IMCA working with IMO on the development of a new MASS Instrument

IMCA has been participating in IMO’s work on the development of a regulatory framework for autonomous vessels since this work stream began and, at the recent session of IMO’s Maritime Safety Committee (MSC 106), IMCA participated in the Working Group on the ‘Development of a Goal-Based Instrument for Maritime Autonomous Surface Ships (MASS)’.

IMO has already agreed that the new Code should initially be a non-mandatory instrument which should be developed using IMO’s Goal-Based Standards (GBS) guidelines, whereby

• A goal is established for each chapter/section of the MASS Code which addresses the issue of concern and reflects the required level of safety; and
• Functional requirements are then developed which provide complete coverage of all hazards within the scope of the goal

On that basis, the Code will be developed based on the principles that it be:

1.           Supplementary to any applied base IMO instruments, such as SOLAS, and only address MASS issues insofar as they are not adequately or fully addressed in the applied base instruments.

2.           Holistic to ensure the objectives, aims and principles of the IMO base instruments are maintained whilst also ensuring that the challenges of MASS functions and operations are addressed across all instruments.

3.           Goal-based and addressing matters at the functional level; d. non-mandatory but developed in such a way as to facilitate future transition to mandatory status; and e. technology neutral and taking note of industry practices and experience in the deployment of new technologies.

4.           Non-mandatory but developed in such a way as to facilitate future transition to mandatory status.

5.           Technology neutral, taking note of industry practices and experience in the deployment of new technologies.

In achieving its Purpose, the goals of the Code are to:

1. Ensure achievement of a level of safety at least equivalent to that expected of a conventional ship.
2. Enable all ships to safely coexist without impeding or negatively impacting each other, regardless of whether certain functions are remotely controlled or autonomously operated.
3. Ensure that there is no relaxation of the level of accepted standards for design, construction, or operation; d. allow for the application of solutions that are demonstrably safe, secure, and environmentally sound in performing the designated function in all defined conditions; and e. be cognizant of the potential for the unintended placement of regulatory barriers to new or novel application of remote control or autonomous technology on ships

When it met at MSC 106 the Working Group was tasked with further developing the draft text which has been developed thus far, identifying any issues that may need to be addressed by the Joint IMO Working Group on MASS which covers safety, legal and facilitation of trade issues and updating the Road map for developing a goal-based code for MASS.

Part 3 of the draft text will contain Goals, Functional Requirements and Provisions and work is now underway in various groups to develop appropriate text for several sections. IMCA has volunteered to work on three specific sections of Part 3:

• Section 2 – Remote Operations together with Bahamas, China, France, India, Japan, Republic of Korea, Russia Federation, Singapore, Saudi Arabia, United States, United Arab Emirates, United Kingdom, INTERTANKO and World Maritime University
• Section 7 – Management of safe operations together with Denmark, Germany, Sweden, BIMCO and World Maritime University
• Section 10 – Search and rescue together with Spain and the International Chamber of Shipping

IMCA’s expertise in this area has been recognised and its’ participation welcomed. IMCA’s IMO representative, Margaret Fitzgerald, Head of Legal & Regulatory Affairs will be leading IMCA’s involvement with technical expertise provided by Technical Advisers Richard Purser and Andre Rose as well as members of IMCA’s MASS Committee as required.

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