face should be tested."
11 HYDROSTATIC RELEASE UNITS
11.2 Technical tests
3 Paragraph 11.2.5.5.3 is replaced by the following:
".5.3 Test for surface resistance to oil
Number of specimens 2 membranes

Temperature +18°C to +20°C
Type of oil A mineral oil meeting the following
requirements:
Aniline point: 120 ± 5°C
Flashpoint: minimum 240°C
Viscosity: 10–25 cSt at 99.0°C
I:\MSC\103\MSC 103/21/Add.1
MSC 103/21/Add.1
Annex 7, page 3
The following oils may be used: IRM 901

IRM 905
ISO Oil No. 1
Testing period: 3 h on each side

Requirements: The material should show no
deterioration."
PART 2 – PRODUCTION AND INSTALLATION TESTS
5 SURVIVAL CRAFT
5.4 Launch test
4 Paragraph 5.4 is replaced by the following:
"Except in the case of a free-fall lifeboat, it should be demonstrated that the fully
equipped lifeboat on cargo ships of 20,000 gross tonnage and upwards and rescue
boat can be launched from a ship proceeding ahead at a speed of not less than
5 knots in calm water and on an even keel. There should be no damage to the lifeboat
or the rescue boat or their equipment as a result of this test."
***
I:\MSC\103\MSC 103/21/Add.1
Attachment 6. to
4 ALBERT EMBANKMENT
LONDON SE1 7SR
Telephone: +44 (0)20 7735 7611 Fax: +44 (0)20 7587 3210
MSC.1/Circ.1318/Rev.1
25 May 2021
REVISED GUIDELINES FOR THE MAINTENANCE AND INSPECTIONS OF

FIXED CARBON DIOXIDE FIRE-EXTINGUISHING SYSTEMS
1 The Maritime Safety Committee, at its eighty-sixth session (27 May to 5 June 2009),
having considered the proposal by the Sub-Committee on Fire Protection, at its fifty-third
session, approved Guidelines for the maintenance and inspections of fixed carbon dioxide
fire-extinguishing systems (MSC.1/Circ.1318).
2 In order to address the need to clarify the hydrostatic testing regime for high-pressure
CO2 cylinders and to align the relevant requirements in the Guidelines with those in the Revised
guidelines for the maintenance and inspection of fire protection systems and appliances
(MSC.1/Circ.1432), the Committee, at its 103rd session (5 to 14 May 2021), approved
amendments to the above-mentioned Guidelines, prepared by the Sub-Committee on Ship
Systems and Equipment, at its seventh session, with a view to dissemination as
MSC.1/Circ.1318/Rev.1. The text of the Revised guidelines for the maintenance and
inspections of fixed carbon dioxide fire-extinguishing systems is set out in the annex.
3 Member Governments are invited to apply the annexed Revised guidelines when
inspecting fixed carbon dioxide fire-extinguishing systems on board all ships and bring them
to the attention of ship designers, shipowners, equipment manufacturers, and other parties
concerned.
4 This circular supersedes MSC.1/Circ.1318.
***
I:\CIRC\MSC\1\MSC.1-Circ.1318-Rev.1.docx
Annex, page 1
ANNEX
REVISED GUIDELINES FOR THE MAINTENANCE AND INSPECTIONS

OF FIXED CARBON DIOXIDE FIRE-EXTINGUISHING SYSTEMS
1 General
These Revised guidelines provide the minimum recommended level of maintenance and
inspections for fixed carbon dioxide fire-extinguishing systems on all ships and are intended to
demonstrate that the system is kept in good working order as specified in SOLAS
regulation II-2/14.2.1.2. These Revised guidelines are intended to supplement the
fire-extinguishing system manufacturer's approved maintenance instructions. Certain
maintenance procedures and inspections may be performed by competent crewmembers,
while others should be performed by persons specially trained in the maintenance of such
systems. The onboard maintenance plan should indicate which parts of the recommended
inspections and maintenance should be completed by trained personnel.
2 Safety
Whenever carbon dioxide fire-extinguishing systems are subjected to inspection or

maintenance, strict safety precautions should be followed to prevent the possibility that
individuals performing or witnessing the activities are placed at risk. Prior to performing any
work, a safety plan should be developed to account for all personnel and establish an effective
communications system between the inspection personnel and the on-duty crew. Measures to
avoid accidental discharges such as locking or removing the operating arms from directional
valves, or shutting and locking the system block valve should be taken as the initial procedure
for the protection of personnel performing any maintenance or inspections. All personnel
should be notified of the impending activities before work is begun.
3 Maintenance and inspection plan
Fixed carbon dioxide fire-extinguishing systems should be kept in good working order and
readily available for immediate use. Maintenance and inspections should be carried out in
accordance with the ship's maintenance plan having due regard to ensuring the reliability of
the system. The onboard maintenance plan should be included in the ship's safety
management system and should be based on the system manufacturer's recommendations
including:
.1 maintenance and inspection procedures and instructions;
.2 required schedules for periodic maintenance and inspections;
.3 listing of recommended spare parts; and
.4 records of inspections and maintenance, including corrective actions taken

to maintain the system in operable condition.
Annex, page 2
4 Monthly inspections
4.1 At least every 30 days a general visual inspection should be made of the overall
system condition for obvious signs of damage, and should include verification that:
.1 all stop valves are in the closed position;
.2 all releasing controls are in the proper position and readily accessible for
immediate use;
.3 all discharge piping and pneumatic tubing is intact and has not been
damaged;
.4 all high-pressure cylinders are in place and properly secured; and
.5 the alarm devices are in place and do not appear damaged.
4.2 In addition, on low pressure systems the inspections should verify that:
.1 the pressure gauge is reading in the normal range;
.2 the liquid level indicator is reading within the proper level;
.3 the manually operated storage tank main service valve is secured in the open
position; and
.4 the vapour supply line valve is secured in the open position.
5 Annual inspections
The following minimum level of maintenance and inspections should be carried out in
accordance with the system manufacturer's instructions and safety precautions:
.1 the boundaries of the protected space should be visually inspected to confirm

that no modifications have been made to the enclosure that have created
uncloseable openings that would render the system ineffective;
.2 all storage containers should be visually inspected for any signs of damage,
rust or loose mounting hardware. Cylinders that are leaking, corroded,
dented or bulging should be hydrostatically retested or replaced;
.3 system piping should be visually inspected to check for damage, loose

supports and corrosion. Nozzles should be inspected to ensure they have
not been obstructed by the storage of spare parts or a new installation of
structure or machinery;
.4 the manifold should be inspected to verify that all flexible discharge hoses
and fittings are properly tightened; and
.5 all entrance doors to the protected space should close properly and should
have warning signs, which indicate that the space is protected by a fixed
carbon dioxide system and that personnel should evacuate immediately if
the alarms sound. All remote releasing controls should be checked for clear
operating instructions and indication as to the space served.
Annex, page 3
6 Minimum recommended maintenance
6.1 At least biennially (intervals of 2 years ± 3 months) in passenger ships or at each

intermediate, periodical or renewal survey 1 in cargo ships, the following maintenance should
be carried out (to assist in carrying out the recommended maintenance, examples of service
charts are set out in the appendix):
.1 all high-pressure cylinders and pilot cylinders should be weighed or have

their contents verified by other reliable means to confirm that the available
charge in each is above 90% of the nominal charge. Cylinders containing
less than 90% of the nominal charge should be refilled. The liquid level of
low pressure storage tanks should be checked to verify that the required
amount of carbon dioxide to protect the largest hazard is available;
.2 the hydrostatic test date of all storage containers should be checked.

High-pressure cylinders should be subjected to periodical tests at intervals
not exceeding 10 years. At the 10-year inspection, at least 10% of the total
number provided should be subjected to an internal inspection and
hydrostatic test 2. If one or more cylinders fail, a total of 50% of the onboard
cylinders should be tested. If further cylinders fail, all cylinders should be
tested. Before the 20-year anniversary and every 10-year anniversary
thereafter, all cylinders should be subjected to a hydrostatic test.
Flexible hoses should be replaced at the intervals recommended by the
manufacturer and not exceeding every 10 years. When cylinders are
removed for testing, the cylinders should be replaced such that the quantity
of fire-extinguishing medium continues to satisfy the requirements of 2.2.1 of
chapter 5 of the FSS Code, subject to SOLAS regulation II-2/14.2; and
.3 the discharge piping and nozzles should be tested to verify that they are not
blocked. The test should be performed by isolating the discharge piping from
the system and flowing dry air or nitrogen from test cylinders or suitable
means through the piping.
6.2 At least biennially (intervals of 2 years ± 3 months) in passenger ships or at each

renewal survey1 in cargo ships, the following maintenance should be carried out by service
technicians/ specialists trained to standards accepted by the Administration:
.1 where possible, all activating heads should be removed from the cylinder
valves and tested for correct functioning by applying full working pressure
through the pilot lines.
In cases where this is not possible, pilot lines should be disconnected from
the cylinder valves and blanked off or connected together and tested with full
working pressure from the release station and checked for leakage.
In both cases this should be carried out from one or more release stations
when installed. If manual pull cables operate the remote release controls,
they should be checked to verify the cables and corner pulleys are in good
condition and freely move and do not require an excessive amount of travel
to activate the system;
1
Refer to the Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2019
(resolution A.1140(31)).
2
Refer to standard ISO 18119:2018 – Gas cylinders – Seamless steel and seamless aluminium-alloy gas
cylinders and tubes – Periodic inspection and testing.
Annex, page 4
.2 all cable components should be cleaned and adjusted as necessary, and the
cable connectors should be properly tightened. If the remote release controls
are operated by pneumatic pressure, the tubing should be checked for
leakage, and the proper charge of the remote releasing station pilot gas
cylinders should be verified. All controls and warning devices should function
normally, and the time delay, if fitted should prevent the discharge of gas for
the required time period; and
.3 after completion of the work, the system should be returned to service.

All releasing controls should be verified in the proper position and connected
to the correct control valves. All pressure switch interlocks should be reset
and returned to service. All stop valves should be in the closed position.
7 Five-year service
At least once every five years, internal inspection of all control valves should be performed.
Annex, page 5
APPENDIX
EXAMPLE SERVICE CHARTS
HIGH PRESSURE CO2 SYSTEM
Date: Name of ship/unit: IMO No.:
Technical description
No. Text Value

1 Manufacturer
2 Number of main cylinders
3 Main cylinders capacity (each)
4 Number of pilot cylinders
5 Pilot cylinder capacity (each)
6 Number of distribution lines
7 Oldest cylinder pressure test date
8 Protected space(s)
9 Date flexible hoses fitted/renewed
Description of inspection/Tests
No. Description Carried Not Not Comment

out carried applicable
out
1 Release controls and distribution valves secured
to prevent accidental discharge
2 Contents in main cylinders checked by weighing
3 Contents in main cylinders checked by liquid level
indicator
4 Contents of pilot cylinders checked
5 All cylinder valves visually inspected
6 All cylinder clamps and connections checked for
tightness
7 Manifold visually inspected
8 Manifold tested for leakage, by applying dry
working air
9 Main valve and distribution valves visually
inspected
10 Main valve and distribution valves tested for
operation
11 Time delay devices tested for correct setting*
12 Remote release system visually inspected
13 Remote release system tested
14 Servo tubing/pilot lines pressure tested at
maximum working pressure and checked for
leakages and blockage
15 Manual pull cables, pulleys, gang releases tested,
serviced and tightened/adjusted as necessary
16 Release stations visually inspected
Annex, page 6

out
17 Warning alarms (audible/visual) tested
18 Fan stop tested*
19 10% of cylinders and pilot cylinder/s pressure tested
every 10 years. All cylinders and pilot cylinder/s
pressure tested before the 20-year anniversary and
every 10-year anniversary thereafter
20 Internal inspection of all control valves performed at
least once every five years
21 Distribution lines and nozzles blown through, by
applying dry working air
22 All doors, hinges and locks inspected*
23 All instruction and warning signs on installation
inspected
24 All flexible hoses renewed and check valves in
manifold visually inspected every 10 years
25 Release controls and distribution valves
reconnected and system put back in service
26 Inspection date tags attached
*
If fitted as part of the CO2 system.
LOW PRESSURE CO2 SYSTEM
Date: Name of ship/unit: IMO No.:
Technical description
No. Text Value

1 Manufacturer
2 No. of tanks
3 Tanks capacity (tonnes)
4 Number of pilot cylinders
5 Pilot cylinder capacity (each)
6 Number of distribution lines
7 Protected space(s)
Description of inspection/Tests

out
1 Tank main service valve closed and secured to
prevent accidental discharge
2 Distribution valves verified closed
3 Check correct function of level indicator
4 Contents of CO2 tank checked by tank level
indicator
Annex, page 7

out
5 Contents of CO2 tank checked by riser tube
reading
6 Contents of CO2 tank checked by level control
valve
7 Supports of tank inspected
8 Insulation on tank inspected
9 Safety valves of tank inspected
10 Safety valves of tank tested
11 Contents of pilot cylinders checked
12 Start/stop function of cooling compressors tested
13 All connected electrical alarms and indicators
tested
14 Main manifold valve inspected
15 Internal inspection of all control valves performed at
least once every five years
16 Main manifold valve tested
17 Distribution valves inspected
18 Distribution valves tested
19 Release stations inspected
20 Total flooding release mechanism inspected
21 Total flooding release mechanism tested
22 Time delay devices tested for correct setting*
23 Warning alarms tested
24 Fan stop tested*
25 Distribution lines and nozzles inspected
26 Distribution lines and nozzles tested
27 Distribution lines and nozzles blown through
28 All doors, hinges and locks inspected*
29 All instruction plates inspected
30 Tank main service valve reopened and secured
open
31 System put back in service
32 Inspection date tags attached
*
If fitted as part of the CO2 system.
___________
Attachment 7. to
4 ALBERT EMBANKMENT
LONDON SE1 7SR
Telephone: +44 (0)20 7735 7611 Fax: +44 (0)20 7587 3210
MSC.1/Circ.1638
3 June 2021
OUTCOME OF THE REGULATORY SCOPING EXERCISE

FOR THE USE OF MARITIME AUTONOMOUS SURFACE SHIPS (MASS)
1 The Maritime Safety Committee, at its 103rd session (5 to 14 May 2021), approved
the Outcome of the regulatory Scoping Exercise for the use of Maritime Autonomous Surface
Ships (MASS), as set out in the annex, which provides the assessment of the degree to which
the existing regulatory framework under purview of the Maritime Safety Committee (MSC)
might be affected in order to address MASS operations. It further provides guidance to the
MSC and interested parties to identify, select and decide on future work on MASS and, as
such, facilitate the preparation of requests for, and consideration and approval of, new outputs.
2 Member States and international organizations are invited to take the annex into
account when proposing future work on MASS for consideration by the MSC and bring it to the
attention of shipowners, operators, academia and all other parties concerned.
***
I:/Circ/MSC/1/MSC.1-Circ.1638.docx
MSC.1/Circ.1638
Annex, page 1
ANNEX
OUTCOME OF THE REGULATORY SCOPING EXERCISE

FOR THE USE OF MARITIME AUTONOMOUS SURFACE SHIPS (MASS)
1 INTRODUCTION
1.1 This document presents the outcome of the regulatory scoping exercise (RSE) for the
use of Maritime Autonomous Surface Ships (MASS), conducted by the Maritime Safety
Committee (MSC).
1.2 The outcome of the RSE, approved by MSC 103 (5 to 14 May 2021), provides the
assessment of the degree to which the existing regulatory framework under its purview might
be affected in order to address MASS operations. It further provides guidance to MSC and
interested parties to identify, select and decide on future work on MASS and, as such, facilitate
the preparation of requests for, and consideration and approval of, new outputs.
Content of this document
1.3 The Intersessional Working Group on MASS, which met from 2 to 5 September 2019,
agreed that the outcome of the RSE to be finally approved by MSC should contain
(MSC 102/5/1, paragraph 4.17):
.1 a background section, including the process followed during the RSE;
.2 information for all degrees of autonomy for every instrument expected to be

affected by MASS operations under the purview of the MSC;
.3 the most appropriate way(s) of addressing MASS operations in those

instruments, as appropriate;
.4 identification of themes and/or potential gaps that require addressing;
.5 identification of possible links between instruments;
.6 identification of priorities for further work, including terminology and the order
in which instruments could be addressed taking into account common
themes and potential gaps; and
.7 references to the material produced before and during the RSE, in particular
IMO documents.
1.4 Taking into account the information in paragraph 1.3, the document is arranged in the
following manner.
1.5 Section 2 contains the background section and section 3 provides a summary of the
process followed during the RSE with reference to the framework as agreed at MSC 100
(MSC 100/20/Add.1, annex 2). The list of mandatory instruments related to maritime safety
and security considered as part of the RSE is set out in appendix 1.
1.6 Section 4 provides an overview of the assumptions made, by the volunteering

Member States, for the purpose of the RSE and refers to appendix 2 for the results of the RSE
at instrument level.
MSC.1/Circ.1638
Annex, page 2
1.7 Appendix 2, being the most substantial part of this document, provides the summary
of the outcome of the first and second step of the RSE as available in IMO documents
published during the RSE (see appendix 3) and the web platform (see paragraph 3.9), and
includes:
.1 information for all degrees of autonomy for every instrument expected to be

affected by MASS operations under the purview of MSC;
.2 the most appropriate way(s) of addressing MASS operations in those

instruments, as appropriate; and
.3 identification of themes and/or potential gaps that require addressing.
1.8 Section 5 provides an overview of the common potential gaps and/or themes that
require addressing for MASS operations and potential links between instruments.
This overview has been developed by using the available information in appendix 2.
1.9 In section 6, priorities for further work are identified, including terminology and the
order in which instruments could be addressed taking into account common themes and
potential gaps. This section has been developed by using the available information in
appendix 2.
1.10 Finally, section 7 provides references to the material produced before and during the
RSE, in particular IMO documents (see also appendix 3).
2 BACKGROUND
2.1 MSC 98 (June 2017) noted that the maritime sector was witnessing an increased
deployment of MASS to deliver safe, cost-effective and high-quality results. In this context,
MASS could include ships with different levels of automation, from partially automated systems
that assisted the human crew to fully autonomous systems which were able to undertake all
aspects of a ship's operation without the need for human intervention. Significant academic
and commercial research and development (R&D) was ongoing on all aspects of MASS,
including remotely controlled and autonomous navigation, vessel monitoring and collision
avoidance systems.
2.2 Although technological solutions were being developed and deployed, delegations
were of the view that there was a lack of clarity on the correct application of existing IMO
instruments to MASS. Delegations believed that IMO needed to ensure that MASS designers,
builders, owners and operators had access to a clear and consistent regulatory framework,
guided by the Principles to be considered when drafting IMO instruments
(resolution A.1103(29)), in order to be able to demonstrate compliance with IMO instruments.
2.3 Following consideration, MSC 98 agreed to include in its 2018-2019 biennial agenda
an output on "Regulatory scoping exercise for the use of Maritime Autonomous Surface Ships
(MASS)" with a target completion year of 2020.
2.4 At MSC 99 (May 2018), the Committee started to develop a framework for the RSE
and defined the aim, the objective, the preliminary definition of MASS and degrees of
autonomy, the list of mandatory instruments1 to be considered and the applicability in terms of
type and size of ships.
1 According to resolution A.911(22), "instrument" encompasses mandatory and non-mandatory conventions,

codes, guidelines, recommendations, etc.
MSC.1/Circ.1638
Annex, page 3
2.5 MSC 100 (December 2018) approved the framework for the RSE, which contained
definitions, a methodology consisting of a two-step approach and a plan of work and
procedures (MSC 100/20/Add.1, annex 2) and invited interested Member States and
international organizations to participate actively in the exercise. The Committee also approved
the holding of an intersessional meeting of Working Group on MASS between MSC 101
and 102. Furthermore, the Committee requested the Secretariat to develop a web platform as
part of the Global Shipping Information System (GISIS) to facilitate the RSE.
2.6 MSC 101 (June 2019) noted the progress made with the RSE and invited volunteering
Member States to submit the result of the first step to the intersessional Working Group on
MASS (ISWG/MASS). MSC 101 further developed and approved Interim guidelines for MASS
trials (MSC.1/Circ.1604).
2.7 As instructed by the Committee, ISWG/MASS (September 2019) considered and

agreed on the result of the first step of the RSE, and commenced the second step. The Group
also developed the guidance on the required format and content of the necessary input to
MSC 102.
2.8 Owing to the COVID-19 pandemic, MSC 102 (November 2020) deferred
consideration of this matter to MSC 103.
2.9 MSC 103 (May 2021) finalized the RSE and approved the outcome as set out in this
document.
3 FRAMEWORK AND PROCESS OF THE RSE
Aim
3.1 The aim of the regulatory scoping exercise was to determine how safe, secure and
environmentally sound MASS operations might be addressed in IMO instruments.
Objective
3.2 The objective of the RSE on MASS conducted by MSC was to assess the degree to
which the existing regulatory framework under its purview might be affected in order to address
MASS operations.
Glossary
3.3 For the purpose of the RSE, "MASS" was defined as a ship which, to a varying degree,
can operate independent of human interaction.
3.4 To facilitate the process of the RSE, the degrees of autonomy were organized as
follows:
Degree One: Ship with automated processes and decision support: Seafarers are
on board to operate and control shipboard systems and functions.
Some operations may be automated and at times be unsupervised
but with seafarers on board ready to take control.
Degree Two: Remotely controlled ship with seafarers on board: The ship is
controlled and operated from another location. Seafarers are
available on board to take control and to operate the shipboard
systems and functions.
MSC.1/Circ.1638
Annex, page 4
Degree Three: Remotely controlled ship without seafarers on board: The ship is
controlled and operated from another location. There are no
seafarers on board.
Degree Four: Fully autonomous ship: The operating system of the ship is able to
make decisions and determine actions by itself.
3.5 The above list does not represent a hierarchical order. It should be noted that MASS
could be operating at one or more degrees of autonomy for the duration of a single voyage.
Instruments
3.6 The list of mandatory instruments related to maritime safety and security considered
as part of the RSE is set out in appendix 1. These instruments have been reviewed on a
regulation or rule level. Subsidiary mandatory instruments established under each parent
instrument have also been considered to the level necessary to establish how they would be
affected.
3.7 The review of mandatory instruments was prioritized. In instruments containing both
mandatory and non-mandatory parts, non-mandatory parts have been considered as part of
the RSE, when deemed necessary, to obtain a complete understanding of how the mandatory
provisions would be affected in order to address MASS operations (e.g. STCW Convention
and Code).
Type and size of ships
3.8 The application of the regulatory scoping exercise was restricted to the applicability
of the instruments under consideration.
Web platform for the conduct of the RSE
3.9 A web platform was developed by the Secretariat as part of GISIS to facilitate the
RSE. The web platform was connected to the IMO web accounts, providing access only to
registered IMO Members.2 All IMO Members have read-only access to the web platform and
the information contained in the web platform will be retained for future reference until the
Committee decides otherwise.
Methodology
3.10 The review of instruments was conducted by volunteering Member States in two
steps. The list of mandatory instruments, as set out in appendix 1, also contains the names of
the volunteering Member States which undertook and supported the review of instruments.
At present intervals, IMO Members were authorized to submit comments on the work done by
the volunteering Member States through the web platform.
3.11 As a first step, containing the "initial review of IMO instruments", provisions in
IMO instruments were identified which, as currently drafted:
A applied to MASS and prevented MASS operations; or
2 Whenever the term "IMO Member" is used in this document, it includes Member Governments, associated
Member Governments, intergovernmental organizations with observer status and non-governmental
organizations in consultative status.
MSC.1/Circ.1638
Annex, page 5
B applied to MASS and did not prevent MASS operations and required no
actions; or
C applied to MASS and did not prevent MASS operations but might need to be
amended or clarified, and/or might contain gaps; or
D had no application to MASS operations.
3.12 Once the first step was completed, a second step was conducted to analyse and
determine the most appropriate way of addressing MASS operations, taking into account,
inter alia, human element,3 technology and operational factors by:
I equivalences as provided for by the instruments or developing

interpretations; and/or
II amending existing instruments; and/or
III developing new instruments; or
IV none of the above as a result of the analysis.
3.13 The terminology for the purpose of the RSE was agreed to at MSC 99 (documents
MSC 99/22, paragraph 5.27 and MSC 99/WP.9). References to degrees of autonomy in this
document refer only to the definitions considered within the scope of the RSE and do not
prevent potential future definitions that should be discussed at the later stage.
4 RESULTS OF THE REGULATORY SCOPING EXERCISE AT INSTRUMENT

LEVEL
4.1 The results of the RSE at instrument level are set out in appendix 2 and provide for
all degrees of autonomy, for every instrument expected to be affected by MASS operations
under the purview of the Maritime Safety Committee, the:
.1 most appropriate way(s) of addressing MASS operations in those

instruments;
.2 reason for selecting the most appropriate way(s); and
.3 identification of potential gaps/themes that require addressing.
Assumptions made for the purpose of the RSE
4.2 The assumptions listed in table 1 should be considered when interpreting the results
in appendix 2, they will not necessarily be used during subsequent work. Any future
assumptions would need to be agreed.
3 Refer to resolution A.947(23), Human element vision, principles and goals for the Organization.
MSC.1/Circ.1638
Annex, page 6
Assumptions Instruments
1 SOLAS chapters III and V, 1966 LL

Degree of autonomy Four means no crew on
Convention and 1988 Protocol,
board
2008 Intact Stability Code, III Code
2 Alternative arrangement, equivalent arrangement SOLAS chapter XI-2
would be allowed and available
3 Passenger transports without seafarers on board SOLAS chapters XI-2 and XIV and
cannot be performed Polar Code
4 The instrument applies to seafarers serving on STCW Convention and Code,
board seagoing ships STCW-F Convention
5 Determination of whether "remote operator" is a STCW Convention and Code,
seafarer and whether "remote operator" STCW-F Convention
encompasses all personnel working aboard of a
ship or those individuals capable of operational
control of the ship are outside of the remit of the
RSE
6 For degrees One and Two, seafarers are on SOLAS chapters II-1, II-2, VI, VII
board and available to take control of shipboard IBC, FSS, FTP, IMSBC, Grain,
systems CSS, IMDG, IGC, INF
7 For degrees Three and Four, persons may stay SOLAS chapters II-1, II-2, VI, VII
on board during berthing, cargo handling and IBC, FSS, FTP, IMSBC, Grain,
anchoring CSS, IMDG, IGC, INF
8 SOLAS chapters II-2, VI and VII
For degree Four, supervision by person is
IBC, FSS, FTP, IMSBC, Grain,
provided at a remote location
CSS, IMDG, IGC, INF
9 MASS of degree one is considered as a SOLAS chapter V
conventional ship with some additional functions
to support human decision-making. However, no
particular automated process or function of
decision support was considered owing to their
diversities.
10 As long as MASS is not fully autonomous; the role SOLAS chapter V
of master is still required. For degree Three
(higher degrees), the responsibility of the master
will be extended/amended.
11 The Safety Management of MASS relates, inter SOLAS chapter IX
alia, to functions which are autonomous
Table 1: List of assumptions used for the RSE
MSC.1/Circ.1638
Annex, page 7
5 COMMON POTENTIAL GAPS AND/OR THEMES AND POTENTIAL LINKS

BETWEEN INSTRUMENTS
5.1 The RSE identified the common potential gaps and/or themes that are required for
MASS operations, as shown in table 2, and these gaps and themes were developed by using
the available information in appendix 2. It should be noted that the potential gaps and themes
outlined below are not exhaustive and that the first column on "Common potential gaps and/or
themes" does not reflect any order of priorities.
5.2 Table 2 also shows the instruments under the remit of the Maritime Safety Committee,
including SOLAS chapters, where the common potential gaps and/or themes were identified,
thus indicating the potential links between instruments.
Common potential gaps and/or themes Instruments
1 Meaning of the terms master, crew or SOLAS chapters II-2, III, V, VI, VII IX and
responsible person XI-1, COLREG, TONNAGE 1969, 1966
LL Convention and 1988 Protocol, Intact
Stability Code, III Code, STCW
Convention and Code
2 Remote Control Station/Centre SOLAS chapters II-1, II-2, III, IV, V IX
and XI-1, STCW Convention and Code,
FSS, ISM, 1966 LL Convention and
1988 Protocol, Casualty Investigation
Code
3 Remote Operator as a seafarer STCW, STCW-F, SOLAS chapter IX,
ISM
4 Provisions containing manual operations, SOLAS chapters II-1, II-2, VI and IX,
alarms to the bridge 1966 LL Convention and 1988 Protocol,
Intact Stability Code,
III Code
5 Provisions requiring actions by personnel SOLAS chapters II-2, VI, VII, IX and XII
(Fire, Spillage Cargo Management, onboard
maintenance, etc.)
6 Certificates and manuals on board SOLAS chapters III, XI-1, XI-2 and XIV
7 Connectivity, Cybersecurity SOLAS chapters IV, V and IX
8 Watchkeeping SOLAS chapters IV and V, COLREG
9 Implication of MASS in SAR SOLAS chapters III, IV and V, SAR
10 Information to be available on board and SOLAS chapters II-1and II-2
required for the safe operation
11 Terminology SOLAS chapters II-1, IV and V,
COLREG, FSS, IBC, IGC, Grain, INF,
1966 LL Convention and 1988 Protocol,
Intact Stability Code, SAR, TONNAGE,
CSS, Casualty Investigation Code
Table 2: List of common potential gaps and/or themes
5.3 It has been recognized that not all common potential gaps and/or themes in table 2
are of the same nature. Some of them are critical and fundamental issues which may shape
the course of addressing MASS operations, while others concern more technical aspects.
MSC.1/Circ.1638
Annex, page 8
High-priority issues
5.4 Some common potential gaps and/or themes are at the core of how to introduce
MASS operation safely and effectively in the regulatory framework and are regarded as
high-priority issues that cut through several IMO instruments and may require a policy decision
before addressing individual instruments.
5.5 Meaning of the terms master, crew or responsible person

It was recognized that in a substantial number of instruments there was a need to clarify the
meaning of the terms master, crew or responsible person. The role, responsibility and definition
of master, especially for degrees of autonomy Three and Four where personnel on the shore
side might control the ship, were considered to be a common theme identified in several
instruments as a potential gap.
5.6 Remote control station/centre
MASS may be operated by a remote control station/centre. It was noted that the functional and
operational requirements of the remote control station/centre, as well as for monitoring, needed
to be addressed. It was further noted that this was a new concept to be implemented in IMO
instruments and a common theme identified in several instruments as a potential gap.
5.7 Remote operator as seafarer
The RSE revealed that the possible designation of a remote operator as seafarer was
considered to be a common theme identified in several instruments as a potential gap.
Qualifications, responsibility and the role of remote operator as seafarer was one of the most
complex issues to be addressed.
5.8 Terminology
Following consideration of terms that should be avoided, some recommended terms and a
draft glossary for future work submitted by Finland and France (MSC 101/5/4), MSC 101
agreed that the matter of a glossary should be further considered after the RSE had been
completed, together with information from ISO concerning new standards, as appropriate.
During step 2, as reported to MSC 102, views were expressed for the degrees of autonomy to
be re-evaluated, taking into account the lessons learned during the RSE. New definitions were
proposed in several places, which need to be further considered and decided upon.
6 PRIORITIES FOR FURTHER WORK
6.1 Given the complex and extensive output of the RSE (section 4 and appendix 2),
establishing priorities for further work is important. This section has been developed by using
the available information in appendix 2, to identify the priorities of work on several issues
cutting across a number of individual IMO instruments. The main high-priority items include
the need to consider the development of a new instrument, review of terminology and
definitions and consideration of high-priority common gaps and themes. It should be noted,
however, that the identified priorities are non-exhaustive.
Development of a new instrument
6.2 In line with the outcome on "the most appropriate ways of addressing MASS
operations" in appendix 2, the many common potential gaps and/or themes, which cut across
several instruments, could preferably be addressed holistically through a new instrument
MSC.1/Circ.1638
Annex, page 9
(e.g. a MASS Code). Addressing every instrument or SOLAS chapter separately could lead to
inconsistencies, confusion and raise potential barriers for the application of existing regulations
to conventional ships. Therefore, a MASS instrument, instead of amending individual
instruments, may be considered which can be made mandatory by means of amending an
existing IMO convention, such as SOLAS. This instrument could preferably be developed
following a goal-based approach,4 in line with the Guidelines developed by the Organization.5
6.3 In order to facilitate the operation of MASS at an early stage, establishing interim
guidelines for MASS may be beneficial for ensuring safe, secure and environmentally-friendly
MASS operations.
Terminology and definitions
6.4 It was recognized that consideration of amendments to instruments, or development

of a new instrument, requires agreement on the use of terminology and is a policy decision.
One of the issues to be addressed was considered to be the re-evaluation of the degrees of
autonomy, taking into account the lessons learned during the RSE. This work could include
the development of a glossary.
Common gaps and themes
6.5 As mentioned in the previous section, some common potential gaps and/or themes
were regarded as high-priority issues that cut across several IMO instruments and might
require a policy decision before addressing individual instruments. Among those are, for
instance:
.1 meaning of the terms master, crew or responsible person;
.2 remote control station/centre; and
.3 remote operator designated as seafarer.
Possible order to address the instruments
6.6 If the decision is made to amend existing instruments rather than to develop a new
instrument the following order of priorities is proposed:
It was concluded that the order to address the instruments for further work should be
classified into three groups, as follows:
.1 High-priority: the group of instruments which contain the common potential

gaps and/or themes listed in section 5 that need to be addressed before all
others;
.2 Medium-priority: the group of instruments which require consideration of the

impact of the use of MASS but which have not been identified as high-priority;
and
.3 Low-priority: the group of instruments that require no significant action for the
use of MASS.
4 See Generic guidelines for developing IMO goal-based standards (MSC.1/Circ.1394/Rev.2).

5 See resolution Uniform wording for referencing IMO instruments (resolution A.911(22)).
MSC.1/Circ.1638
Annex, page 10
High-priority instruments
6.7.1 The RSE concluded that the following IMO instruments under the purview of MSC
were classified as "High-priority":
SOLAS chapters II-1, II-2, III, IV, V, VI, VII, IX, XI-1and XI-2;
COLREG;
STCW Convention and Code;
STCW-F Convention;
1966 LL Convention and 1988 Protocol thereto;
1979 SAR Convention;
FSS Code;
IMSBC Code;
IMDG Code;
TONNAGE 1969;
IBC Code; and
IGC Code.
6.7.2 The most appropriate way(s) of addressing MASS operations in the instruments
classified as high-priority is set out in the table 3, with the following four options:
I equivalences as provided for by the instruments or developing

interpretations; and/or
III developing a new instrument; or
MSC.1/Circ.1638
Annex, page 11
The most appropriate way(s) of addressing

IMO Instruments
MASS operations
Degree of Autonomy One Two Three Four
SOLAS II-1 IV II II - III II - III
SOLAS II-2 IV II - III II - III II - III
SOLAS III IV II - III III III
SOLAS IV II II - III III III
SOLAS V II II - III III III
SOLAS VI IV II - III II - III II - III
SOLAS VII IV II - III II - III II - III
SOLAS IX IV III III III
SOLAS XI-1 IV III I - III I - III
SOLAS XI-2 I - II II - III II - III II - III
COLREG I I - II I - II II
STCW I - II I - II - III I - II - III IV
STCW-F I - II I - II - III I - II - III IV
LL 1966 + 1988
II
Protocol IV II II
SAR 1979 IV II II II
TONNAGE 1969 IV I I I
IMDG Code IV II- III II - III II - III
IMSBC Code IV II- III II - III II - III
FSS Code IV II- III II - III II - III
IBC Code IV II- III II - III II - III
IGC Code IV II- III II - III II - III
Table 3: List of high-priority instruments
Instruments to be addressed at the same time
6.7.3 Among the high-priority instruments, some may need to be addressed in parallel with
others in order to address the common potential gaps and/or themes.
Medium-priority instruments
6.8.1 The RSE concluded that the following IMO instruments under the purview of MSC
were classified as "Medium-priority":
SOLAS chapter XII

CSS Code;
Casualty Investigation Code;
III Code;
Grain Code;
INF Code;
2008 Intact Stability Code; and
Standards for owners' inspection and maintenance of bulk carrier hatch covers.
MSC.1/Circ.1638
Annex, page 12
6.8.2 The most appropriate way(s) of addressing MASS operations of the medium-priority
instruments is set out in table 4 below.
The most appropriate way(s) of addressing

IMO Instruments
MASS operations
SOLAS XII IV II - III II - III II - III
CSS Code IV II - III II - III II - III
Casualty Investigation Code IV II II II
III Code IV II II II
Grain Code IV II - III II - III II - III
INF Code IV II - III II - III II - III
IS Code IV II II II
Standards for owners' inspection and
maintenance of bulk carrier hatch IV IV II - III II - III
covers
Table 4: List of medium-priority instruments
6.8.3 Almost all of the medium-priority instruments were concluded to be addressed by

amending the instruments individually (i.e. the most appropriate way of addressing MASS
operations was option II (paragraph 6.8.2)).
Instruments to be addressed at the same time
6.8.4 Among the medium-priority instruments, some might need to be addressed in parallel
with others in order to address the common potential gaps and/or themes.
Low-priority instruments
6.9.1 The RSE concluded that the following remaining instruments under the purview of
MSC were classified as "low-priority" and required no significant action for the use of MASS.
6.9.2 The most appropriate way(s) of addressing MASS operations of the low-priority
instruments are set out in the table 5 below, showing that no action is required for the use of
MASS.
6.9.3 It was, however, recognized that some of the low-priority instruments might need to
be considered in future in relation to the introduction of new technologies.
MSC.1/Circ.1638
Annex, page 13
The most appropriate way(s) of

IMO Instruments
addressing MASS operations
SOLAS chapter XIII IV IV IV IV
SOLAS chapter XIV IV IV IV IV
CSC Code IV IV IV IV
ESP Code IV IV IV IV
RO Code IV IV IV IV
FTP Code IV IV IV IV
Polar Code IV IV IV IV
LSA Code IV IV IV IV
ISM Code IV IV IV IV
ISPS Code IV IV IV IV
Standards for the evaluation of scantlings of the
transverse watertight vertically corrugated
bulkhead between the two foremost cargo holds IV IV IV IV
and for the evaluation of allowable hold loading of
the foremost cargo hold
Standards and criteria for side structure of bulk
IV IV IV IV
carriers of single-side skin construction
Table 5: List of low-priority instruments
Proposals for new outputs
6.10 The need for justification in relation to any future proposals for changes in the
regulatory framework was agreed and, consequently, it was recognized that any future work
on MASS need to be approved following a proposal for a new output. Therefore, all activities
described below requires new outputs to be agreed by MSC.
Addressing MASS operations in IMO instruments under the remit of the Maritime Safety
Committee
6.11.1 When addressing the high-priority issues identified above, coordination and
delegation of work between committees and sub-committees should be considered.
High-priority issues for addressing MASS operations in IMO instruments

6.11.2 Commencement of developing and establishing rules and regulations to address
MASS operations may require certain issues of high priority, as set out in paragraphs 6.2 to
6.6, to be considered in order to determine what, how and when to address MASS operations
and to provide a foundation for future work. This effort would benefit from the sharing of
experience gained by early MASS operations.
6.11.3 A possible way forward in addressing MASS operations in IMO instruments under the
remit of the Maritime Safety Committee is set out in table 6.
MSC.1/Circ.1638
Annex, page 14
Issue Planned activities and result

1 Consideration of a holistic approach to MASS operations in IMO instruments
Development of a goal-basedMASS Consideration on how to develop a new

instrument MASS instrument and draft amendments
to the applicable instruments through
which it can be made mandatory
Definition of MASS Consideration on the need to revise
definition and/or degrees and if revision
is deemed necessary, agreeing on the
definition and/or degrees
Terminology for MASS operations in the IMO Consideration on the need of
regulatory framework supplementing terminology, and if
deemed necessary, agreeing on such
terminology
High-priority common gaps and themes in Consideration of the high-priority
relation to MASS operations and IMOs common gaps and themes
regulatory framework:
- Meaning of Master, crew or
responsible person
- Remote control station/centre
- Remote operator designated as
seafarer
Non-mandatory instrument Consideration of the development of
guidelines for MASS operations such as
guidelines for installation and guidelines
for system application
Table 6: Addressing MASS operations in IMO instruments under the remit of the
Maritime Safety Committee
7 REFERENCES TO THE MATERIAL PRODUCED BEFORE AND DURING THE RSE
IMO documents
7.1 A list containing a reference to IMO documents published before and during the RSE
is provided in appendix 3.
The MASS module of GISIS
7.2 All detailed information, including analysis by the volunteering Member States and
comments made by IMO Members have been recorded in the MASS module of GISIS.
This web platform is connected to the IMO web accounts, providing access to registered IMO
Members only.
MSC.1/Circ.1638
Annex, page 15
Appendix 1
LIST OF INSTRUMENTS AND VOLUNTEERING MEMBERS UNDERTAKING OR SUPPORTING THE REVIEW OF INSTRUMENTS
Instrument Volunteering Member Supporting Member(s)

State(s)
International Convention for the Safety of Life at Sea, 1974, as amended

(SOLAS 1974)
Chapter II-1 (Construction – structure, subdivision and stability, France China, Iran (Islamic Republic
machinery and electrical installations) of) and Sweden
Chapter II-2 (Construction – fire protection, fire detection and fire Japan China and IACS
extinction), including:
- International Code for Fire Safety Systems (FSS Code); and
- International Code for Application of Fire Test Procedures, 2010
(2010 FTP Code)
Chapter III (Life-saving appliances and arrangements), including: Netherlands Belgium and China
- International Life-Saving Appliance Code (LSA Code)
Chapter IV (Radiocommunications) Turkey China and Japan
Chapter V (Safety of navigation) China Denmark, Japan and
Singapore
Chapter VI (Carriage of cargoes and oil fuels), including: Japan China
- International Maritime Solid Bulk Cargoes Code (IMSBC Code);
- Code of Safe Practice for Cargo Stowage and Securing (CSS Code);
- International Code for the Safe Carriage of Grain in Bulk (Grain Code)
- Part A "Specific requirements"; and
- Part B "Calculation of assumed heeling moments and general
assumptions".
MSC.1/Circ.1638
Annex, page 16

State(s)
Chapter VII (Carriage of dangerous goods), including: Japan China

- International Maritime Dangerous Goods Code (IMDG Code);
- International Code for the Construction and Equipment of Ships
Carrying Dangerous Chemicals in Bulk (IBC Code);
- International Code for the Construction and Equipment of Ships
Carrying Liquefied Gases in Bulk (IGC Code); and
- International Code for the Safe Carriage of Packaged Irradiated
Nuclear Fuel, Plutonium and High-Level Radioactive Wastes on Board
Ships (INF Code).
Chapter IX (Management for the safe operation of ships), including: Norway China, Nigeria, Republic of
- International Safety Management (ISM) Code. Korea and Russian Federation
Chapter XI-1 (Special measures to enhance maritime safety), Finland China
including:
- Code for Recognized Organizations (RO Code);
- International Code on the Enhanced Programme of Inspections during
Surveys of Bulk and Oil Tankers, 2001 (2011 ESP Code); and
- Code of the International Standards and Recommended Practices for
a Safety Investigation into a Marine Casualty or Marine Incident
(Casualty Investigation Code).
Chapter XI-2 (Special measures to enhance maritime security), Finland China
including:
- International Ship and Port Facility Security Code (ISPS Code)
Chapter XII (Bulk Carrier), including: Japan
- Bulk carrier bulkhead and double bottom strength standards;
- Standards for owners' inspection and maintenance of bulk carrier
hatch covers; and
- Standards and criteria for side structures of bulk carriers of single-side
skin construction.
Chapter XIII (Verification of Compliance) Japan
MSC.1/Circ.1638
Annex, page 17

State(s)
Chapter XIV (Safety measures for ships operating in polar waters), Finland
including:
- International Code for Ships Operating in Polar Waters (Polar Code)
International Convention on Standards of Training, Certification and United States China, Cyprus, Japan, New
Watchkeeping for Seafarers, 1978, as amended (STCW 1978) and Seafarers' Zealand, Republic of Korea,
Training, Certification and Watchkeeping Code (STCW Code) Russian Federation and Spain
International Convention on Standards of Training, Certification and Japan New Zealand and Spain
Watchkeeping for Fishing Vessel Personnel, 1995 (STCW-F 1995)
Convention on the International Regulations for Preventing Collisions at Sea, Marshall Islands China, Japan, Singapore,
1972, as amended (COLREG 1972) Spain, Sweden and
United States
International Convention for Safe Containers (CSC), 1972 Japan Finland
International Convention on Load Lines, 1966 (LL 1966), including: India China and Liberia
- IMO Instruments Implementation Code (III Code); and
- International Code on Intact Stability, 2008 (2008 IS Code) – Part A.
Protocol of 1988 relating to LL 1966 (LL PROT 1988) India Liberia
International Convention on Maritime Search and Rescue, 1979 (SAR 1979) Spain and France Turkey
International Convention on Tonnage Measurement of Ships, 1969 Liberia
(TONNAGE 1969)
MSC.1/Circ.1638
Annex, page 18
Appendix 2
RESULTS OF THE REGULATORY SCOPING EXERCISE AT INSTRUMENT LEVEL
The application of IMO instruments, as currently drafted, is divided in the following categories:
A applied to MASS and prevented MASS operations; or
B applied to MASS and did not prevent MASS operations and required no actions; or
C applied to MASS and did not prevent MASS operations but might need to be amended or clarified, and/or might contain gaps; or
D had no application to MASS operations.
The most appropriate way(s) of addressing MASS operations are categorized with the following four options:
I equivalences as provided for by the instruments or developing interpretations; and/or
III developing a new instrument; or
Instrument: SOLAS Chapter II-1

The most
appropriate
Degree of way(s) of Reason for selecting the most appropriate
autonomy addressing way(s) of addressing MASS operations Potential gaps/themes that require addressing
MASS
operations
(I, II, III, IV)
Specific definitions could be added in Reg. 2 and 3
Reg. 2 and 3 mention no specific definitions for MASS
II for MASS operations (e.g. master, operator,
operations
Remote Control Centre, unmanned, etc.)
Specific requirements on remote monitoring and
General
remote control may be developed (e.g.
No specific requirements on remote monitoring and
III requirements on Remote control centre, including
remote control in the existing instruments
facility and manning, communication network and
system, human machine interface, etc.)
MSC.1/Circ.1638
Annex, page 19
Degree One IV MASS application (initial review) = B or D None

Specific definitions could be added in Reg. 2 and 3 Reg. 13, 13-1, 14, 15-1, 17-1, 22-1, 25, 29, 30, 31, 37,
to clarify that the Remote Control Centre could be a 49, 50, 51, 53 mention indications, alarms, controls in the
substitute to the bridge bridge or communication means with the bridge
Reg. 22 could be amended considering that the
Reg. 22 mentions control of doors and other devices
II control could be performed remotely
Degree Two Reg. 5, 5-1, 8-1, 28 mention information to be available
Reg. 5, 5-1, 8-1, 20, 23, 24 and 28 could be on board for the use of the master or information to be
amended considering that the master and/or the supplied to the master
officer of the watch could be on board or not on
Reg. 20, 23, 24 mention actions to be done by the
board
master and/or the officer of the watch
Reg. 3-3 mentions means to enable the crew to gain safe
access to the bow
Reg. 3-4, 3-6, 3-8, 12, 13, 13-1, 15, 17, 17-1, 19-1, 21,
22, 26, 29, 31, 33, 35-1, 41, 44, 48, 49 mention manual
operation done on board
Reg. 3-6, 3-7, 3-10, 5, 5-1, 8-1, 19, 28 mention
information available on board or information supplied to
the master
Could be amended considering no crew and no Reg. 6 and 7.3 take into account the presence of the
master (or officer of the watch) on board crew in the stability calculation (index R and permeability)
Reg. 13, 13-1, 14, 15-1, 17-1, 22-1, 25, 29, 30, 31, 37,
Degrees or 49, 50, 51, 53 mention indications, alarms, controls or
Three and II or III communication means in the bridge, engine room or
Four Considering the number of gaps identified involving centralized control position
a lot of regulations, developing a separate and Reg. 20, 22, 23, 24 mention actions done by the master
dedicated instrument could be the solution with less (or officer of the watch)
complexity and easier to conduct Reg. 32 mentions a direct reading gauge glass
Reg. 38 mentions an alarm in the engineers'
accommodation
Reg. 40, 41 mention habitable conditions
Reg. 42, 42-1, 43 mention emergency consumers,
lighting, muster and embarkation station related to crew
evacuation
Reg. 54 mentions periodically unattended machinery
spaces
MSC.1/Circ.1638
Annex, page 20
Instrument: SOLAS chapter II-2

The most
appropriate
way(s) of
Degree of Reason for selecting the most appropriate way(s)
addressing Potential gaps/themes that require addressing
autonomy of addressing MASS operations
MASS
operations
(I, II, III, IV)
Appropriate alternative safety measures should be
adopted to achieve the equivalent functionalities
intended by the existing regulations and resolve the
potential gaps and/or themes identified in the first
step.
On the other hand, it could also be considered to

amend the regulations or develop new instruments to
ensure fire safety based on another concept. In such
a case, one of the future issues to be addressed is
how to evaluate the reduction of fire risks owing to
absence of persons on board and to what extent we
General could relax the regulations.
The choice of the most appropriate way(s) of doing

so would be affected by several issues, such as the
scale of amendments and time it takes to be agreed.
Some of them would be identified during the
discussion on the actual amendments, and thus it
seems difficult to determine the most appropriate way
at this stage. Therefore, the following analysis shows
options to be considered as the most appropriate
way(s).
MSC.1/Circ.1638
Annex, page 21
"MASS application" of all regulations were

identified as ".B" or ".D" and no action is required.
Degree One IV None.
However, some considerations might be needed
depending on the conditions or premises of this
degree of autonomy.
Regarding the clarification of the term "master" and
its similar words, consistent measures (e.g.
amending or developing definition) should be taken
considering its importance. All IMO instruments are
provided subject to the existence of the master on
board even if there is no explicit reference. Changing
this precondition would have huge impact on the
instruments. Therefore, amendment or clarification of
these terms should be done carefully in a consistent
manner. • Since there is the possibility that "master", "crew",
"responsible person", etc. are not on board, the
Regarding the other potential gaps and/or themes, meanings of such personnel of the ship should be
the provisions regarding definitions and the clarified.
provisions regarding facilities such as alarms, • Provisions regarding definitions (control stations and
Degree Two II and/or III
indications and operational booklets should be safety centre) should be amended.
amended to safely introduce remote operations with • Provisions regarding facilities such as alarms,
seafarers on board. indications and operational booklets should be
amended so that remote operators can also be
As mentioned in the general comments, it seems notified.
difficult to determine the most appropriate way at this
stage because it might only be found during the
discussion on the actual amendments. However,
easy measures such as developing unified
interpretation (UI) should be avoided to prevent
creating confusion and contradiction.
Therefore, "II and/or III" were determined as the most

appropriate way(s) of addressing MASS operations.
MSC.1/Circ.1638
Annex, page 22
Regarding clarifications of "master", etc., see the

comments in degree Two.
Regarding the other potential gaps and/or themes,

one way is to amend the provisions to safely
introduce remote operations without seafarers on
board. Another way is to apply regulation 17
"Alternative design and arrangements" to the
provisions for systems and appliances which need
manual operations or provisions requiring actions by
personnel on board in regulations 4 to 23 other than
17 of SOLAS chapter II-2. • The meanings of "master", etc.
• Functional requirements of remote/ automated system
On the other hand, regarding the provisions for to detect and control fire.
systems and appliances which need manual • Definitions of manned spaces, control stations and
operations and provisions requiring actions by safety centre.
personnel on board, especially for fire fighting, it may • Facilities such as alarms, indications, notification and
Degree Three II and/or III
be more appropriate to develop new instruments means of escape, and operational booklets.
(new code for SOLAS-related issues and new • Systems and appliances which need manual
chapter in SOLAS to make the code mandatory) operations.
rather than amending them one by one since there • Actions by personnel on board, such as fire fighting.
are a lot of provisions in the same themes or • Accommodations and accessibility.
potential gaps in this chapter. • Safe return to port and its casualty threshold.
As mentioned in the general comments, it seems


MSC.1/Circ.1638
Annex, page 23


introduce autonomous operations without seafarers
on board. Another way is to apply regulation 17
17 of SOLAS chapter II-2.
On the other hand, regarding the provisions for

systems and appliances which need manual
operations and provisions requiring actions by
personnel on board, especially for fire fighting, it may
Degree Four II and/or III Ditto.
be more appropriate to develop new instruments
(new code for SOLAS-related issues and new
chapter in SOLAS to make the code mandatory)
rather than amending them one by one since there
are a lot of provisions in the same themes or
potential gaps in this chapter.


MSC.1/Circ.1638
Annex, page 24
Instrument: FSS Code

The most
appropriate
way(s) of
Degree of Reason for selecting the most appropriate
autonomy way(s) of addressing MASS operations
MASS
operations
(I, II, III, IV)
themes/potential gaps identified in the first step.

General
could relax the regulations.

seems difficult to determine the most appropriate
way at this stage. Therefore, the following analysis
shows options to be considered as the most
appropriate way(s).
MSC.1/Circ.1638
Annex, page 25
"MASS application" of all regulations were identified

as ".B" or ".D" and no action is required.
Degree One IV None.
However, some considerations might be needed
depending on the conditions or premises of this
degree of autonomy.
these terms should be done carefully in a consistent • Since there is the possibility that "master", "crew",
manner. "responsible person", etc. are not on board, the
meanings of such personnel of the ship should be
Regarding the potential gaps and/or themes, the clarified.
Degree Two II and/or III provisions should be amended to safely introduce • The meanings of control stations and safety centre
remote operations with seafarers on board. should be clarified.
As mentioned in the general comments, it seems • Provisions regarding facilities such as alarms and
difficult to determine the most appropriate way at this indications should be amended so that remote
stage because it might only be found during the operators can also be notified.
Therefore, "II and/or III" were determined as the

most appropriate way(s) of addressing MASS
operations.
MSC.1/Circ.1638
Annex, page 26


board. Another way is to apply regulation 17
17 of SOLAS chapter II-2. • Since "master", "crew", "responsible person", etc. are
not on board, the meanings of such personnel of the
On the other hand, regarding the provisions for ship should be clarified.
systems and appliances which need manual • The meanings of manned spaces, control stations and
operations, especially for fire fighting, it may be more safety centre should be clarified.
appropriate to develop new instruments (new code • Provisions regarding facilities such as alarms,
for SOLAS-related issues and new chapter in indications, notification and means of escape should
SOLAS to make the code mandatory) rather than be amended.
amending them one by one since there are a lot of • Provisions regarding systems and appliances which
provisions in the same themes or potential gaps in need manual operations should be amended.
this code. • Provisions regarding accommodations and
accessibility should be amended.

operations.
MSC.1/Circ.1638
Annex, page 27


on board. Another way is to apply regulation 17
17 of SOLAS chapter II-2.
On the other hand, regarding the provisions for

systems and appliances which need manual
operations, especially for fire fighting, it may be more
appropriate to develop new instruments (new code
for SOLAS-related issues and new chapter in
SOLAS to make the code mandatory) rather than
amending them one by one since there are a lot of
provisions in the same themes or potential gaps in
this code.


operations.
MSC.1/Circ.1638
Annex, page 28
Instrument: FTP Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
Degree One IV None.
as ".B" and no action is required.
Degree Two IV None.
Degree Three IV None.
Degree Four IV None.
Instrument: SOLAS Chapter III

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
Degree One IV Scored MASS application B for all regulations in the None
first step.
MSC.1/Circ.1638
Annex, page 29
Degree Two I, II or III More than one way possible in order to capture the Communications between remote operator and crew
concept of remote control, the altered status of the on board, definition and status of the navigation bridge,
navigation bridge therein, and the definition/role of definition and role of the master (either on board or at
the master in such a concept, related to the the remote operator station).
(emergency) process of evacuating persons on
board and rescuing persons from the water.
Degree Three III The concept of unmanned MASS requires principle Availability of sufficient and qualified persons.
assumptions and new concept thinking related to the Manning of survival craft and supervision of evacuation.
process of evacuating persons on board a ship Definition and role of the master.
carrying passengers and rescuing persons from the Definition and status of the navigation bridge.
water that cannot just be accommodated by How to render assistance to other ships in distress, or
amending existing instruments or applying recover persons from the water without crew on board.
equivalents. Goal and function of rescue boat and line-throwing
appliance.
Degree Four III The concept of unmanned MASS requires principle Availability of sufficient and qualified persons.
assumptions and new concept thinking related to the Manning of survival craft and supervision of evacuation.
process of evacuating persons on board a ship Definition and role of the master.
carrying passengers and rescuing persons from the Definition and status of the navigation bridge.
water that cannot just be accommodated by How to render assistance to other ships in distress, or
amending existing instruments or applying recover persons from the water without crew on board.
equivalents. Goal and function of rescue boat and line-throwing
appliance.
MSC.1/Circ.1638
Annex, page 30
Instrument: SOLAS chapter IV – Radiocommunications

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
Potential gaps may be addressed by amending • New terms and definitions
Degree One II existing instrument, possibly as they are introduced. • New requirements for automated processes and
decision support system
Since remotely controlled operations have not been • New terms and definitions
a part of this instrument, developing a new • Requirements for remote control stations' technical
instrument would be the most appropriate way to issues
address the requirements for remote control • Functional and maintenance requirements
Degree Two II, III centres.
In addition, necessity for new requirements and

frequencies could be addressed by developing new
instrument as well.
Since remotely controlled operations have not been • New terms and definitions
a part of this instrument, developing a new • Requirements for remote control stations' technical
instrument would be the most appropriate way to issues
address the requirements for remote control • Functional and maintenance requirements
Degree Three III centres. • Radio watch requirements and radio personnel
• Distress, safety and urgency calls and related
In addition, necessity for new requirements and requirements
frequencies could be addressed by developing a
new instrument as well.
Since fully autonomous ships with most probably • New terms and definitions Requirements for main
having main control centre ashore have not been control stations' technical issues
Degree Four III foreseen in this instrument, developing new • Functional and maintenance requirements
instrument would be the most appropriate way to • Radio watch requirements and radio personnel
MSC.1/Circ.1638
Annex, page 31
address the requirements for potential main control • Distress, safety and urgency calls and related
centres. requirements
In addition, necessity for new requirements and

frequencies could be addressed by developing new
instrument as well.
Instrument: SOLAS chapter V

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
For MASS of degree One, crew on board will still be 1. Definitions
responsible for ship operation including decision- 2. General provisions for decision-making functions and
making. For general application of decision-making automated processes
functions and automated processes, a basic 3. Provisions and performance standards for defined
principle for adopting them are required to be specific decision-making functions and automated
developed and included in SOLAS (e.g. in Ch. I). processes
If there are any specific decision-making functions 4. Relationship between manning level and specific
or automated processes, such as "periodically automated processes
Degree One II unmanned bridge", then new regulations and
performance standards are to be developed and
included in SOLAS chapter V. Also,
amendments/additions to definitions will be needed
to accommodate the concept of MASS. In light of
the above, modification to current instruments
(option II) are considered as the most appropriate
way for addressing the operation of degree One
MASS.
For degree Two MASS, there are quite a few 1. Definitions
Degree Two II, III
potential gaps identified involving many regulations. 2. Requirements for remote control (location)
MSC.1/Circ.1638
Annex, page 32
Some require amendments to current provisions 3. Definition, roles, responsibilities and qualification of
(items 1, 3, 4, 6, 7), while others require the Ship Master
reconstruction of regulations (for item 5). Moreover, 4. Roles, responsibilities and qualification of crew or
new regulation/provisions will also need to be responsible personnel
developed (requirements for remote control). In 5. Manning requirements (on board and at remote control
terms of this, two paralleled tracks are suggested: location)
1. Modify existing regulations for gaps require 6. Carriage of equipment and the related performance
amendments; and standards
2. Accommodate functions of remote control and 7. Ship-shore communications
those require reconstruction in a new and dedicated
instrument. Additional performance standards for
some navigational equipment of remotely controlled
MASS most likely also need to be developed.
Separate guidelines (mandatory or non-mandatory)
for these performance standards are suggested.
For degree Three MASS, there are quite a few 1. Definitions
potential gaps identified involving many regulations. 2. Requirements for remote control (location)
Some require amendments to current provisions 3. Definition, roles, responsibilities and qualification of
(items 1, 3, 4, 5, 6, 7, 9, 13), while others require Ship Master
the reconstruction of regulations (for items 8, 10, 4. Roles, responsibilities and qualification of crew or
11, 12). Moreover, new regulation/provisions will responsible personnel
also need to be developed (requirements for remote 5. Implication of MASS in SAR
control). In terms of this, conducting large scale 6. Certificates and manuals on board
amendments to existing provision will not be an 7. Carriage of equipment and the related performance
optimized way to address the issue. Remotely standards
Degree Three III
controlled MASS certainly will appear in the future. 8. Manning requirements
However, for a very long period, the large majority 9. Ship reporting and reporting method
of the world's fleet will still be conventional ship. 10. Bridge design and visibility
Therefore, large scale amendments of current 11. Training and drilling
regulations only to accommodate MASS operation 12. Onboard manual operation
seem to be unwise, which will also cause confusion
and potential barriers for the application of existing
provisions to conventional ships. On the other hand,
developing a separate and dedicated mandatory
instrument for MASS of this level to encompass all
MSC.1/Circ.1638
Annex, page 33
the provisions to mitigate gaps identified will be the

solution with less complexity and easier to realize.
Additional performance standards for some
navigational equipment of remotely controlled
MASS will also need to be developed. Separate
guidelines (mandatory or non-mandatory) for these
performance standards are suggested.
For degree Four MASS, there are quite a few 1. Definitions
potential gaps identified involving many regulations. 2. Definition, roles, responsibilities and qualification of
Some require amendments to current provisions Ship Master
(items 1, 2, 3, 4, 5, 7, 10), while others require the 3. Implication of MASS in SAR
reconstruction of regulations (items 6, 8, 9). New 4. Certificates and manuals on board
regulation/provisions might also need to be 5. Carriage of equipment and the related performance
developed. In terms of this, conducting large scale standards
amendments to existing provision will not be an 6. Bridge design and visibility
optimized way to address the issue. Autonomously 7. Ship reporting and reporting method
operated MASS certainly will appear in the future. 8. Training and drilling
However, for a very long period, the large majority 9. Onboard manual operation (steering) and action
of world's fleet will still be conventional ship. (maintenance, pilot transfer)
Therefore, large scale amendments of current 10. Information transfer/ship-shore communication
Degree Four III
regulations only to accommodate MASS operation
seem to be unwise, which will also cause confusion
and potential barriers for the application of existing
provisions to conventional ships. On the other hand,
developing a separate and dedicated mandatory
instrument for MASS of this level to encompass all
the provisions to mitigate gaps identified will be the
solution with less complexity and easier to realize.
Additional performance standards for some
navigational equipment of autonomously operated
MASS will also need to be developed. Separate
guidelines (mandatory or non-mandatory) for these
performance standards are suggested.
MSC.1/Circ.1638
Annex, page 34
Instrument: SOLAS chapter VI

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
step.
On the other hand, another way could also be

considered to amend the regulations or develop new
instruments to introduce absolutely different
emergency procedures in the case that there are no
persons on board and the cargo does not include
any harmful substances for the marine environment.
In such a way, one of the future issues to be
General
addressed is how to evaluate the reduction of risks
owing to absence of persons on board and to what
extent we could relax the regulations.

appropriate way(s).
MSC.1/Circ.1638
Annex, page 35
"MASS application" of all regulations were ".B" or

Degree One IV None.
".D" and no action is required.
this precondition would have a huge impact on the
these terms should be done carefully in a consistent
manner.
Since there is the possibility that "master", "crew",
Degree Two II and/or III "responsible person", etc. are not on board, the meanings
of such personnel of the ship should be clarified.

operations.
Regarding clarifications of "master", etc., see the • The meanings of "master", etc.
comments in degree Two. • Systems and appliances which need manual
operations.
Regarding the other potential gaps and/or themes, • Actions by personnel on board, such as emergency
one way is to amend the provisions to safely response and onboard inspection.
board. Another way is to develop new instruments Taking them into account, for the carriage of cargoes by
(new code for SOLAS-related issues and new ships without persons on board during sailing, one of the
chapter in SOLAS to make the code mandatory) not important issues is how to establish the emergency
amending them one by one, especially for the procedures to deal with conditions of leakage, spillage or
MSC.1/Circ.1638
Annex, page 36
procedures to ensure safety of cargoes in normal fire involving cargoes, as well as the procedures for
and emergency conditions, since there are a lot of ensuring safety in normal conditions.
this chapter.

operations.

on board. Another way is to develop new instruments
chapter in SOLAS to make the code mandatory) not
amending them one by one, especially for the
procedures to ensure safety of cargoes in normal
and emergency conditions, since there are a lot of
this chapter.

MSC.1/Circ.1638
Annex, page 37


operations.
Instrument: IMSBC Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
step.

General instruments to introduce absolutely different
MSC.1/Circ.1638
Annex, page 38

appropriate way(s).
Degree One IV None.
these terms should be done carefully in consistent
manner.

operations.
MSC.1/Circ.1638
Annex, page 39


board. Another way is to develop new instruments
• The meanings of "master", etc.
• Actions by personnel on board, such as emergency
chapter in SOLAS to make the code mandatory) with
response, onboard inspection and security
the similar issues in SOLAS chapter VI, not
responsibilities.
procedures to ensure safety of cargoes in normal • Instructions for onboard procedures.
Degree Three II and/or III and emergency conditions.
Taking them into account, for the carriage of cargoes by
As mentioned in the general comments, it seems ships without persons on board during sailing, one of the
difficult to determine the most appropriate way at this important issues is how to establish the emergency
stage because it might only be found during the procedures to deal with conditions of leakage, spillage or
discussion on the actual amendments. However, fire involving cargoes, as well as the procedures for
easy measures such as developing unified ensuring safety in normal conditions.

operations.

chapter in SOLAS to make the code mandatory) with
the similar issues in SOLAS chapter VI, not
MSC.1/Circ.1638
Annex, page 40

and emergency conditions.


operations.
Instrument: CSS Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
step.
General
MSC.1/Circ.1638
Annex, page 41

appropriate way(s).
Degree One IV None.
as "B" and no action is required.
manner.

operations.
Since "master", "crew", "responsible person", etc. are not
Degree Three II and/or III Ditto. on board, the meanings of such personnel of the ship
should be clarified.
Degree Four II and/or III Ditto. Ditto.
MSC.1/Circ.1638
Annex, page 42
Instrument: Grain Code Part A and B

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
step.

General so would be affected by several issues, such as the
appropriate way(s).
Degree One IV None.
MSC.1/Circ.1638
Annex, page 43

manner.


operations.

• The meanings of "master", etc.
• Actions by personnel on board, such as inspection of
the lashing or strapping during voyages.
chapter in SOLAS to make the code mandatory) for
the onboard inspection with the similar issues in
Taking into account the above potential gaps and/or
Degree Three II and/or III SOLAS chapter VI and the associated codes, not
themes identified, for the carriage of cargoes by ships
amending them one by one.
without persons on board during sailing, one of the
important issues to be considered is how to establish the
procedures for ensuring safety of cargoes in normal
conditions.
MSC.1/Circ.1638
Annex, page 44

operations.

SOLAS chapter VI and the associated codes, not
amending them one by one.

operations.
MSC.1/Circ.1638
Annex, page 45
Instrument: SOLAS chapter VII

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
step.

General so would be affected by several issues, such as the
appropriate way(s).
Degree One IV None.
MSC.1/Circ.1638
Annex, page 46

manner.


operations.

introduce remote operations without seafarers on • The meanings of "master", etc.
board. Another way is to develop new instruments • Actions by personnel on board, such as inspection of
(new code for SOLAS-related issues and new the lashing during voyages.
chapter in SOLAS to make the code mandatory) for • Instructions for onboard procedures.
Degree Three II and/or III SOLAS chapter VI and the associated codes, not Taking into account the above potential gaps and/or
amending them one by one. themes identified, for the carriage of cargoes by ships
without persons on board during sailing, one of the
As mentioned in the general comments, it seems important issues to be considered is how to establish the
difficult to determine the most appropriate way at this procedures for ensuring safety of cargoes in normal
stage because it might only be found during the conditions.
MSC.1/Circ.1638
Annex, page 47

operations.
Regarding the other themes/ potential gaps, one way

is to amend the provisions to safely introduce
autonomous operations without seafarers on board.
Another way is to develop new instruments (new
code for SOLAS-related issues and new chapter in
SOLAS to make the code mandatory) for the
onboard inspection with the similar issues in SOLAS
chapter VI and the associated codes, not amending
them one by one.
Therefore, the Volunteering Members determined

"II and/or III" as the most appropriate way(s) of
addressing MASS operations.
MSC.1/Circ.1638
Annex, page 48
Instrument: IMDG Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)

General addressed is how to evaluate the reduction of risks

appropriate way(s).
MSC.1/Circ.1638
Annex, page 49

Degree One IV None.
manner. Since there is the possibility that "master", "crew",
Degree Two II and/or III As mentioned in the general comments, it seems "responsible person", etc. are not on board, the meanings
difficult to determine the most appropriate way at this of such personnel of the ship should be clarified.

operations.
comments in degree Two. • Actions by personnel on board, such as supervision or
inspection of ro-ro cargo space and judgement by the
Regarding the other potential gaps and/or themes, master in the event of incidents.
Degree Three II and/or III introduce remote operations without seafarers on Taking them into account, for the carriage of cargoes by
board. Another way is to develop new instruments ships without persons on board during sailing, one of the
(new code for SOLAS-related issues and new important issues is how to establish the emergency
chapter in SOLAS to make the code mandatory) for procedures to deal with conditions of leakage, spillage or
the procedures to ensure safety of cargoes in normal fire involving cargoes, as well as the procedures for
and emergency conditions, with the similar issues in ensuring safety in normal conditions.
MSC.1/Circ.1638
Annex, page 50
SOLAS chapter VI and VII and the associated codes,

not amending them one by one.

operations.
Regarding the other themes/ potential gaps, one way

is to amend the provisions to safely introduce
autonomous operations without seafarers on board.
Another way is to develop new instruments (new
code for SOLAS-related issues and new chapter in
SOLAS to make the code mandatory) for the
and emergency conditions, with the similar issues in
Degree Four II and/or III not amending them one by one. Ditto.


operations.
MSC.1/Circ.1638
Annex, page 51
Instrument: IBC Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
step.

General

appropriate way(s).
MSC.1/Circ.1638
Annex, page 52

Degree One IV None.
manner.
• Since there is the possibility that "master", "crew",
Regarding the other themes/potential gaps, the "responsible person", etc. are not on board, the
provisions regarding facilities such as alarms should meanings of such personnel of the ship should be
Degree Two II and/or III be amended to safely introduce remote operations clarified.
with seafarers on board. • Provisions regarding facilities such as alarms should
be amended so that remote operators can also be
On the other hand, as mentioned in the general notified.
comments, it seems difficult to determine the most
appropriate way at this stage because it might only
be found during the discussion on the actual
amendments. However, easy measures such as
developing unified interpretation (UI) should be
avoided to prevent creating confusion and
contradiction.

comments in degree Two. • Systems and appliances which need manual
Degree Three II and/or III operations.
Regarding the other potential gaps and/or themes, • Actions by personnel on board, such as training in
one way is to amend the provisions to safely emergency procedures and fire fighting.
MSC.1/Circ.1638
Annex, page 53
introduce remote operations without seafarers on • Accommodations, spaces normally entered during
board. Another way is to develop new instruments cargo-handling operations and accessibility.
(new code for SOLAS-related issues and new • Facilities such as alarms.
the procedures to ensure safety of cargoes in normal Taking into account the above potential gaps and/or
and emergency conditions, with the similar issues in themes identified, for the carriage of cargoes by ships
SOLAS chapter VI and VII and the associated codes, without persons on board during sailing, one of the
not amending them one by one. important issues to be considered is how to establish the
emergency procedures to deal with conditions of leakage,
As mentioned in the general comments, it seems spillage or fire involving cargoes, as well as the
difficult to determine the most appropriate way at this procedures for ensuring safety in normal conditions.

operations.

the procedures to ensure safety of cargoes in normal
and emergency conditions, with the similar issues in
MSC.1/Circ.1638
Annex, page 54


operations.
Instrument: IGC Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
"Appropriate alternative safety measures should be
step.
General On the other hand, another way could also be

MSC.1/Circ.1638
Annex, page 55


appropriate way(s).
Degree One IV None.
this precondition would have huge impact on the • Since there is the possibility that "master", "crew",
instruments. Therefore, amendment or clarification of "responsible person", etc. are not on board, the
these terms should be done carefully in consistent meanings of such personnel of the ship should be
Degree Two II and/or III manner. clarified.
• Provisions regarding facilities such as alarms should
Regarding the potential gaps and/or themes, the be amended so that remote operators can also be
provisions regarding facilities such as alarms should notified.
be amended to safely introduce remote operations
with seafarers on board.

MSC.1/Circ.1638
Annex, page 56


operations.
Regarding the other potential gaps and/or themes, • The meanings of "master", etc.
• Definitions of normally entered spaces, cargo control
room and cargo control station.
• Systems and appliances which need manual
operations.
• Actions by personnel on board, such as supervision
the onboard supervision with the similar issues in
and fire fighting.
not amending them one by one. • Facilities such as alarms.
Degree Three II and/or III • Accommodations.
difficult to determine the most appropriate way at this Taking into account the above potential gaps and/or
stage because it might only be found during the themes identified, for the carriage of cargoes by ships
discussion on the actual amendments. However, without persons on board during sailing, one of the
easy measures such as developing unified important issues to be considered is how to establish the
interpretation (UI) should be avoided to prevent emergency procedures to deal with conditions of leakage,
creating confusion and contradiction. spillage or fire involving cargoes, as well as the
procedures for ensuring safety in normal conditions.
operations.
MSC.1/Circ.1638
Annex, page 57


the onboard supervision with the similar issues in

operations.
MSC.1/Circ.1638
Annex, page 58
Instrument: INF Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)

General
could relax the regulations.

appropriate way(s).
MSC.1/Circ.1638
Annex, page 59

Degree One IV None.
manner.

operations.
comments in degree Two. • Since "master", "crew", "responsible person", etc. are
not on board, the meanings of such personnel of the
Regarding the other potential gaps and/or themes, ship should be clarified.
one way is to amend the provisions to safely • Provisions regarding systems and appliances which
introduce remote operations without seafarers on need manual operations (fixed fire-extinguishing
board. Another way is to develop new instruments arrangements) should be amended.
(new code for SOLAS-related issues and new • Provisions regarding facilities such as notification and
chapter in SOLAS to make the code mandatory) for shipboard emergency plan should be amended.
fire fighting with the similar issues in SOLAS chapter
MSC.1/Circ.1638
Annex, page 60
II-2 and the associated codes, not amending them

one by one.


operations.

fire fighting with the similar issues in SOLAS chapter
II-2 and the associated codes, not amending them
one by one.

operations.
MSC.1/Circ.1638
Annex, page 61
Instrument: SOLAS chapter IX

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
For MASS operation at degree One:
- still personnel with certified competencies
on board;
- master still on board; and
Degree One IV - no changes to the continued technological
development of ships.
No changes to instrument needed.
For MASS operation at degree Two: 1. role and placement of master and crew
- process control remote (off the ship); 2. remote control station
- still personnel with certified competencies 3. remote operator
on board; 4. connectivity
- still available personnel with certified 5. cybersecurity
competencies with the possibility to take
over; and
Degree Two IV
- themes and potential gaps are with other
instruments.
No changes to instrument needed as long as the

relevant potential gaps and/or themes are
addressed in a new separate instrument addressing
the particulars of MASS operation (MASS Code).
For MASS operation at degree Three: 1. role and placement of master and crew
Degree Three III 2. remote control station
3. remote operator
MSC.1/Circ.1638
Annex, page 62
- process control remote (off the ship) or 4. connectivity

automated on board with intervention 5. cybersecurity
possibility from a remote location; and 6. fundamental issue regarding reduction of risks owing to
- themes and potential gaps are common with the absence of persons on board
other instruments. 7. implication of MASS on search and rescue
If potential gaps are addressed in a new separate

instrument, in order of consistency the most
appropriate way is III.
For MASS operation at degree Four: 1. role and placement of master and crew
- themes and potential gaps are common with 2. cybersecurity
other instruments. 3. fundamental issue regarding reduction of risks owing to
Degree Four III the absence of persons on board
If potential gaps are addressed in a new separate 4. implication of MASS on search and rescue
Instrument: ISM Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
For MASS operation at degree One:
- still personnel with certified competencies
on board;
- master still on board; and
Degree One IV
- no changes to the continued technological
development of ships.
No changes to instrument needed.
MSC.1/Circ.1638
Annex, page 63
For MASS operation at degree Two: 1. role and placement of master and crew
- process control remote (off the ship); 2. remote control station
- still personnel with certified competencies 3. remote operator
on board; 4. connectivity
- still available personnel with certified 5. cybersecurity
competencies with the possibility to take
over; and
Degree Two IV
- themes and potential gaps are common with
other instruments.
No changes to instrument needed as long as the

relevant themes and potential gaps are addressed
in a new separate instrument addressing the
particulars of MASS operation (MASS Code).
For MASS operation at degree Three: 1. role and placement of master and crew
- process control remote (off the ship) or 2. remote control station
automated on board with intervention 3. remote operator
possibility from a remote location; and 4. connectivity
Degree Three III
the absence of persons on board
For MASS operation at degree Four: 1. role and placement of master and crew
Degree Four III the absence of persons on board
MSC.1/Circ.1638
Annex, page 64
Instrument: SOLAS chapter XI-1

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
This chapter does not require any amendments for
Degree One IV degree One.
The circumstances when the master of the vessel is

Degree Two III performing his or her duties from a location not on
board the vessel needs to be clarified.
No actions are needed to address the issue of
onboard certificates at this moment. The FAL
Committee approved FAL.5/Circ.39/Rev.2 on the
Guidelines for the use of electronic certificates.
The Committee further endorsed that, for the time
being, it would be better to keep the guidelines as a
FAL circular, and not to convert it to an Assembly
resolution or incorporate it into the IMO
Compendium, and to continue gathering experience
with respect to the implementation of electronic
certificates. The distinctive objectives of the CSR
Degree Three I, III
document in case of a MASS needs to be taken into
account.

performing his or her duties from a location not on
For unmanned vessels the possibility for having

atmosphere testing instruments provided at the port
instead of a carriage requirement would be
recommended.
MSC.1/Circ.1638
Annex, page 65

Guidelines for the use of electronic certificates. The
Committee further endorsed that, for the time being,
it would be better to keep the guidelines as a FAL
circular, and not to convert it to an Assembly
certificates. The distinctive objectives of the CSR
Degree Four I, III
document in case of a MASS needs to be taken into
account.

For unmanned vessels the possibility for having

atmosphere testing instruments provided at the port
instead of a carriage requirement would be
recommended.
MSC.1/Circ.1638
Annex, page 66
Instrument: ESP Code 2011

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
ESP Code concerns mainly surveys of ships and
Degree One IV
therefore requires no actions.
Degree Two IV
therefore requires no actions.
therefore requires no actions. However, the
Degree Three IV practical solution of having survey report file with all
supporting documents on board might need to be
considered.
therefore requires no actions. However, the
Degree Four IV practical solution of having survey report file with all
supporting documents on board might need to be
considered.
MSC.1/Circ.1638
Annex, page 67
Instrument: RO Code
The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
RO Code concerns monitoring, auditing and
management, cooperations and functions of the
Degree One IV Recognized Organizations including flag State
obligations and therefore has no application to
MASS.
Degree Two IV Recognized Organizations including flag State
MASS.
Degree Three IV Recognized Organizations including flag State
MASS.
Degree Four IV Recognized Organizations including flag State
MASS.
MSC.1/Circ.1638
Annex, page 68
Instrument: Casualty Investigation Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
If a vessel of technical abilities to be of degree Three
or Four would be manned with certified seafarers,
this would have the consequence that the vessel
concerned would cease to be of degree Three or
Four, and would become degree Two (Remotely
controlled ship with seafarers on board: The ship is
General controlled and operated from another location.
Seafarers are available on board to take control and
to operate the shipboard systems and functions).
Seafarers are assumed to be able to take control of
a fully autonomous system if seafarers are on board.
This philosophy was applied to degrees Three and
Four throughout the assessment.
No provisions preventing MASS, in need to be
Degree One IV
amended or clarified were identified.
The definition of a seafarer needs to be amended to
include personnel engaged in remote operation of
the vessel.
It needs to be clarified if the location of a remote

Degree Two II
control centre causes the State in which it is located
to be a substantially interested State to an accident,
which is not located within its waters, territories and
jurisdiction or does not involve any legal entities or
citizens of that State.
MSC.1/Circ.1638
Annex, page 69
The definition of a seafarer needs to be amended to

include personnel engaged in remote operation of
the vessel.

Degree Three II
Degree Four II
Instrument: SOLAS chapter XI-2

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
There is a need to add a definition concerning
Degree One I, II
MASS to the definitions.
Degree Two II, III The circumstances when the master of the vessel is
MSC.1/Circ.1638
Annex, page 70
The issue of remote control operational centres

needs to be regulated at the instrument level where
onboard command or manual operation is
considered as a mandatory requirement. As the
remote control operational centres will affect all
instruments, it is deemed that the most appropriate
way of addressing the issue is by a new instrument
dedicated to the distinct features of MASS
operations.
The exemption allowed under SOLAS XI-2/11 will

require broadening of scope from short international
voyage to all voyages. This would limit the need to
amend the Code.

The ship security alert systems activating point

Degree Three II, III
required to be placed on the bridge needs to be
considered holistically in conjunction with remote
control requirements to be developed.

operations.
MSC.1/Circ.1638
Annex, page 71


The ship security alert systems activating point

required to be placed on the bridge needs to be
considered holistically in conjunction with remote
Degree Four II, III control requirements to be developed.

operations.
Instrument: ISPS Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
No amendments required to ISPS Code
Degree One IV pending necessary amendments done to SOLAS
chapter XI-2.
MSC.1/Circ.1638
Annex, page 72

Degree Two IV pending necessary amendments done to SOLAS
chapter XI-2.
Degree Three IV pending necessary amendments done to SOLAS
chapter XI-2.
Degree Four IV pending necessary amendments done to SOLAS
chapter XI-2.
Instrument: SOLAS chapter XII

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
step.
General The choice of the most appropriate way(s) of doing

MSC.1/Circ.1638
Annex, page 73

appropriate way(s).
Degree One IV None.
Regarding the potential gap and/or themes in the
right column, the provisions should be amended to
safely introduce remote operations with seafarers on
board.
On the other hand, it can also be considered to

develop new instruments (new code for
SOLAS-related issues and new chapter in SOLAS to
make the code mandatory) with the similar issues in
Provisions regarding facilities such as alarms should be
Degree Two II and/or III the other chapters in SOLAS.
amended so that remote operators can also be notified.
As mentioned in general comments, it seems difficult
to determine the most appropriate way at this stage
because it might only be found during the discussion
on the actual amendments.

operations.
Regarding the potential gaps and/or themes in the
safely introduce remote operations without seafarers
• Provisions regarding facilities such as alarms should
on board.
be amended.
• Provisions requiring actions by personnel on board,
Degree Three II and/or III On the other hand, it can also be considered to
such as onboard maintenance, should be amended.
develop new instruments (new code for
SOLAS-related issues and new chapter in SOLAS to • Provisions regarding accessibility should be
make the code mandatory) with the similar issues in amended.
the other chapters in SOLAS.
MSC.1/Circ.1638
Annex, page 74


operations.
Regarding the potential gaps and/or themes in the
safely introduce autonomous operations without
seafarers on board.

develop new instruments (new code for SOLAS-
related issues and new chapter in SOLAS to make
the code mandatory) with the similar issues in the
Degree Four II and/or III other chapters in SOLAS. Ditto.


operations.
MSC.1/Circ.1638
Annex, page 75
Instrument: Bulk carrier bulkhead and double bottom strength standards

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
Degree One IV None.
Degree Two IV None.
Instrument: Standards for owners' inspection and maintenance of bulk carrier hatch covers
The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
General
step.
MSC.1/Circ.1638
Annex, page 76

appropriate way(s).
Degree One IV None.
Degree Two IV None.
Regarding the potential gap/theme, the provisions
should be amended to safely introduce remote
operations without seafarers on board.

Provisions requiring actions by personnel on board, such
Degree Three II and/or III related issues and new chapter in SOLAS to make
as onboard maintenance, should be amended.
SOLAS Convention.

operations.
Regarding the potential gap/theme, the provisions
should be amended to safely introduce autonomous
operations without seafarers on board.
related issues and new chapter in SOLAS to make
MSC.1/Circ.1638
Annex, page 77

SOLAS Convention.

operations.
Instrument: Standards and criteria for side structures of bulk carriers of single-side skin construction
The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
Degree One IV None.
Degree Two IV None.
MSC.1/Circ.1638
Annex, page 78
Instrument: SOLAS chapter XIII

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
MASS application" of all regulations were identified
Degree One IV None.
Degree Two IV None.
Instrument: SOLAS chapter XIV

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
Degree One IV This chapter does not require any amendments.
Degree Two IV This chapter does not require any amendments.
Degree Three IV This chapter does not require any amendments.
Degree Four IV This chapter does not require any amendments.
MSC.1/Circ.1638
Annex, page 79
Instrument: Polar Code

The most
appropriate
way(s) of
MASS
operations
(I, II, III, IV)
The Polar Code applies to MASS and requires no
Degree One IV
actions for degree One.
The Polar Code is an add-on to the requirements of
the SOLAS Convention, and the issue of remote
operation of vessels from a remote control
operational centre cannot be regulated by a
sub-regulation to the Convention.

Degree Two III needs to be regulated at the instrument level where
operations.
Electronic Certificates
Degree Three I, III
MSC.1/Circ.1638
Annex, page 80

certificates.
Remote Control Centres

sub-regulation to the Convention.

operations.
Life-saving appliances
The requirement for life-saving appliances on degree
Three might be in need of further consideration.
However, this possible requirement needs to be
addressed at a convention level. The requirements
in the Polar Code regarding life-saving appliances
are add-ons to the requirements specified in the
SOLAS Convention, and therefore these
requirements apply only if the equipment is fitted,
and no amendments are required.
MSC.1/Circ.1638
Annex, page 81
Electronic Certificates
certificates.
Remote Control Centres
Degree Four I, III sub-regulation to the Convention.

operations.
Life-saving appliances
The requirement for life-saving appliances on degree
Three might be in need of further consideration.
However, this possible requirement needs to be
addressed at a convention level. The requirements
in the Polar Code regarding life-saving appliances
MSC.1/Circ.1638
Annex, page 82
are add-ons to the requirements specified in the

SOLAS Convention, and therefore these
requirements apply only if the equipment is fitted,
and no amendments are required.
Instrument: STCW Convention

The most Reasons for selecting the most appropriate way(s) of addressing MASS operations
Degree of appropriate
Autonomy way(s) of
addressing
MASS
operations
(I, II, III, IV)
Degree One I and/or II With seafarers serving on board, the Convention and Code in its entirety remains applicable to MASS. Some
requirements may need to be amended based on the introduction of new technologies and/or automated
processes. Changes can be made through the existing Convention processes and flexibilities – through
authorized equivalencies or amendments to the codes or regulations.
Degree Two I and/or II Option 1 – Determination that "remote operator is a seafarer"
.1 Changes to the Convention and Code to establish definitions and provisions to include the "remote
operator" can be made through the existing Convention processes and other flexibilities – through authorized
equivalencies or amendments to the codes or regulations.
.2 Some requirements applicable to seafarers may need to be amended to:

1) introduce new technologies and/or automated processes; and
2) address the relationship of the "remote operator" with other seafarers serving on board.
These changes can be made through the existing Convention processes and other flexibilities – through
I and/or II Option 2 – Determination that "remote operator is not a seafarer"
and or III
.1 Provisions necessary to address the "remote operator" could be established through either:
1) existing instrument(s) other than the STCW Convention and Code; or
2) a new instrument.
MSC.1/Circ.1638
Annex, page 83
.2 Some requirements applicable to seafarers may need to be amended to:

1) introduce new technologies and/or automated processes; and
2) address the relationship between the "remote operator" and other seafarers serving on board.
Degree Three I and/or II Option 1 – Determination that "remote operator is a seafarer"
.1 Changes to establish definitions and provisions to include the "remote operator" can be made through the
existing Convention processes and other flexibilities – through authorized equivalencies or amendments to the
codes or regulations.
.2 There are no trained and qualified seafarers serving on board to perform the operational functions on board
the vessel.
III Option 2 – Determination that "remote operator is not a seafarer"
.1 Consistent with the first step assumptions, new provisions necessary to address the "remote operator" will
need to be established through either:
1) existing instrument(s) other than the STCW Convention and Code; or
2) a new instrument.
The provisions will need to include the relationship between seafarers on board and the "remote operator".
However, this relationship will also need to be established in the STCW Convention through the existing
processes and other flexibilities – through authorized equivalencies or amendments to the codes or regulations.
.2 There are no trained and qualified seafarers serving on board to perform the operational functions on board
the vessel. Article 3 (Application) of the STCW Convention stipulates that the Convention applies only to
"seafarers serving on board seagoing ships entitled to fly the flag of a Party…".
Degree Four IV There are no trained and qualified seafarers serving on board to perform the operational functions on board the
vessel.
MSC.1/Circ.1638
Annex, page 84
Instrument: STCW-F Convention

The most Reasons for selecting the most appropriate way(s) of addressing MASS operations
Degree of appropriate
Autonomy way(s) of
addressing
MASS
operations
(I, II, III, IV)
Degree One I and/or II With personnel serving on board fishing vessels, the Convention in its entirety remains applicable to MASS.
Some requirements may need to be amended based on the introduction of new technologies and/or automated
processes. Changes can be made through the existing Convention processes and flexibilities – through
authorized equivalencies or amendments to the regulations.
Degree Two I and/or II Option 1 – Determination that "remote operator is a personnel serving on board seagoing fishing vessel"
1 Changes to the Convention and Code to establish definitions and provisions to include the "remote
operator" can be made through the existing Convention processes and other flexibilities – through
2 Some requirements applicable to personnel serving onboard seagoing fishing vessels may need to be
amended to:
.1 introduce new technologies and/or automated processes; and
.2 address the relationship of the "remote operator" with other personnel serving on board.
MSC.1/Circ.1638
Annex, page 85
I and/or II Option 2 – Determination that "remote operator is not a personnel serving on board seagoing fishing vessel"
and/or III
1 Consistent with the step 1 assumptions, provisions necessary to address the "remote operator" could be
established through either:
.1 existing instrument(s) other than the STCW-F Convention; or
.2 a new instrument.
2 Some requirements applicable to seafarers may need to be amended to:
.1 introduce new technologies and/or automated processes; and
.2 address the relationship between the "remote operator" and other personnel serving on board
fishing vessel.
Degree Three I and/or II Option 1 – Determination that "remote operator is a personnel serving onboard seagoing fishing vessel"
1 Changes to establish definitions and provisions to include the "remote operator" can be made through the
existing Convention processes and other flexibilities – through authorized equivalencies or amendments
to the regulations.
2 There are no trained and qualified personnel serving onboard fishing vessel to perform the operational
functions on board the vessel.
III Option 2 – Determination that "remote operator is not a personnel serving onboard seagoing fishing vessel"
1 Consistent with the step 1 assumptions, provisions necessary to address, new provisions necessary to
address the "remote operator" will need to be established through either:
.1 existing instrument(s) other than the STCW-F Convention; or
.2 a new instrument.
MSC.1/Circ.1638
Annex, page 86
The provisions will need to include the relationship between personnel on board and the "remote operator".
However; this relationship will also need to be established in the STCW-F Convention through the existing
processes and other flexibilities – through authorized equivalencies or amendments to the regulations.
2 There are no trained and qualified seafarers serving on board to perform the operational functions on
board the vessel. Article 3 (Application) of the STCW-F Convention stipulates that the Convention applies
only to "personnel serving onboard seagoing fishing vessels entitled to fly the flag of a Party".
Degree Four IV There are no trained and qualified personnel serving on board seagoing fishing vessels to perform the
operational functions on board the vessel.
Instrument: COLREG 1972

The most
appropriate
way(s) of
Degree of Potential gaps/themes
addressing Reason for selecting the most appropriate way(s) of addressing MASS operations
Autonomy that require addressing
MASS
operations
(I, II, III, IV)
Some of the ways in which bridge watchkeeping and other operations on board will be Terminology, lights,
carried out on MASS will result in distortion or a lack of clarity within COLREG. Degree shapes and sound signals,
Degree One I One is expected to be the least disruptive and as a result the group feels equivalences role of master
as provided for by the instrument or developing interpretations will act as the best means
to address this degree.
Some of the ways in which bridge watchkeeping and other operations on board will be Terminology, lights,
carried out on MASS will result in distortion or a lack of clarity within COLREG. Degree shapes and sound signals,
Two will serve as the intermediary point between degree One and degree Three and will role of master,
Degree Two I and/or II
result in control potentially being shifted to a remote location, as a result it is felt that responsibility of the remote
either equivalences or interpretations as well as the amending of existing instruments will operator
allow for the necessary distortion caused by this new approach to be addressed.
Degree Three represents the biggest shift in shipping and will require necessary Terminology, lights,
amendments to COLREG in order to align itself with future autonomous shipping without shapes and sound signals,
Degree Three I and/or II seafarers on board and bringing about a significant reduction in the level of human role of master,
interaction. It is agreed that COLREG in its current form is still the reference point and responsibility of the remote
should retain as much of its current content as possible. operator, distress signals
MSC.1/Circ.1638
Annex, page 87
Degree Four represents the most future concept in shipping and will require necessary Terminology, lights,
amendments to COLREG in order to align itself with future autonomous shipping as a shapes and sound signals,
Degree Four II direct result of the lack of seafarers on board in any capacity. It is agreed that COLREG role of master,
in its current form is still the reference point and should retain as much of its current responsibility of the remote
content as possible. operator, distress signals
Instrument: CSC
The most
appropriate
way(s) of
Degree of Reason for selecting the most appropriate way(s) of addressing Themes/potential gaps that require
addressing
autonomy MASS operations addressing
MASS
operations
(I, II, III, IV)
"MASS application" of all articles of the Convention was ".B" or ".D" and
Degree One IV None.
no action is required.
Degree Two IV None.
At the commenting stage, one member chose "II and/or III" with a
comment that "Communication between ship and port should be
considered involving remote control centre." However, CSC 1972 does
not include any provision regarding communication between ship and
port.
Degree Four IV Ditto. None.
MSC.1/Circ.1638
Annex, page 88
Instrument: IMO Instruments Implementation Code (III Code)

Degree of The most Reason for selecting the most appropriate way(s) Potential gaps/themes that require addressing
autonomy appropriate of addressing MASS operations
way(s) of
addressing
MASS
operations
(I, II, III, IV)
Degree One IV All provisions of the code are applicable to degree None.
One MASS.
Degree Two II Some parts of the Code, such as obligations of flag, Additional/alternate/equivalent responsibilities arising out
coastal and port States, may need revision to account of amendments to instruments referred to, within the III
for additional/alternate/equivalent responsibilities in Code.
relation to MASS operating in degree Two.
Degree Three II Some parts of the Code, such as obligations of flag, Additional/alternate/equivalent responsibilities arising out
relation to MASS operating in degree Three.
Degree Four II Some parts of the Code, such as obligations of flag, Additional/alternate/equivalent responsibilities arising out
relation to MASS operating in degree Four.
General The provisions of the III Code, are relevant to all
degrees of MASS. Some parts of the Code, such as
obligations of the flag, coastal and port States may
need revision to account for additional/alternate/
equivalent responsibilities in relation to MASS
operating in degrees Two, Three and Four.
As the III Code deals with the implementation of IMO
instruments in general, additional requirements
arising out of amendments to IMO instruments may
need to be accounted for.
MSC.1/Circ.1638
Annex, page 89
Instrument: International Code on Intact Stability, 2008 (2008 IS Code) – Part A

way(s) of
addressing
MASS
operations
(I, II, III, IV)
Degree One IV Part A of the IS Code remains relevant, as written to None.
this category of MASS.
Degree Two II With regard to regulations referring to "master", Since, degree Two MASS operates in the remote
amendment may be required in order to clarify the operation mode, the term "master" needs to be clarified,
equivalent responsible authority, in the remote whether it would include the "person in command" during
operation mode. remote operation mode.
Degree Three II With regard to regulations referring to "master", As a degree Three MASS is remotely operated, the term
amendments may be required in order to clarify the "master" needs to be clarified, whether it would include the
equivalent responsible authority, in degree Three. "person in command" during remote operation mode.
Degree Four II With regard to regulations referring to "master", As a degree Four MASS is fully autonomous, the term
amendments may be required in order to clarify the "master" needs to be clarified to identify an equivalent
equivalent responsible authority, in degree Four. responsible Authority.
General In general, Part A of the IS code is considered
relevant to all degrees of MASS.
For MASS of degree Two, Three and Four, with
regard to references to "master" used in sections of
Part A, amendments may be required as identified for
the respective categories of MASS.
MSC.1/Circ.1638
Annex, page 90
Instrument: Protocol of 1988 relating to LL 1966 (LL PROT 1988)

way(s) of
addressing
MASS
operations
(I, II, III, IV)
Degree One IV "MASS application" of all regulations were identified None.
as ".B" in step 1 and no action is required.
Degree Two IV "MASS application" of all regulations were identified None.
Degree Three IV "MASS application" of all regulations were identified None.
Degree Four IV "MASS application" of all regulations were identified None.
General LL PROT 1988 is considered to generally apply to all
degrees of MASS with the understanding that they
will be considered as New Ships, under the
Convention.
Instrument: International Convention on Load Lines, 1966 (LL 1966)

way(s) of
addressing
MASS
operations
(I, II, III, IV)
MSC.1/Circ.1638
Annex, page 91
Degree One II "MASS application" of most regulations were Minor amendments may be required to generic sections
identified as ".B" in Step 1. Minor amendments may such as application, definitions etc. to address the
be required to generic sections such as application, inclusion of this new category of Vessel (degree One
definitions etc. to address the inclusion of this new MASS).
category of Vessel (degree One MASS).
Degree Two II With regard to regulations referring to "master", Since the vessel operates in the remote operation mode,
amendment may be required in order to clarify the the term "master" needs to be clarified, whether it would
equivalent responsible authority, in the remote include the "person in command" during remote operation
operation mode. mode.
Degree Three II With regard to regulations referring to "master", As a degree Three vessel is remotely operated, the term
amendments may be required in order to clarify the "master" needs to be clarified, regarding whether it would
equivalent responsible authority, in degree Three. include the "person in command" during remote operation
Additionally, provisions which presume/require mode.
manual intervention for their application may need
amendment owing to no seafarers being present on Provisions which presume/require manual intervention for
board. The LL 1966 contains several provisions for their application may need amendments owing to the
protection of the crew (i.e. guard rails elevated absence of seafarers on board.
walkways etc.). For ships without seafarers on board
(i.e. autonomy degrees Three and Four) these
features are not necessary. However, whether
protection arrangements should still be required,
needs to be addressed.
Degree Four II With regard to regulations referring to "master", As a degree Four vessel is fully autonomous, the term
amendments may be required in order to clarify the "master" needs to be clarified to identify an equivalent
equivalent responsible authority, in degree Four. responsible Authority.
Additionally, provisions which presume/ require
manual intervention for their application may need Provisions which presume/require manual intervention is a
adjustment owing to no seafarers being present on gap for this category of vessel, owing to absence of
board. The LL 1966 contains several provisions for seafarers on board.
protection of the crew (i.e. guard rails elevated
walkways, etc.). For ships without seafarers on board
(i.e. autonomy degrees Three and Four) these
features are not necessary. However, whether
protection arrangements should still be required,
needs to be addressed.
MSC.1/Circ.1638
Annex, page 92
General Articles of LL 1966, as amended by LL PROT 88:

While most articles can be retained as they are,
amendments may be required to address the
following issues to cater for MASS.
Potential gaps and/or themes that require addressing
for specific gaps that have been identified for Articles:
Article 2 – Definitions: Where new definitions may
need to be added based on the amendments to other
articles and annexes.
Article 14 – Initial, Renewal and Annual Surveys:
Where it may be clarified that the surveying of all
listed items in para. 1(c) may not be applicable to
MASS without seafarers on board.
Article 21 – Control: Where it should be clarified as to
how to implement control measures for MASS
without seafarers on board.
General: The concept of assigning freeboards and
Load Line Marks remain relevant in the context of
safety of all degrees of MASS, and hence most
regulations remain applicable to all categories of
MASS, with amendments being required for
categories of MASS without crew on board (degrees
Three and Four), in relation to activities requiring
manual intervention/presence of crew on board.
Further, there are explicit/implicit assumptions in the
LL 1966 "General notes" that certain pre-departure
functions will be accomplished by master and crew
(safe loading, ballasting, stability, stowage, etc.). For
MASS without seafarers on board, responsibility for
these pre-departure functions needs to be
addressed.
With respect to the LL 1966 certificate and Record of
Conditions of Assignment, consideration should be
given to whether or not these need to include a
notation regarding the vessel's autonomous status.
MSC.1/Circ.1638
Annex, page 93
Instrument: International Convention on Maritime Search and Rescue, 1979 (SAR Convention). France, Spain and Turkey
The most
appropriate Reason for selecting the most appropriate Potential gaps/themes that require addressing
way(s) of way(s) of addressing MASS operations
Degree of
addressing
autonomy
MASS
operations
(I, II, III, IV)
Since no potential gaps have been identified none None
of the first three ways of addressing such MASS
operation have been selected. Therefore, this
Degree One IV
degree would meet the provisions of the SAR
Convention as it is.
Tacit acceptance procedure for amendments is not Ability of MASS to perform as SAR facility, on-scene
applicable to paragraphs 2.1.4, 2.1.5, 2.1.7, 2.1.10, coordinator or alerting post. (2.1.1, 2.1.9, 2.2, 2.3, 2.5,
3.1.2, and 3.1.13. No gap has been identified in 4.2.1, 4.2.2, 4.2.3, 4.2.4, 4.4, 4.5 and 4.7)
those paragraphs; therefore, any amendment to the
Convention is likely to be feasible using tacit Reference to the master (3.1.9)
acceptance procedure.
The SAR system, as it stands, is globally able to

Degree Two II
cope with the emergence of autonomous vessels.
Mostly potential gaps need clarification which may

be addressed most appropriately by amendments.
The way the SAR Convention should be adapted

taking into account the adaptation of the COLREG
and SOLAS chapters IV and V.
Tacit acceptance procedure for amendments is not Inconsistency between the concept of "rescue" and
applicable to paragraphs 2.1.4, 2.1.5, 2.1.7, 2.1.10, "distress" with regard to unmanned MASS being
Degree Three II
3.1.2, and 3.1.13. No gap has been identified in considered as "vessel and other craft".1.3.11, 1.3.12,
those paragraphs; therefore, any amendment to the 1.3.13, and potentially 1.3.7 and 1.3.9
MSC.1/Circ.1638
Annex, page 94
Convention is likely to be feasible using tacit

acceptance procedure. Ability of MASS to perform as SAR facility, on-scene
coordinator or alerting post. (2.1.1, 2.1.9, 2.2, 2.3, 2.5,
The SAR system, as it stands, is globally able to 4.2.1, 4.2.2, 4.2.3, 4.2.4, 4.4, 4.5 and 4.7)
Reference to the master (3.1.9)
Mostly potential gaps need clarification which may

Tacit acceptance procedure for amendments is not Inconsistency between the concept of "rescue" and
applicable to paragraphs 2.1.4, 2.1.5, 2.1.7, 2.1.10, "distress" with regard to unmanned MASS being
3.1.2, and 3.1.13. No gap has been identified in considered as "vessel and other craft".1.3.11, 1.3.12,
those paragraphs; therefore, any amendment to the 1.3.13, and potentially 1.3.7 and 1.3.9
Convention is likely to be feasible using tacit
acceptance procedure. Ability of MASS to perform as SAR facility, on-scene
coordinator or alerting post. (2.1.1, 2.1.9, 2.2, 2.3, 2.5,
Degree Four II
The SAR system, as it stands, is globally able to 4.2.1, 4.2.2, 4.2.3, 4.2.4, 4.4, 4.5 and 4.7)
Mostly potential gaps need clarification, which may Reference to the master (3.1.9)
MSC.1/Circ.1638
Annex, page 95
Instrument: International Tonnage Convention on Tonnage Measurement of Ships, 1969

The most
Degree of
addressing
autonomy
MASS
operations
(I, II, III, IV)
Generally, the TONNAGE 1969 Convention is
equally applicable to MASS and non-MASS
operations. However, for degrees of autonomy Two,
General Three and Four, article 2, regulation 2 and possibly
also regulation 6 may require appropriate
interpretations to provide clarifications and avoid
ambiguities.
At the RSE for the first step all articles and None.
regulations were decided to be MASS application
Degree One IV
".B", i.e. apply to MASS and do not prevent MASS
operations and require no actions.
At the RSE for the first step there was general Definition of master, crew and passenger needs to be
consensus1 that all articles and regulations were clarified in the context of MASS operation. This
decided to be MASS application ".B" except for clarification could be addressed through developing
article 2 and regulation 2. interpretations.
Since both article 2 (Definitions) and regulation 2 The calculation of volumes (Reg. 6) that are included in
Degree Two I (Definitions of terms used in the annexes) relates the calculation of gross and net tonnages may need to be
definitions it is expected these definition issues can further considered. Therefore, the reason for UK's
be addressed through appropriate interpretation(s). disagreement with MASS application ".B" for Reg. 6
(Calculation of Volumes) needs to be identified to see if it
Note 1: at the commenting stage at the first step can be addressed through interpretation(s).
United Kingdom disagreed with MASS application
".B" for regulation 6.
MSC.1/Circ.1638
Annex, page 96
The most
Degree of
addressing
autonomy
MASS
operations
(I, II, III, IV)
At the RSE for the first step there were general Definition of master, crew and passenger needs to be
Degree Three I (Definitions of Terms used in the annexes) relates the calculation of gross and net tonnages may need to be
definitions it is expected these definition issues can further considered. Therefore, the reason for United
be addressed through appropriate interpretation(s). Kingdom's disagreement with MASS application ".B" for
Reg. 6 (Calculation of volumes) needs to be identified to
Note 1: at the commenting stage at the first step see if it can be addressed through interpretation(s).
At the RSE for the first step there were general Definition of master, crew and passenger needs to be
Degree Four I (Definitions of terms used in the annexes) relates the calculation of gross and net tonnages may need to be
definitions it is expected these definition issues can further considered. Therefore, the reason for United
be addressed through appropriate interpretation(s). Kingdom's disagreement with MASS application ".B" for
Reg. 6 (Calculation of volumes) needs to be identified to
Note 1: at the commenting stage at the first step see if it can be addressed through interpretation(s).
MSC.1/Circ.1638
Annex, page 97
Appendix 3
REFERENCES TO IMO DOCUMENTS PUBLISHED BEFORE AND DURING THE RSE
MSC documents
MSC 98/20/2 Denmark, Estonia, Maritime Autonomous Surface Ships Proposal
Finland, Japan, for a regulatory scoping exercise
Netherlands, Norway,
Republic of Korea, United
Kingdom and United
States
MSC 98/20/13 ITF Comments on document MSC 98/20/2

MSC 98/23 Secretariat Report of the Maritime Safety Committee on its
ninety-eighth session
MSC 99/5 Secretariat Comments on the regulatory scoping exercise
MSC 99/5/1 IFSMA and ITF Comments and proposals on the way forward
for the regulatory scoping exercise
MSC 99/5/2 ICS Proposals for the development of a work plan
MSC 99/5/3 Finland, Liberia, Recommendations on identification of potential

Singapore, South Africa, amendments to existing IMO instruments
Sweden
MSC 99/5/4 France Considerations on and proposals for the
methodology to use within the framework of the
regulatory scoping exercise
MSC 99/5/5 Australia, Canada, Plan of approach for the scoping exercise
Denmark, Estonia,
Finland, Japan,
Netherlands, Norway,
Singapore, Sweden,
United Kingdom, United
States, IMarEST and
IMCA
MSC 99/5/6 Finland Considerations on definitions for levels and
concepts of autonomy
MSC 99/5/7 China and Finland Proposal on the work plan of the regulatory
scoping exercise for the use of MASS
MSC 99/5/8 China and Liberia Recommendations on categorization and

regulatory scoping exercise of MASS
MSC 99/5/9 Japan Japan's perspective on regulatory scoping
exercise for the use of MASS
MSC 99/5/10 ITF General comments on a way forward
MSC 99/5/11 Turkey Comments on documents MSC 99/5, MSC
99/5/2, MSC 99/5/5, MSC 99/5/8 and
MSC 99/5/9
MSC 99/5/12 United States Comments on document MSC 99/5/5
MSC 99/INF.3 Denmark Final Report: Analysis of Regulatory Barriers to
the use of Autonomous Ships
MSC 99/INF.5 IFSMA and ITF Regulatory Scoping Exercise for the use of
Maritime Autonomous Surface Ships (MASS)
MSC.1/Circ.1638
Annex, page 98
MSC 99/INF.8 CMI Work conducted by the CMI International

Working Group on Unmanned ships
MSC 99/INF.13 Finland Establishing international test area

"Jaakonmeri" for autonomous vessels
MSC 99/INF.14 Japan Studies conducted in Japan on mandatory

regulations relating to Maritime Autonomous
Surface Ships – SOLAS, STCW and
COLREGs
MSC 99/INF.16 Norway Presentation by Norway on 21 May 2018 on
the "YARA Birkeland" development
MSC 99/WP.9 Secretariat Report of the Working Group on Maritime

Autonomous Surface Ships (MASS)

ninety-ninth session
MSC 100/5 Finland Report of the Correspondence Group on
MASS
MSC 100/5/1 ISO Proposal for a classification scheme for degrees
of autonomy
MSC 100/5/2 Norway and BIMCO Interim guidelines for MASS trials
MSC 100/5/3 Republic of Korea Proposals for the development of interim
guidelines for Maritime Autonomous Surface
Ships (MASS) trials
MSC 100/5/4 Secretariat Comments on document MSC 100/5
MSC 100/5/5 Japan Comments on document MSC 100/5
MSC 100/5/6 Australia, Denmark, Comments on document MSC 100/5
Finland, France and
Turkey
MSC 100/5/7 China Comments on document MSC 100/5
MSC 100/5/8 United States Comments on document MSC 100/5
MSC 100/INF.3 Secretariat Initial review of IMO instruments under the
purview of MSC
MSC 100/INF.6 China Preliminary analysis of the International
Regulations for Preventing Collisions at Sea,
1972
MSC 100/INF.10 Republic of Korea Results of technology assessment on Maritime

100th session
Status report – Progress of the regulatory
MSC 101/5 Secretariat
scoping exercise
MSC 101/5/1 ITF Comments and proposals for interim guidelines
for MASS trials
MSC 101/5/2 China The initial review of the mandatory IMO
instruments related to maritime safety and
security
MSC 101/5/3 China Proposals on key aspects of the interim
guidelines for MASS trials
MSC.1/Circ.1638
Annex, page 99
Proposal for terms to be avoided,

MSC 101/5/4 Finland and France
recommended terms and draft of glossary
MSC 101/5/5 Finland, Japan, Norway, Interim guidelines for MASS trials
Republic of Korea,
Singapore, United Arab
Emirates and BIMCO
MSC 101/5/6 Republic of Korea Comments on documents MSC 101/5/5 and
MSC 101/INF.17
MSC 101/INF.17 Finland, Japan, Norway Draft interim guidelines for MASS trials
and Republic of Korea

Report of the Maritime Safety Committee on its
MSC 101/24 Secretariat
101st session
MSC 102/5 Secretariat Status report – progress of the regulatory
scoping exercise
MSC 102/5/1 Secretariat Report of the Intersessional Working Group on
Maritime Autonomous Surface Ships
MSC 102/5/2* IFSMA Comments on document MSC 102/5/1 –
potential gaps and themes regarding the role of
the shipmaster
MSC 102/5/3 Marshall Islands Summary of results of the second step and
conclusion of the RSE for the International
Regulations for Preventing Collisions at Sea
1972 (COLREG)
MSC 102/5/4 Belgium, China, Summary of results of the second step of the
Netherlands RSE for SOLAS chapter III and the LSA Code
MSC 102/5/5 India Summary of results of the second step of the
RSE for LL 1966, LL PROT 1988, IS Code Part
A and III Code
MSC 102/5/6 France Summary of results of the second step of the
RSE for SOLAS chapter II-1
MSC 102/5/7 Germany List of common potential gaps/themes
identified during the first step of RSE for STCW
Convention and Code, STCW-F, SOLAS, ISM
Code, TONNAGE 1969, LL 1966, LL PROT
1988, IS Code, III Code, COLREG and SAR
1979
MSC 102/5/8 Liberia Summary of results of the RSE for the
International Convention on Tonnage
Measurement of Ships, 1969 (TONNAGE
1969)
MSC 102/5/9 China Summary of results of the second step of the
RSE for SOLAS chapter V
MSC 102/5/10 Finland Summary of results of the second step of the
RSE for SOLAS chapter XI-1 and related
codes
RSE for SOLAS chapter XI-2 and the ISPS
Code
RSE for SOLAS chapter XIV and the Polar
Code
MSC 102/5/13 France, Spain Summary of results of the second step of the
RSE for SAR 1979 Convention
MSC.1/Circ.1638
Annex, page 100
MSC 102/5/14* Russian Federation Development of interim regulatory measures

for operation of MASS in the Russian
Federation
MSC 102/5/15 Turkey Summary of the results of the second step of
the RSE for SOLAS chapter IV
MSC 102/5/16* CMI Summary of results of analysis of IMO
instruments under the purview of the Maritime
Safety Committee
MSC 102/5/17 United States Summary of results of the second step of the
RSE for STCW Convention and Code
MSC 102/5/18 ISO Proposed terminology for MASS
MSC 102/5/19 Japan Summary of results of the second step of the
RSE for SOLAS chapter II-2 and associated
codes
RSE for SOLAS chapter VI and associated
codes
RSE for SOLAS chapter VII and associated
codes
MSC 102/5/22 Japan Summary of the results of the second step of
the RSE for SOLAS chapter XII and associated
standards
the RSE for SOLAS chapter XIII
the RSE for CSC 1972
MSC 102/5/25 Norway Summary of results of the second step of the
RSE for SOLAS chapter IX and the ISM Code
the RSE for the STCW-F Convention
MSC 102/5/27 Japan Japan's perspective on further work after the
completion of the RSE
MSC 102/5/28* IMSO Comments on document MSC 102/5/1 –
potential gaps and themes regarding
connectivity, cybersecurity and the implication
of MASS on search and rescue
MSC 102/5/29 Russian Federation Ongoing MASS trials in the Russian Federation
MSC 102/5/30 Republic of Korea Comments on documents MSC 102/5/1,
MSC 102/5/2 and MSC 102/5/7
MSC 102/5/31 Republic of Korea Comments on document MSC 102/5/18
MSC 102/5/32 China Comments on document MSC 102/5/1
MSC 102/INF.8 Japan Report on MASS trials conducted in
accordance with the Interim Guidelines for
MASS trials
MSC 102/INF.17 Finland Strategic themes in MASS perspective
MSC 103/5 IACS Comments on documents MSC 102/5/1,
MSC 102/5/7, MSC 102/5/27,
MSC 102/5/32 and MSC 102/5/18
MSC 103/5/1 Republic of Korea Comments on the potential gaps and themes
identified by the results of the RSE
MSC 103/5/2 Islamic Republic of Iran Comments on documents MSC 102/5/18,
MSC 102/5/7 and MSC 103/5 and ʺcommon
and goal-based understanding on these main
issues, common potential gaps and themes
identified during the RSE".
MSC.1/Circ.1638
Annex, page 101
MSC 103/5/3 ISO Comments on document MSC 102/5/18

MSC 103/5/4 Japan Comments on documents MSC 102/5/9,
MSC 102/5/11, MSC 102/5/15 and
MSC 102/5/27
MSC 103/5/7* Russian Federation Comments on document MSC 102/5/14
MSC 103/5/8* Russian Federation Comments on document MSC 102/5/14
MSC 103/5/9 Russian Federation Comments on document MSC 102/5/29
MSC 103/5/10* Russian Federation Comments on documents MSC 102/5/1,
MSC 102/5/3 and MSC102/5/4
MSC 103/5/11 Russian Federation Comments on documents MSC102/5/4,
MSC 102/5/9, MSC 102/5/10, MSC 102/5/11,
MSC 102/5/12, MSC102/5/16 and
MSC 102/INF.17
MSC 103/5/12 Russian Federation Comments on documents MSC102/5/4,
MSC 102/5/9, MSC 102/5/10, MSC 102/5/11,
MSC 102/5/12 and MSC 102/INF.17

103rd session
* Following the decision of MSC 103, this document has been kept in abeyance for future
consideration, as appropriate.
ISWG documents
ISWG/MASS 1/1/Rev.1 Secretariat Provisional agenda
ISWG/MASS 1/2 Norway Results of the first step of the regulatory
scoping exercise analysing possible gaps in
SOLAS chapter IX and the ISM Code in
relation to the safe operation of Maritime
ISWG/MASS 1/2/1 France Summary of results of the first step of the
RSE for SOLAS chapter II-1
ISWG/MASS 1/2/2 France and Spain Summary of results of the first step of the
RSE for International Convention on
Maritime Search and Rescue, 1979
ISWG/MASS 1/2/3 Japan Summary of results of the first step of the
RSE for SOLAS chapter II-2 and associated
codes
RSE for SOLAS chapter VI and associated
codes
RSE for SOLAS chapter VII and associated
codes
ISWG/MASS 1/2/6 Japan Findings and common issues identified in
the initial review of chapters II-2, VI and VII
of the annex to SOLAS 1974 and the
associated codes
RSE for SOLAS chapter XII and associated
standards
MSC.1/Circ.1638
Annex, page 102

RSE for SOLAS chapter XIII
RSE for SOLAS chapter XIII
RSE for CSC 1972
RSE for STCW-F 1995
ISWG/MASS 1/2/11 Belgium and Summary of results of the first step of the
Netherlands RSE for SOLAS chapter III and the
LSA Code
ISWG/MASS 1/2/12 Finland Summary of results of the first step of the
RSE for SOLAS chapter XI-1 and related
codes
RSE for SOLAS chapter XI-2 and the related
ISPS Code
RSE for SOLAS chapter XIV and the related
Polar Code
ISWG/MASS 1/2/15 Turkey Summary of results of the first step of the
RSE for SOLAS chapter IV
ISWG/MASS 1/2/16 China Summary of results of the first step of the
ISWG/MASS 1/2/16 China Summary of results of the first step of the
ISWG/MASS 1/2/17 Liberia Summary of results of the first step of the
RSE for International Convention on
Tonnage Measurement of Ships, 1969
(TONNAGE 1969)
ISWG/MASS 1/2/18 India Summary of results of the first step of the
RSE for LL 66, PROT 88, IS Code Part A
and III Code
ISWG/MASS 1/2/19 Marshall Islands Summary of results of the first step of the
RSE for the International Regulations for
Preventing Collisions at Sea 1972
(COLREGs)
ISWG/MASS 1/2/20 United States Summary of results of the first step of the
RSE for the STCW Convention and Code
ISWG/MASS 1/3 China Proposals on the guidance for use in the
second step
ISWG/MASS 1/3/1 China Proposal on the second step of the
regulatory scoping exercise of the
International Regulations for Preventing
Collisions at Sea, 1972
ISWG/MASS 1/3/2 Secretariat Regulatory Scoping Exercise
ISWG/MASS 1/3/3 Japan Comments on document
ISWG/MASS 1/3/1
ISWG/MASS 1/6 Secretariat Report of the Intersessional Working Group
on Maritime Autonomous Surface Ships
MSC.1/Circ.1638
Annex, page 103
MSC circulars
MSC.1/Circ.1604 Interim Guidelines for MASS trials
MSC.1/Circ.1638 Outcome of the regulatory Scoping Exercise for the use of

IMO circular letters
Circular Letter No.3945 Intersessional Working Group on Maritime Autonomous

Surface Ships (MASS) (2 to 6 September 2019)
Circular Letter No.3945/Add.1 Additional information on the Intersessional Working

Group on Maritime Autonomous Surface Ships (MASS)
(2 to 6 September 2019)
Circular Letter No.3956 New GISIS module for the regulatory scoping exercise on
___________
Attachment 8. to
E
4 ALBERT EMBANKMENT
LONDON SE1 7SR
Telephone: +44 (0)20 7735 7611 Fax: +44 (0)20 7587 3210
MSC.8/Circ.2
1 June 2021
VOLUNTARY EARLY IMPLEMENTATION OF THE AMENDMENTS TO

THE SOLAS CONVENTION AND THE LSA CODE
ADOPTED BY RESOLUTIONS MSC.482(103) AND MSC.485(103), RESPECTIVELY
1 The Maritime Safety Committee, at its 103rd session (5 to 14 May 2021), adopted
amendments to SOLAS regulation III/33.2 and paragraph 4.4.1.3.2 of the LSA Code by
resolutions MSC.482(103) and MSC.485(103), respectively. The expected entry-into-force
date of the aforementioned amendments is 1 January 2024.
2 In adopting the amendments to the SOLAS Convention and the LSA Code, the
Committee, having considered the need for their voluntary early implementation, in
accordance with the Guidelines on the voluntary early implementation of amendments to the
1974 SOLAS Convention and related mandatory instruments (MSC.1/Circ.1565), agreed to
invite SOLAS Contracting Governments to implement them prior to the entry-into-force date.
3 Voluntary early implementation of the amendments by a Contracting Government

should be communicated to the Organization, for dissemination through GISIS. In addition, a
Contracting Government may also consider the use of the existing provisions for equivalent
arrangements under SOLAS regulation I/5 to cover the interim period between the date of the
voluntary early implementation and the entry-into-force date of the amendments.
4 A Contracting Government, in line with paragraph 1.2.4 of the Procedures for port
State control, 2019 (resolution A.1138(31)), as may be amended, when acting as a port State,
should refrain from enforcing its decision to voluntarily implement the amendments early on
ships flying the flag of other Contracting Governments, calling at its ports.
5 Contracting Governments, when undertaking port State control activities, should take
into account the present invitation and any subsequent notifications communicated by other
Contracting Governments through GISIS.
6 Contracting Governments are invited to be guided accordingly and to bring the

contents of this circular to the attention of all concerned, especially port State control
authorities and recognized organizations.
___________
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Subject

Summary of the Outcomes of MSC 103

1. Adopted mandatory requirements

Applied: on or after 1 January 2024

Applied: on or after 1 January 2024

(3) Amendments to 2011 ESP Code (See attachment 2)

Applied: on or after 1 January 2023

(4) Amendments to chapter 9 of the FSS Code (See attachment 3)

Applied: on or after 1 January 2024

2. Approved guidelines etc.

(2) Consideration of safety matters on use of low sulphur fuel

For any questions about the above, please contact:

NIPPON KAIJI KYOKAI (ClassNK)

AMENDMENTS TO THE INTERNATIONAL CONVENTION FOR THE

THE MARITIME SAFETY COMMITTEE,

RECALLING Article 28(b) of the Convention on the International Maritime Organization

1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to

2 DETERMINES, in accordance with article VIII(b)(vi)(2)(aa) of the Convention, that

3 INVITES Contracting Governments to the Convention to note that, in accordance

4 REQUESTS the Secretary-General, for the purposes of article VIII(b)(v) of

5 REQUESTS ALSO the Secretary-General to transmit copies of this resolution and

AMENDMENTS TO THE INTERNATIONAL CONVENTION FOR THE

2 The water level detectors required by paragraph 1 shall:

Regulation 33 – Survival craft embarkation and launching arrangements

1 Paragraph 33.2 is replaced by the following:

AMENDMENTS TO THE INTERNATIONAL CODE ON THE ENHANCED PROGRAMME

THE MARITIME SAFETY COMMITTEE,

RECALLING Article 28(b) of the Convention on the International Maritime Organization

RECALLING ALSO resolution A.1049(27), by which the Assembly adopted the

1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to

2 DETERMINES, in accordance with article VIII(b)(vi)(2)(bb) of the Convention, that the

3 INVITES Contracting Governments to the Convention to note that, in accordance

4 REQUESTS the Secretary-General, for the purposes of article VIII(b)(v) of

5 REQUESTS ALSO the Secretary-General to transmit copies of this resolution and

AMENDMENTS TO THE INTERNATIONAL CODE ON THE ENHANCED PROGRAMME

CODE ON THE ENHANCED PROGRAMME OF INSPECTIONS DURING

CODE ON THE ENHANCED PROGRAMME OF INSPECTIONS DURING

MINIMUM REQUIREMENTS FOR THICKNESS MEASUREMENTS AT RENEWAL

1 In the table for "Minimum requirements for thickness measurements at renewal

"1 Suspect areas"

AMENDMENTS TO THE INTERNATIONAL CODE FOR FIRE SAFETY SYSTEMS

THE MARITIME SAFETY COMMITTEE,

RECALLING Article 28(b) of the Convention on the International Maritime Organization

1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to the

2 DETERMINES, in accordance with article VIII(b)(vi)(2)(aa) of the Convention, that the

3 INVITES Contracting Governments to note that, in accordance with

4 REQUESTS the Secretary-General, in conformity with article VIII(b)(v) of the

AMENDMENTS TO THE INTERNATIONAL CODE FOR FIRE SAFETY SYSTEMS

2.1 General requirements

AMENDMENTS TO THE INTERNATIONAL LIFE-SAVING APPLIANCE CODE

THE MARITIME SAFETY COMMITTEE,

RECALLING Article 28(b) of the Convention on the International Maritime Organization

RECALLING ALSO resolution MSC.48(66), by which it adopted the International Life-Saving

1 ADOPTS, in accordance with article VIII(b)(iv) of the Convention, amendments to the

2 DETERMINES, in accordance with article VIII(b)(vi)(2)(aa) of the Convention, that the

3 INVITES Contracting Governments to note that, in accordance with

4 REQUESTS the Secretary-General, in conformity with article VIII(b)(v) of the

AMENDMENTS TO THE INTERNATIONAL LIFE-SAVING APPLIANCES CODE

4.4 General requirements for lifeboats

1 Paragraph 4.4.1.3.2 is replaced by the following: