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New IP Code deadline approaches 

Published on 10 June 2024

The International Code of Safety for Ships Carrying Industrial Personnel (IP Code) has been developed by the International Maritime Organization (IMO) as a mandatory code which enters into force on 1 July 2024. 

The Code is intended to create the conditions for safe carriage of Industrial Personnel on ships and their safety during personnel transfer operations between the ship and offshore installations. 

Industrial Personnel are defined as, ʺpersons who are transported or accommodated on board for the purpose of offshore industrial activities performed on board other ships and/or offshore facilities.ʺ  The IP Code is made mandatory through a new Chapter XV in the SOLAS Convention. 

More details on the new rules, and the implications of the changes, can be found in a series of Information Notes and a Guidance document prepared by IMCA. Simply register or login with your work email to access our Member-only resources. 

IMCA Contact

Margaret Fitzgerald
Head of Legal & Regulatory Affairs
Contact

Commenting on the approaching deadline, Margaret Fitzgerald, Head of Legal & Regulatory Affairs, IMCA said: “The new Mandatory IP Code will enter into force in only a few weeks’ time and Member companies will need to understand its potential impact on their projects and ways of working. We’d urge all Members to make themselves aware of changes in the first instance, then review their own approaches to working at sea to ensure they are compliant with the new Code.” 

IMCA engages the UK Government over concerns relating to the application of the IP Code

Following the introduction of the IP Code, IMCA has written to the Department for Transport (DfT) and the Maritime & Coastguard Agency (MCA) highlighting industry concerns over the application of the new IP Code.

In the letter, which was co-signed with the UK Chamber of Shipping and the British Rig Owners’ Association,we collectively outlined a number of issues relating to the Code’s application in the UK, seeking clarification on several points, notably:

  • What the treatment of non-SPS compliant vessels will be, and the level of compliance required to address any gaps identified.
  • That the MCA will accept IP Code certification issued by other Flag Administrations.
  • That non-MCA flagged vessels operating in the UK sector will not be prevented from carrying Industrial Personnel.
  • That the process to allow all UK-flagged vessels will be ‘grandfathered’ into the IP Code, given the deadline for such grandfathering is 1July 2024.
  • What the process for full compliance will be after that date.
  • What goals the MCA wishes to achieve through the IP Code implementation. Signatories to the letter are unaware of any non-compliance with the SPS Code leading to major incidents which would lead shipowners to being required to make considerable modifications to comply fully with the IP and SPS Codes.
  • That all applications for grandfathering made by the 30 June 2024 will be considered, even if the MCA is unable to process them until after the IP Code enters into force on 1 July 2024.


Commenting on the letter on 28 June 2024, Margaret Fitzgerald added: “While the IP Code enters into force in three days’ time, there remain several areas of uncertainty with regard to its implementation in UK territorial waters. Working collaboratively with the broader maritime sector in the UK, we’ve written to seek clarification over how it will work in practice, on behalf of our Members.”

“I’d like to thank the MPRA Committee, as well as the Bahamas Maritime Authority and Bahamas Shipowners Association for supporting us on the drafting of the letter. We hope to be able to share an update with IMCA Members soon on the impact of this activity.”