The IMO’s sub-Committee on the Implementation of IMO Instruments met between 20 and 24 July 2026.

IMO updates

Casualty Investigation Code

The Correspondence Group reviewing the Casualty Investigation Code submitted a comprehensive draft document that has been developed over the past 12 months. Following review by expert members of The Nautical Institute, we spoke in support of the draft Code.  Specifically, we supported proposals for:

• The renaming of Causal Factor to Contributing Factor, which reflects that there is rarely one causal factor and that accidents are invariably an amalgam of contributing factors.
• The formal definition of Safety Issue as a ‘contributing factor that can adversely affect future operations’, which reflects this being a characteristic of an organisation or system rather than a specific individual. This conceptual shift properly distinguishes systemic and organisational factors from individual acts.
• The new Chapter 24 on Safety issues and actions, which is a particularly positive step in the recording and tracking of actions and recommendations from casualty reports.

The draft of the new Code will be further refined over the next 12 months prior to submission to the next meeting of the sub-Committee.

Enclosed Space Entry in Tankers

The sub-Committee received a proposal to clarify the guidelines on CO2 measurement prior to enclosed space entry in oil, chemical and liquified gas cargo tanks operating under inert gas regimes. It was reported that some Port State Control inspections were requiring such measurements, despite the inerting systems and associated cargo generating no CO2 risk.

The ensuing debate highlighted some key points of interest to members:

• The recommendations for entering enclosed spaces aboard ships (Resolution MSC.581(110)) provide a range of options to make enclosed space entry safer.  Per the resolutions own wording: “It may not be practicable to apply all of these recommendations to all situations”.
• Port State Control can only log a deficiency if they find an issue that is not in compliance with the requirements of a relevant convention. Noting that the recommendations for enclosed space entry (MSC.581(110)) are neither explicitly part of a convention, nor a requirement (they are ‘recommendations’), a crew that follows a risk-based approach when applying the recommendations (instead of applying each and every one of the recommendations, regardless of applicability) cannot create a PSC deficiency.

Port Reception Facilities

It is a requirement of MARPOL that any inadequacies of port reception facilities for ships’ waste are reported to the IMO via flag States.  A total of just 13 reports were received for 2025, from four parties to MARPOL.

Six of the reports related to MARPOL Annex I (oily waste); seven reports related to MARPOL Annex V (garbage). In eight cases, the problems encountered were related to the unavailability of Port Reception Facilities, in three cases, an inconvenient location, and in two cases, unreasonable charges.

Members are encouraged to report all situations of inadequate port reception facilities to their flag States for official submission to the IMO.

Acknowledgements

The Nautical Institute was represented at this IMO meeting by Captains Chris O’Flaherty AFNI, Mohab Abou-Elkawam AFNI and Sitki Ustaoglu FNI.