The 109th session of the IMO’s Maritime Safety Committee (MSC 109) was held from 2 to 6 December 2024. Amendments to the IGC Code to enable the use of ammonia cargo as fuel were adopted, and interim guidelines for the general use of ammonia as fuel were approved. The IGF Code was amended to improve the safety of ships using natural gas as fuel. MSC 109 further approved draft SOLAS amendments to enhance the safety of pilot transfer arrangements and progress was made on the new safety code for Maritime Autonomous Surface Ships
Meeting highlights
- Adopted amendments to the IGC Code to enable the use of ammonia cargo as fuel
•Adopted amendments to the IGF Code for ships using natural gas as fuel
•Approved draft interim guidelines for ammonia as fuel
•Approved draft amendments to SOLAS Regulation V/23 and the related performance standards to improve the safety of pilot transfer arrangements
•Advanced the non-mandatory Code on Maritime Autono- mous Surface Ships (MASS)
Amendments to mandatory instruments
Ammonia cargo as fuel (IGC Code)
MSC 109 adopted amendments to Paragraph 16.9.2 of the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) to enable the use of ammonia as fuel on ammonia carriers.
An MSC circular to encourage the voluntary early implemen- tation of the amendments to Chapter 16 was approved.
The amendments will enter into force on 1 July 2026.
Safety of ships using natural gas as fuel (IGF Code)
MSC 109 adopted amendments to the International Code of Safety for Ships Using Gases or Other Low-flashpoint Fuels (IGF Code), based on experience with the code since its entry into force in 2017.
The amendments include:
- Clarified application provisions
•Alignment with the IGC Code on suction wells for fuel tanks extending below the lowermost boundary of the tank
•Alignment with the IGC Code on discharge from pressure relief valves to discharge to tanks under certain conditions
•Clarified requirements to fire insulation for deck structures in relation to fuel tanks on open deck
•Clarified requirements for hazardous ducts through non- hazardous spaces and vice versa
•Updated requirements for the hazardous zone radius for fuel tank vent mast outlets, increasing to 6 metres for zone 1 and 4 metres for zone 2
The amendments will enter into force on 1 January 2028.
Goal-based new ship construction standards
Goal-based standards (GBS) for the new construction of bulk carriers and oil tankers are, conceptually, the IMO’s rules for class rules. Under the GBS, IMO auditors use guidelines to verify the construction rules for bulk carriers and oil tankers of class societies acting as Recognized Organizations (Resolu- tion MSC.454(100)).
Initial GBS verification of Biro Klasifikasi Indonesia (BKI)
BKI has requested GBS verification of their ship construction rules for bulk carries and oil tankers. MSC 109 agreed that the BKI rules comply with the GBS, provided non-conformities and observations are rectified and verified in a new audit.
North Atlantic wave data (IACS Recommendation No. 34, Revision 2)
MSC 109 noted that IACS is currently undertaking a review of its Common Structural Rules (CSR) for bulk carriers and oil tankers to reflect advances in data, materials, technologies and calculation methodologies. The CSR are implemented in the individual class rules of the IACS members, which are subject to compliance with the GBS.
MSC 109 further noted that IACS has now issued a revision of the North Atlantic wave data to ensure more scientific data as a basis for the rule formulas in the CSR. The new scatter diagram in Revision 2 of IACS Recommendation No. 34 shows the probability of occurrence of different sea states and is based on wave data from advanced hindcast wave models combined with ships’ AIS data for all SOLAS vessels in the period from 2013 to 2020.
MSC 109 agreed that an observation from the initial CSR audit in 2015, that the scatter diagram in Revision 1 of IACS Recommendation No. 34 was based on past statistics, was now considered addressed.
MSC 109 further invited IACS to provide more information about the assumptions, modelling and technical background for Revision 2 of IACS Recommendation No. 34, and agreed that the GBS audit of the revision to follow should be carried out in conjunction with the consequential rule changes in the CSR.
Maritime autonomous surface ships (MASS)
The prospect of autonomous ships operating internationally with little or no human intervention has revealed the need for a regulatory framework for such ships, including their interac- tion and co-existence with conventional manned ships.
The current regulatory framework generally assumes man- ning and human intervention. The IMO has agreed to develop a non-mandatory, goal-based code for cargo MASS, poten- tially entering into force as a mandatory code upon expe- rience with its application. The purpose of the code is to provide a framework to address both the remote control and the autonomous operation of key functions.
The non-mandatory MASS Code is planned to be finalized by 2026, followed by an experience-building phase after its adoption. A mandatory code is expected to enter into force on 1 January 2032, at the earliest.
MSC 109 finalized the chapters of the MASS Code on risk assessment, remote operations and connectivity. The chap- ters on remote operation and connectivity will apply depend- ing on the mode of operation and the functionality being applied, which, for example, would open for a manned MASS with a periodically unmanned bridge, without the support of a remote operation centre.
The search and rescue obligations of a MASS to assist per- sons in distress were considered, but not concluded.
The non-mandatory MASS Code will be progressed in a Cor- respondence Group until MSC 110 (June 2025
New technologies and alternative fuels Identification of gaps in current IMO instruments
MSC 109 continued its consideration of potential alternative fuels and new technologies to support the reduction of GHG emissions from ships from a safety perspective. The intention is to identify safety obstacles, barriers and gaps in the current IMO instruments that may impede the use of the various alter- native fuels and new technologies.
MSC 109 agreed to add “swappable traction lithium-ion battery containers” to the list of alternative fuels and new technologies. The list already includes fuels and technolo- gies such as ammonia, hydrogen, fuel cell power installations, nuclear power, solar power, wind power, lithium-ion batteries and supercapacitor energy storage technology.
Recommendations to address each of the identified barriers and gaps in the IMO regulatory framework will be considered in a Correspondence Group until MSC 110 (June 2025).
Application of the IGF Code
MSC 109 agreed on draft amendments to SOLAS to clarify that the IGF Code applies to ships using gaseous fuels, whether they are low-flashpoint or not. The term “gaseous fuels” was added to the definitions in SOLAS Regulation II-1/2 and to the application provisions of SOLAS Regulations II-1/56 and 57.
The draft amendments are expected to enter into force on 1 January 2027, subject to adoption by MSC 110 (June 2025).
Maritime cyber risk management
MSC 109 recognized the importance of cybersecurity stand- ards for ships and port facilities, and invited for proposals on the next steps to enhance maritime cyber security.
Formal safety assessment
MSC 109 agreed to draft modifications to the Revised FSA Guidelines (MSC-MEPC.2/Circ.12/Rev.2). The draft modifi- cations include an updated threshold for the cost–benefit assessment and improved guidance for the ranking of cost- efficient risk control options. In addition, the guidelines have been editorially reviewed to increase clarity and take into account experience gained.
Ship systems and equipment
Life jacket requirements in the High Speed Craft Codes MSC 109 approved draft amendments to Paragraph 8.3.5 of Annex 1 of the 1994 and 2000 High Speed Craft (HSC) Codes to harmonize the life jacket carriage requirements in the codes with the corresponding requirements in SOLAS Chapter III with respect to the number of infant life jackets and accessories to adult life jackets to accommodate large persons.
The draft amendments are expected to enter into force on 1 January 2028, subject to adoption by MSC 110 (June 2025).
Maintenance of inflated rescue boats
MSC 109 approved a Unified Interpretation of SOLAS Regu- lations III/20.8.4 and 20.11, and of Resolution MSC.402(96), to clarify that the requirements for the maintenance, thor- ough examination, operational testing, overhaul and repair of rescue boats apply to all rescue boats, whether inflated or rigid.
Arrangement of gas-freeing piping/ducts on tankers
MSC 109 approved a Unified Interpretation of SOLAS Regula- tion II-2/4.5.6.1 and Paragraphs 3.1.2, 3.1.4 and 3.5.3 of the IBC Code to facilitate the consistent implementation of the requirements to prevent the release of inflammable vapours into non-hazardous closed spaces.
Crowns and casings of machinery spaces of category A
MSC 109 approved a Unified Interpretation of SOLAS Regula- tion II-2/11.4.1 to clarify the term “crown” in machinery spaces of category A. The UI clarifies that the “crown” means the under- side of the deck and the uppermost horizontal part of the main space of the machinery space, with exemplary sketches.
Secondary means of venting cargo tanks of tankers
MSC 109 approved a draft Unified Interpretation of SOLAS Regulations II-2/4.5.3.2.2 and 11.6.3.2 to clarify the pressure alarm settings for ships that apply pressure sensors in each tank as an alternative to having a secondary means of venting.
Reliability of essential propulsion components
MSC 109 approved a draft Unified Interpretation of SOLAS Regulation II-1/26.2 to clarify its application to dual winding electric propulsion motors for passenger ships. The draft Unified Interpretation addresses the risk of a non-repairable single failure in an electric propulsion motor.
Average mass of a person during lifeboat testing
MSC 109 approved a revision of Part 1 of Resolution MSC.81(70) on the testing of life-saving appliances and the test report forms in MSC.1/Circ.1630/Rev.2 to reflect that the average mass of a person should be 75 kilograms for life- boats intended for passenger ships and 82.5 kilograms for lifeboats intended for cargo ships.
Retro-reflective materials on life-saving appliances
MSC 109 approved, as a minor corrections draft, consequen- tial amendments to the Revised Standardized Life-Saving Appliance and Test Report Forms MSC.1/Circ.1628/Rev.2 (personal LSA), MSC.1/Circ.1630/Rev.2 (survival craft) and MSC.1/Circ.1632 (launching and embarkation appliances) to replace the reference to Resolution A658(16) with a reference to Resolution MSC.481(102) to reflect the most recent recom- mendation on the use and fitting of retro-reflective materials on life-saving appliances.
In addition, some minor details were added to MSC.1/ Circ.1630/Rev.2 (survival crafts) and MSC.1/Circ.1631 (rescue boats).
Pressure-vacuum valves on cargo tanks in tankers
MSC 109 approved draft amendments to the “Revised Standards for the Design, Testing and Locating of Devices to Prevent the Passage of Flame into Cargo Tanks in Tankers” (MSC.1/Circ.677/Rev.1) to reference the 2021 edition of the ISO standard 15364, introducing a maximum leakage rate from pressure-vacuum valves.
The circular will apply to devices installed on or after 6 December 2026.
Minor correction to MSC.1/Circ.1276/Rev.1
MSC 109 approved draft amendments to MSC.1/Circ.1276/Rev.1 on Unified Interpretations to SOLAS Chapter II-2 to replace the reference to SOLAS Regulation II-2/9.7.5 with a reference to SOLAS Regulation II-2/9.7.5.1 to clarify that the Unified Interpre- tation related to exhaust ducts from galley ranges was intended for passenger ships carrying more than 36 passengers.
Correction of references to structural fire protection tables MSC 109 approved a correction of two references in SOLAS Regulation II-2/11 to refer to the correct fire integrity tables in SOLAS Regulation II-2/9.
The amendments are expected to take effect on 1 January 2028.
Navigation, communications, search and rescue – check repo
Digital navigational data system (NAVDAT)
MSC 109 adopted performance standards for the NAVDAT system and amendments to Resolution MSC.509(105) on “Provision of radio services for the Global Maritime Distress and Safety System (GMDSS)”.
NAVDAT is intended for broadcasting digital data, includ- ing maritime safety information (MSI) and search and rescue (SAR)-related information on medium frequency (MF) and high frequency (HF) bands from shore to ships.
Mobile satellite communication services in the GMDSS MSC 109 approved a revision of the “Criteria for the provi- sion of mobile satellite communication systems in the Global Maritime Distress and Safety System (GMDSS)” (Resolution A.1001(25)) based on experience gained when open for multiple recognized mobile satellite providers in the GMDSS.
The new resolution will cover both new and already approved GMDSS Mobile Satellite Service providers.
The resolution is expected to be adopted by the Assembly in December 2025 and enter into force immediately thereafter.
Safety of pilot transfer arrangements
MSC 109 approved a draft revision of SOLAS Regulation V/23 and associated performance standards for pilot transfer arrangements. The intention is to ensure safe arrangements for pilots and other personnel embarking and disembarking ships in all conditions of draught and trim.
The draft amendments are expected to enter into force on 1 January 2028, subject to adoption by MSC 110 (June 2025). The requirements will be applied retroactively.
A draft MSC circular open for voluntarily early implementa- tion of the amendments was approved.
Improvement of security and integrity aspects of AIS
MSC 109 approved a revision of the performance stand- ards for the shipborne Automatic Identification System (AIS) (Resolution MSC.74(69)) to prevent the unauthorized entry or tampering of a ship’s identity information in the AIS.
Validity of radiocommunications equipment
MSC 109 approved a revision of MSC.1/Circ.1460/Rev.4 to clarify that:
- The mandatory VHF/DSC equipment required by SOLAS Regulation IV/7 on radio equipment (including the required duplicated equipment for maintenance purposes) should comply with the latest channel arrangements in Appendix 18 of the Radio Regulations by the first radio survey sched- uled on or after 1 January 2028, or earlier.
•Ships should always be able to communicate with shore facilities in their area of operation, noting that some admin- istrations may already have implemented the new channels.
Carriage of cargoes and containers
Ammonia as fuel
MSC 109 approved draft interim guidelines for the safety of ships using ammonia as fuel.
Ships carrying liquefied gases in bulk (IGC Code)
MSC approved draft amendments to the IGC Code to incor- porate the large number of Unified Interpretations developed since the latest major review of the code, which entered into force in 2016. The primary objective of the draft amendments is to remove ambiguity and promote the consistent imple- mentation of the IGC Code
requirements.
Implementation of IMO instruments
Lessons learned and analysis of marine safety investigation reports
MSC 109 approved a MSC circular to recommend that national administrations expand requirements for carriage of AIS and VHF for the domestic fishing fleet to prevent collisions.
Guidance on implementation of Cape Town Agreement MSC 109 approved interim guidance to support implementa- tion of the Cape Town Agreement.
The Cape Town Agreement (CTA) sets minimum require- ments on the design, construction, equipment, surveys and certification of fishing vessels of 24 metres in length and over, or equivalent in gross tonnes. The agreement has now been
ratified by 22 states, with a combined fleet of about 2,600 fishing vessels. The number of states is sufficient, but a com- bined fleet of 3,600 fishing vessels is needed.
Work programme
MSC 109 agreed on the following new work items:
Sub-Committee on Navigation, Communications, Search and Rescue
Very high frequency (VHF) voice communications
MSC 109 agreed to the development of a transition scheme for the the introduction of digital technology for VHF voice communications.
S-100 Electronic Chart Display and Information System (ECDIS) MSC 109 agreed to the development of guidance to establish a framework for data distribution and global IP-based con- nectivity between shore-based facilities and ships for ECDIS S-100 products.
Any other business
Maintenance of radiocommunication equipment
MSC 109 recalled that the modernization of the GMDSS requirements in SOLAS Chapter IV was not intended to bring substantive changes to the radio installations on existing ships.
MSC 109 confirmed that for operating in sea area A3, a single MF/HF radio installation is accepted as a means to comply with the requirements of a primary MF radio installation and a duplicated MF/HF radio installation simultaneously. Footnote 6 of COMSAR.1/Circ.43/Rev.2 was amended to reflect this confirmation.
Recommendations
DNV recommends customers note that MSC 108 was the last session to adopt amendments to the 2026 update of SOLAS and related mandatory codes. The MSC is now working on updates of SOLAS and related mandatory codes, which will enter into force on 1 January 2028 and beyond. Amendments to the 2028 update must be adopted before 1 July 2026.
DNV further recommends that customers monitor the out- come of MSC 110 in June 2025.
Source: DNV
