IP Code update

At its’ 106^th session, IMO’s Maritime Safety Committee adopted the new mandatory International Code of Safety for Ships Carrying Industrial Personnel (IP Code) (insert link to MSC 106//3/1) which has been specifically developed to ensure the safety of people, designated as “Industrial Personnel”, transported to work on offshore facilities.  Such personnel may be engaged in the construction, maintenance, decommissioning, operation, or servicing of offshore facilities, such as windfarms, as well as offshore oil and gas installations, aquaculture, ocean mining or similar activities.

The aim of the IP Code is to provide minimum safety standards for ships that carry industrial personnel, as well as for the personnel themselves, and address specific risks of maritime operations within the offshore and energy sectors, such as personnel transfer operations.

The implementation of the Code necessitated the development of a new chapter of the SOLAS Convention, Chapter X and both will enter into force on 1 July 2024.

Since this work commenced at IMO over 5 years ago, IMCA’s Marine Policy & Regulatory Affairs (MPRA) Committee has been working alongside the Secretariat fully participating in the process of developing the Code to ensure the offshore industry’s concerns have been addressed, not least, the perceived ambiguity in the application of the requirements of the new mandatory IP Code and the non-mandatory SPS Code the lack of clarity as to how the two codes will co-exist.

On several occasions IMCA submitted proposals to the Sub-Committee on Ship Design and Construction (SDC) raising issues of concern such as the fact that the IP Code will not permit the carriage of dangerous goods, which are used in offshore construction, while the SPS Code does allow their carriage. IMCA submitted two documents (SDC 8/4/3 and SDC 8/4/7) to the 8^th session of the SDC Sub-Committee which met in January proposing various changes to the draft text of the IP Code, including:

1.           a revised definition of industrial personnel

2.           clarification on the application of the IP Code by defining categories of persons

3.           explicitly permitting passenger ships to carry industrial personnel

4.           additional text to address cases of failure of the personnel transfer arrangement

In considering the proposals the Sub-Committee deemed that the draft text sufficiently addressed the issues raised and that no further clarification was needed. However, it was agreed that, if considered necessary, a second phase of work may be initiated involving the development of Explanatory Notes, which should take effect in conjunction with the entry into force of SOLAS chapter XV and the IP Code. In response to this, the MPRA Committee undertook the development of a Guidance document for members on the application of the new IP Code which is now available on our website. This document has also been formally submitted to IMO (link to SDC 9/INF.3) for consideration as a base document for further work by the Sub-Committee in this area.

Should members have any questions on this, please contact Margaret Fitzgerald Head of Legal & Regulatory Affairs at Margaret.fitzgerald@legacy.imca-int.com

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