New Year 2021 – New Regulations

New regulations that may affect your operations include:

IBC Code and MARPOL Annex II

IMO Resolutions MEPC.318(74) and MSC.460(101) introduce significant changes to the existing IBC Code. Resolution MEPC.318(74) also introduces amendments to MARPOL Annex II with the addition of the term ’persistent floater’ to categorise certain cargoes. These cargoes  have a dedicated prewash requirement if discharged in Northern European ports.

For further details see –  2021 Regulations – Big Changes for Vessels Carrying Chemicals

IMSBC Code 2020 amendments  *reminder*

Amendments 05-19 to the IMSBC Code, which have been in place on a voluntary basis since 1 January 2020, become mandatory on 1 January 2021. The amendments include the re-classification of Group B cargoes, changes and additions to the bauxite and seed cake schedules and also new cargo schedules.

For further details see – 2020 IMSBC Code Amendments

Our article Sowing the Seed of Confusion provides guidance specifically on the changes to the seed cake schedules.

Cyber Security

The International Maritime Organization (IMO) states that cyber security should be included in safety management systems (SMS) from January 2021. Compliance with Resolution MSC.428 (98) Maritime Cyber Risk Management Systems is an important part of being prepared for cyber risks. Accidents, financial loss, business disruption and damage to a company’s reputation can all happen as a result of digital or electronic systems failing or being attacked.

The Resolution states that a vessel’s safety management system should take into account cyber risk management in accordance with the ISM Code and it encourages Flag States to ensure that cyber risks are appropriately addressed no later than the first annual verification of the company’s Document of Compliance after 1 January 2021.

Ship Recycling

From 31 December 2020, all vessels of 500 GT or over calling at an EU port or anchorage will require to have on board an Inventory of Hazardous Materials (IHM) which is approved by their Flag State. This is a requirement under Regulation (EU) No. 1257/2013 on Ship Recycling Regulation (EU SRR), and will apply to all vessels regardless of flag.

The inventory is a list of hazardous materials that form part of the ship’s structure and equipment, operationally generated hazardous wastes and stores on board.

Non-EU flagged vessels can also be certified against EU SRR by complying with the requirements of the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships, which has yet to be ratified.