The completion of the scoping exercise represents an all important first step, paving the way to focused discussions to ensure that regulation will keep pace with technological developments.
The scoping exercise was initiated in 2017 to determine how safe, secure and environmentally sound MASS 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 which applied to MASS and prevented MASS operations; or applied to MASS and do not prevent MASS operations and require no actions; or applied to MASS and do not prevent MASS operations but may need to be amended or clarified, and/or may contain gaps; or have no application to MASS 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, Recognised Organisations (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).
For each provision, the exercise identified whether MASS 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 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 MASS 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.