IMCA helps drive the implementation of the Industrial Personnel (IP) Code

From previous updates in Making Waves, the most recent being December 2022, Members will be aware that IMCA’s Marine Policy & Regulatory Affairs (MPRA) Committee has been fully engaged in the development of the IP Code at IMO through the Sub-Committee on Ship Design and Construction (SDC).  At several sessions of the Sub-Committee IMCA has highlighted areas of disparity between the new mandatory IP Code and the existing non-mandatory SPS Code such as the fact that, the carriage of dangerous goods, which are used in offshore construction, are permitted to be carried under the existing non-mandatory SPS Code but will not be permitted under the new mandatory IP Code.    

IMCA has also maintained pressure on the IMO Member States to address several areas where we feel there is ambiguity in the meaning of the Code including:  

1.            The definition of industrial personnel
2.            The application of the IP Code in respect of categories of persons
3.            Explicitly permitting passenger ships to carry industrial personnel
4.            Addressing cases of failure of the personnel transfer arrangement  

While IMO envisages the development of Explanatory Notes to supplement the implementation of the IP Code and the associated new chapter of SOLAS (Chapter X) both of which enter into force on 1 July 2024, this work has yet to get going so in the interim, IMCA’s MPRA Committee developed a Guidance document for IMCA members which was published in December (Guidance on the Industrial Personnel (IP) Code (IMCA REG 005)). This document was subsequently submitted to the January meeting of the SDC Sub-Committee as SDC 9/INF.3 (INSERT LINK) for consideration by IMO Member States. While no specific comments were made during the meeting, IMCA’s efforts to progress IMO’s intention to develop a companion document for the IP Code were recognised and the SDC Sub-Committee invited interested delegations to ‘liaise with IMCA’ with a view to developing a first draft of the Explanatory Notes for the next Sub-Committee session (SDC 10), taking document SDC 9/INF.3 into account. This is very positive for IMCA as it puts us in the driving seat on this issue.    

IMCA will now take the lead and follow-up on this instruction by convening a roundtable with key offshore Flag States to discuss the issues we see as significant for the offshore sector and agree how best to develop a draft IMO submission based on its Guidance document.

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