IMCA seeks clarification from the UK MCA on its implementation of the Marine Guidance Note 674

IMCA has written to the UK’s MCA seeking a meeting to discuss Marine Guidance Notice (MGN) 674, which has been issued in recent months, on the Application of the Special Purpose Ships Code which removes the previously applicable grandfather clause permitting existing UK and foreign flagged vessels already operating on the UKCS to continue operating.

It is our understanding that MGN 674 now requires all non-SPS Code vessels to carry out a gap analysis/assessment which has to be submitted to the MCA for evaluation.

This change, which has been implemented with immediate effect and seemingly without industry consultation, has very serious implications for our members and the potential worst-case scenario is that they cannot show either full or partial compliance without considerable upgrades to the vessels, mainly to satisfy extra stability/sub-division requirements. This has the potential to impact offshore vessels working in UK waters and the roll out of offshore renewable energy projects.

As IMCA members have not been advised of any safety reason behind the MCA’s decision, IMCA has posed the following questions to the MCA in order to understand the rationale for this change:

1. Why, in MGN  674, has the MCA has revoked the grandfather clause which existed in the previous MGN, 515?
2. What consultation has taken place with the affected Industry and what lead in time has been applied?
3. What issues need to be addressed in the gap analysis which IMCA Members are required to carry out and has the MCA has issued any guidance on this?
4. Is the MCA working with key Flag States for the Offshore Marine Contracting Industry to ensure smooth application of the IP Code?
5. What is the expected outcome where a vessel cannot demonstrate full compliance with MGN 674? i.e. will vessels be required to fully comply or no longer be granted permission to work in the UK sector?

The MCA has acknowledged receipt of our letter and has promised to revert with a proposed date for a virtual meeting. We will update members as soon as we have further information.

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