The International Maritime Organisation’s (IMO) Maritime Safety Committee (MSC) has completed a regulatory scoping exercise to analyse relevant ship safety treaties, in order to assess how autonomous surface ships could be regulated.
The MSC said the scoping exercise was initiated in 2017 to determine how safe, secure, and environmentally sound autonomous vessel operations might be addressed in IMO instruments.
The exercise involved assessing a substantial number of IMO treaty instruments under the remit of the MSC and identifying provisions that applied to autonomous ships and prevented operations of such vessels; or applied to autonomous ships and do not prevent their operations and require no actions; or applied to the vessels and do not prevent their operations but may need to be amended or clarified, and/or may contain gaps; or have no application to these vessels’ operations.
Varying degrees of autonomy were considered: crewed ship with automated processes and decision support (Degree One); remotely controlled ship with seafarers on board (Degree Two); remotely controlled ship without seafarers on board (Degree Three); and fully autonomous ship (Degree Four).
The safety treaties assessed include the SOLAS Convention and various codes made mandatory under SOLAS (Casualty Investigation, Enhanced Survey Programme (ESP), Fire Safety Systems (FSS), Fire Test Procedures (FTP), Bulk Chemical (IBC), Gas Carrier (IGC), Solid Bulk Cargoes (IMSBC), Dangerous Goods (IMDG), Carriage of Irradiated Nuclear Fuel (INF), Intact Stability, International Safety Management (ISM), Ship and Port Facility Security (ISPS), Grain, Polar, Recognized Organizations (RO)); collision regulations (COLREG); Load Lines Convention and 1988 Protocol; Convention on Safe Containers (CSC); STCW Convention and Code, as well as STCW-F Convention; search and rescue (1979 SAR Convention); tonnage measurement (Tonnage 1969) and the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) and IMO Instruments Implementation Code (III Code).
The outcome of the regulatory scoping exercise was discussed and completed by the Maritime Autonomous Surface Ships (MASS) Working Group, which met during the MSC’s 103rd session held in May 2021.
For each provision, the exercise identified whether autonomous ships could potentially be regulated by: equivalences as provided for by the instruments or developing interpretations; and/or amending existing instruments; and/or developing a new instrument; or none of the above as a result of the analysis.
The MSC said the outcome highlights a number of high-priority issues, cutting across several instruments, that would need to be addressed at a policy level to determine future work. These involve the development of autonomous ship terminology and definitions, including an internationally agreed definition of MASS and clarifying the meaning of the term “master”, “crew” or “responsible person”, particularly in Degrees Three (remotely controlled ship) and Four (fully autonomous ship).
Other key issues include addressing the functional and operational requirements of the remote-control station/centre and the possible designation of a remote operator as seafarer.
Further common potential gaps and themes identified across several safety treaties related to provisions containing manual operations and alarms on the bridge; provisions related to actions by personnel (such as firefighting, cargoes stowage and securing and maintenance); watchkeeping; implications for search and rescue; and information required to be on board for safe operation.
The committee noted that the best way forward to address MASS in the IMO regulatory framework could, preferably, be in a holistic manner through the development of a goal-based MASS instrument. Such an instrument could take the form of a “MASS Code”, with goal(s), functional requirements and corresponding regulations, suitable for all four degrees of autonomy, and addressing the various gaps and themes identified by the RSE.
The committee invited member states to submit proposals on how to achieve the best way forward to a future session of the MSC.
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