Brief: III 12

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Overview: Brief: III 12

The IMO Sub-Committee on Implementation of IMO Instruments (III) held its 12th session from 20 to 24 July 2026. During the session, the Sub-Committee launched a revision of the ISM Code implementation Guidelines, with completion targeted for 2028. It also agreed on a remote survey eligibility coding system for the Harmonized System of Survey and Certification (HSSC) Guidelines, confirmed enhanced provisions for Pilot Transfer Arrangement mandatory from 1 January 2028, and advanced the development of new guidance for Port State Control inspection on machinery and maintenance.

This Brief provides an overview of the more significant issues progressed at this session.

Key Takeaways

ISM Code Overhaul Launched: A Correspondence Group has been established with a roadmap to develop draft amendments for III 13 (Summer 2027). The scope for 2028 includes safety culture, harassment prevention, fatigue management, Management of Change, digital Safety Management Systems, and data-driven safety measurement.
Machinery and Maintenance in Port State Control Crosshairs: The number of maintenance-related detentions has nearly doubled. New detailed inspection guidance has been proposed but requires further development before inclusion as a Port State Control Procedures appendix. A Correspondence Group has been established to progress the work.
Remote Survey Coding Agreed: A line-by-line Y/N/C coding approach was adopted for every survey item in the Harmonized System of Survey and Certification (HSSC) Guidelines, with clarification text for all three codes to be developed at a later stage.
Pilot Transfer Arrangements Survey Provisions: More detailed provisions of survey items were agreed, covering strongpoints, manropes, type-approval certification, maintenance records, crew familiarization, and means of communication; mandatory from 1 January 2028.
New Safety Outputs Advancing to the Maritime Safety Committee: Self-unloading bulk carrier fire safety and inflatable lifejacket doffing and deflation instructions to be considered by MSC 112 in December 2026.
Tanker Operators - CO₂ monitoring issue remains unresolved: The Sub-Committee rejected the proposed unified interpretation as it is not in line with the Committees' method of work for non-mandatory resolutions. Interested parties are invited to submit proposals for a new output to revise Resolution MSC.581(110) directly. Tanker operators should continue to ensure that their enclosed space entry procedures clearly document the relevant hazards based on a risk assessment.