Amendments to International Merchant Shipping Requirements Implemented Into UK Domestic Law

Three sets of amendments to international merchant shipping requirements have been implemented into UK law. These amendments cover damage stability in cargo ships, load line protocol and prevention of pollution by noxious liquid substances carried in bulk. 

Damage stability

The first of the three sets of amendments relates to damage stability in cargo ships. The amendment arose when the International Maritime Organisation (IMO) identified inconsistencies in the provisions for watertight doors in the mandatory requirements for cargo ship construction. 

In response to this finding, Annex I of the International Convention for the Prevention of Pollution from Ships, 1973 (MARPOL) has been amended to better align the requirements for watertight doors on tankers with the requirements of SOLAS (which remains unchanged as a result of this amendment). 

IMO Resolution MEPC.343(78) makes this amendment. 

The amendment will enter into force in the UK on 1st January 2024 by way of the ambulatory reference provision in the Merchant Shipping (Prevention of Oil Pollution) Regulations 2019. 

This first ‘set’ of amendments includes Resolutions MEPC.345(78) and MSC.526(106) which amend the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code) to better align the requirements for watertight doors on chemical tankers with the requirements of SOLAS. 

These particular amendments will be implemented when new regulations (the draft Merchant Shipping (Carriage of Dangerous Goods and Harmful Substances) Regulations 2024) are made - but will not take effect until the international coming into force date of 1st July 2024. 

Other amendments relating to damage stability in cargo ships include Resolution MSC.492(104) relating to gas carriers. 

Load Line Protocol

The second major set of amendments concern load line protocol - guidance covering reserve buoyancy and loading. 

Resolution MSC.491(104) makes the amendment and makes a minor editorial correction to regulation 22(1)(g) of Chapter III of Annex I of the 1988 Load Line Protocol to remove erroneous reference to ‘inlets’ in a table setting out acceptable arrangements for scuppers and discharges. 

This amendment will enter into force on 1st January 2024 by way of the ambulatory reference provision in the Merchant Shipping (International Load Line Convention) (Amendment) Regulations 2018. 

Noxious liquid substances carried in bulk

The third ‘set’ of amendments relates to the prevention of pollution by noxious liquid substances carried in bulk by sea. 

Resolution MEPC.344(78) amends appendix I of Annex II to update guidance used in the categorisation of liquid chemicals. This amendment subdivides the rating for inhalation toxicity to make it more relevant for shipboard operations, deletes an outdated rating for seafood tainting and reassigns the column to rate flammability flashpoint. 

The amendment entered force in the UK on 1st November 2023 by way of the ambulatory reference provision in the Merchant Shipping (Prevention of Pollution from Noxious Liquid Substances in Bulk) Regulations 2018. 

Regulatory legal advice

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Not only does our team have a detailed understanding of the specific regulations impacting the shipping industry, but they take a pragmatic and commercially-sensible approach to ensure the regulatory compliance and commercial aspects of any issues are met. 

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