IMO News Final

MSC 109

One hundred-nineth session of the Maritime Safety Committee

(hereinafter referred to as MSC 109) was convened in London
from 2 to 6 December 2024 to discuss a wide range of issues
under the purview of the Committee. This News Final modifies
and supplements the News Flash issued soon after MSC 109, and
provides conclusive briefing on the outcomes of MSC 109
relating to major technical issues.

Executive Summary
The Committee adopted amendments to various Conventions and mandatory IMO instruments, which enter into
force on 1 July 2026 or 1 January 2028. The major amendments are listed below, and the details of all revisions
can be found in this IMO News Final.

 Amendments to the IGC Code to permit the use of toxic cargoes (e.g. Ammonia) as fuel; and
 Amendments to the IGF Code on various safety issues

In addition, a number of non-mandatory instruments including technical guidelines and unified interpretations
were approved at this session. Key issues may be as follows:

 Unified interpretation of SOLAS regulation II-2/4.5.6.1 and the IBC Code relating to the piping arrangements
for safe gas-freeing
 Unified interpretation of SOLAS regulation II-1/26.2 relating to single essential propulsion using a dual
winding electric motor on passenger ships
 New performance standards for digital navigation data system (NAVDAT)
 Replacement or upgrade of shipborne VHF radio installations to allow communication using digital VHF
channels
 Interim guidelines for the safety of ships using ammonia as fuel

Alongside several other draft amendments, MSC 109 notably approved amendments to SOLAS regulation V/23
concerning pilot transfer arrangements, as well as to the IGC Code addressing a wide range of safety issues.
However, these draft amendments need to go through the formal adoption process at the next session of MSC
to become legally binding.

As part of discussions on safe decarbonization and safe digitalization, MSC 109 continued its discussion on the
development of a non-mandatory Code for autonomous ships and on the safe regulatory frameworks to support
the GHG reduction using alternative fuels and new technologies.

Overall, MSC 109 could achieve fruitful results on various safety issues.

Hope KR News Final may assist you to take a close look at and implement appropriately the outcome of MSC
109.

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Adoption of amendments to Conventions and mandatory IMO instruments

1.1 Use of toxic cargoes as fuel on gas carriers

Amongst the toxic cargoes listed in chapter 19 of the IGC Code, ammonia stands out as an eco-friendly fuel
option due to its lack of CO2 emission, i.e. a major contributor to greenhouse gases. However, under the current
IGC Code, the use of ammonia cargo as a ship’s fuel is legally prohibited because of its toxicity.

As part of the comprehensive review of the IGC Code, the CCC Sub-Committee explored allowing the use of toxic
cargoes, including Ammonia, as fuel for gas carriers from 2022 to 2023. These efforts align with global initiatives

IMO News Final : MSC 109

to reduce greenhouse gas emissions.

Consequently, paragraph 16.9.2 of the IGC Code was

amended at this session by adopting resolution
MSC.566(109). The details of the amendments are as
follows:

 The prohibition on using cargoes as fuel now

applies only to the one (i.e. toxic cargoes) that
require the carriage in type 1G ship, which have the
highest safety containment requirements; and

 Toxic cargoes required to be carried on type

2G/2PG ships, such as Ammonia, may be used as
ship’s fuel with the approval from the
Administration, provided that the same level of
safety as natural gas is maintained.

To support these amendments, the CCC Sub-Committee is currently developing the Guidelines on the use of
ammonia cargo as fuel until 2026, which will be included as a footnote to the revised paragraph 16.9.2 of the IGC
Code.

These amendments will come into force on 1 July 2026 and will apply to gas carriers constructed on or after 1
July 2016 (including existing ships). In addition, to encourage voluntary early implementation before 1 July 2026,
MSC.1/Circ.1681 was also approved during this session in conjunction with the adoption of the IGC Code
amendments.

Source: resolution MSC.566(109) (as found in MSC 109/22/Annex 1) and MSC.1/Circ.1681

Impact Analysis Ship owners, shipyards, and equipment manufacturers

Unlike the use of LNG cargo as fuel, for which chapter 16 of the IGC Code provides detailed requirements, the
use of Ammonia cargo as ship’s fuel requires flag Administration’s authorization as an equivalent based on the
guidelines to be developed by the CCC Sub-Committee.

Flag Administrations may voluntarily early-implement the amendments before 1 July 2026, in accordance with
MSC.1/Circ.1681.

Given that these amendments are retroactively applied, any new construction using Ammonia cargo as ship’s
fuel may be considered in consultation with ship’s flag Administration even before the amendments are
implemented.

1.2 Amendments to the IGF Code on various safety issues

During MSC 109, the amendments to the IGF Code were adopted to address various safety issues. These

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amendments enter into force on 1 January 2028. While they generally apply to new ships constructed on or after
1 January 2028 1, some provisions retroactively apply to all ships.

In this regard, key amendments, which may have substantive implications, are summarized in the ensuing
paragraphs. Nonetheless, it is recommended that concerned parties go through thorough review on all revised
provisions in the original IMO paper to correctly assess any implication to their business and work.

Source: resolution MSC.567(109) (as found in MSC 109/22/Annex 2)

1.2.1 Suction well of LNG fuel tank (paragraphs 5.3.3.5.1 and 5.3.4.2 of the IGF Code)

IMO News Final : MSC 109

While SOLAS regulation II-1/9.3.1 permits a reduced protection distance for small wells constructed within the
double bottom of passenger ships and cargo ships (excluding tankers), the IGF Code does not specify the
allowable extent to which a suction well of an LNG fuel tank may extend into the ship’s double bottom. This lack
of clarity associated with LNG’s inherent safety risk has raised questions about whether such a suction well could
be permitted at the bottom of LNG fuel tank on ships subject to the IGF Code.

To address this, Korean Register submitted to CCC 9 document CCC 9/3/5 (Republic of Korea), which proposed
the amendments to the IGF Code, based on paragraph 2.4.3 of the IGC Code. As a result, paragraphs 5.3.3.5.1
and 5.3.4.2 of the IGF Code were amended to specify that the suction well of an LNG fuel containment system,
if fitted, may protrude below the inner bottom plating no more than 25% of the double bottom’s depth or 350mm,
whichever is less. These amendments retroactively apply to all ships subject to the IGF Code.

Impact Analysis Ship owners and shipyards

This amendment allows the use of suction wells for LNG fuel tank pumps, enabling the safe and efficient
stripping of residual LNG fuel. This contributes to enhancing both the safety and convenience of ship
operations.

Notwithstanding the entry-into-force date of this amendment, i.e. 1 January 2028, but considering its clarifying
nature, KR has already incorporated and implemented the requirements in its Guidance Relating to the Rules
for the Classification of Ships Using Low-flashpoint Fuels (Chapter 5 Section 3 Paragraph 302).

1 The term “ships constructed on or after 1 January 2028” means ships for the building contract is placed on or after 1 Jan
2028 or the delivery of which is on or after 1 Jan 2032. For more details, please refer to paragraph 2.2.44 of the IGF Code.
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1.2.2 Protection from fire and explosion of LNG fuel tanks (paragraphs 11.3.2.1 and 11.3.2.2 of the IGF Code)

Existing paragraph 11.3.2 of the IGF Code requires that any boundary of accommodation spaces, service spaces,
control stations, escape routes and machinery spaces, facing fuel tanks located on open deck, shall be shielded
by A-60 class divisions, which extend up to the underside of the deck of the navigation bridge.

To clarify the protection requirements for LNG fuel tanks located above the open deck, existing paragraph 11.3.2
of the IGF Code was restructured to paragraphs 11.3.2.1 and 11.3.2.2 and amended as follows:

 Notwithstanding the existing requirements, any such boundaries facing the fuel tank on the open deck,
which is separated by a minimum distance determined through a heat analysis to provide protection

IMO News Final : MSC 109

equivalent to an A-60 class division, shall be considered acceptable. Intermediate structures providing
heat protection to the above spaces may also be considered acceptable. (paragraph 11.3.2.1)

 For oil tankers and chemical tankers, A-60 insulation as per SOLAS regulation II-2/9.2.4.2.5 for
protection of Accommodation shall be considered to meet paragraph 11.3.2.1 of the Code, provided the
fuel tanks are in cargo area forward of accommodation spaces, etc. Nonetheless, consideration for the
protection of accommodation block sides may be neccssary. (paragraph 11.3.2.1.1)

 Where no source of gas leak is possible from the fuel containment system such as type C tanks with
tank connection spaces (TCS), A-60 insulation shielding is not required. (paragraph 11.3.2.1.2)

These amendments apply to ships constructed on or after 1 January 2028.

Impact Analysis Ship owners and shipyards

This amendment provides design flexibility by allowing alternative measures or accepting similar SOLAS
provision for fire protection requirements (A-60 insulation) concerning safe spaces, including accommodation
space, facing LNG fuel tanks located on open decks. Therefore, shipyards are invited to note the amendments
and take actions as necessary.

A standardized methodology for the heat analysis under the revised paragraph 11.3.2.1 needs to be established
ASAP.

In implementing the new paragraph 11.3.2.1.1 (which is for oil and chemical tankers), the accommodation side
block, outside the protection scope in accordance with SOLAS II-2/9.2.4.2.5 (i.e., 3 meters from the boundary
facing the cargo area), may be waived from A-60 fire insulation, if the distance from the fuel tank is
demonstrated by the heat analysis to provide equivalent fire protection to A-60 insulation, or if the area is
shielded by an intermediate structure.

The exemption from A-60 insulation (or alternative protection) under the new paragraph 11.3.2.1.2 is limited to
cases where tank connections of Type C tanks located on open decks are installed inside a Tank Connection
Space (TCS). In this regard, please be guided by the following interpretations of KR:

 Although such designs are unlikely, Type A or B tanks positioned on open decks cannot be exempted from
A-60 insulation, considering the risk of LNG fuel leakage due to tank damage.

 The term “source of gas release from the fuel containment system" is limited to direct leakage sources
from the fuel containment system and adjacent tank connections, and does not require consideration of
leaks from fuel or vent pipes beyond the tank connection.

1.2.3 Arrangement for relieving over-pressure in LNG fuel pipelines (paragraphs 7.3.1.4 and 9.4.2 of the IGF
Code)

Paragraph 7.3.1.3 of part A-1 of the IGF Code currently specifies that all pipelines or components which may be
isolated in a liquid full condition shall be provided with pressure-relief valves. However, it lacks detailed

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requirements on how the discharge line from the pressure-relief valve should be arranged. This contrasts with
paragraph 5.2.2.4 of the IGC Code, which includes relevant provisions for this arrangement.

Given the discrepancy, there was an urgent need to establish corresponding requirements in the IGF Code.
Consequently, MSC 109 adopted the amendments to paragraphs 7.3.1.4 and 9.4.2 of the IGF Code, which will
apply to ships constructed on or after 1 January 2028, as follows:

 Pressure relief valves discharging liquid or gas from the piping system shall discharge into the fuel tanks
whenever the tank MARVS pressure is lower than the setting of the pressure relief valves. Alternatively,
they may discharge to the vent mast, if any liquid in the vent can be detected and disposed. (paragraph
7.3.1.4)

IMO News Final : MSC 109

 Fuel tank inlets from pressure relief valve discharge line as per new paragraph 7.3.1.4 shall be provided
with non-return valves in lieu of valves automatically closing at the time of emergency shut down. In
addition, a safe means for tank isolation during maintenance will be also available without affecting
proper operation of safety relief valves. (paragraph 9.4.2)

Impact Analysis Ship owners and shipyards

This amendment applies to ships constructed on or after 1 January 2028, and the shipbuilding industry should
take appropriate measures to ensure its proper integration into ship designs

The revised paragraph 9.4.2 of the IGF Code Part A-1 mandates that a safe means of isolating the fuel tank
during maintenance be provided in accordance with IGF Code Part C-1, paragraph 18.3 (i.e. regulations for
maintenance), without affecting the operation of the pressure relief valve. Therefore, shipowners should ensure
that relevant maintenance procedures are also established when implementing this amendment.

1.2.4 Clarification on the minimum distance between independent type C tank’s surface and fuel storage hold
space’s A-60 boundary (paragraph 11.3.3.1 of the IGF Code)

Existing paragraph 11.3.3 of the IGF Code requires that the space containing the fuel containment system be
separated from machinery spaces of category A or other rooms with high fire risks, by a cofferdam of at least
900 mm with A-60 class insulation. In this regard, the fuel storage hold space for type C tanks may be considered
a cofferdam, provided the minimum distance between the outer shell of the type C fuel tank and the A-60
boundary of the fuel storage hold space is not less than 900 mm. However, it was unclear if the minimum
distance of 900 mm should be calculated from the outer surface of the tank shell or its insulation system.

According to paragraph 11.3.3.1, as amended this session, the minimum distance shall be calculated from the
outer surface of a type C tank’s insulation system to provide sufficient protection thereto. For vacuum insulated
type C tanks, the outer surface of the insulation system refers to the outer surface of the outer shell. These

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amendments apply to ships constructed on or after 1 January 2028.

IMO News Final : MSC 109

Impact Analysis Ship owners and shipyards

This amendment clarifies the previous requirements and has been partly implemented through classification
rules*. While its impact on ship design is considered limited, shipyards are invited to pay attention and take
actions as necessary.
* KR Rules for the Classification of Ships Using Low-flashpoint Fuels 2024, Chapter 11, Paragraph 301.3

1.2.5 Classification of hazardous areas (paragraphs 12.5.2.3, 12.5.2.4, and 12.5.3.3 of the IGF Code)

To be consistent with the IGC Code and IEC 60092-502:1999, the classifications of hazardous areas have been
amended, as follows, for application to ships constructed on or after 1 January 2028:

 Existing paragraph 12.5.2.3 of the IGF Code identifies the area on open deck or semi-enclosed spaces
on deck within 3 m of the ventilation outlet from fuel preparation rooms (i.e. zone 1) as one of hazardous
area zone 1. Given that the level of hazard from other zone 1 is not different than that of fuel preparation
rooms, the amendment now classifies the areas within 3m of all ventilation outlets from zone 1 spaces,
as hazardous area zone 1. (paragraph 12.5.2.3)

 To mitigate hazards in the event of a large gas leakage, an additional zone 1 area shall be designated
around the fuel tank vent mast outlet. This area is defined as a cylindrical shape extending 6 m in radius
from the center of the vent mast outlet (with no height restriction upwards) and a hemispherical shape
with a 6-meter radius underneath it. However, if the vessel’s size and layout make this application
impossible, a reduced Zone 1 area may be accepted based on a dispersion analysis using 50% Lower
Explosive Limit (LEL) criteria. In any case, this reduced Zone 1 area must not be smaller than the 3 m
radius specified in paragraph 12.5.2.3 and shall include the hazardous area zone 2 meeting the
dimensions given in paragraph 12.5.3.1 of the IGF Code (i.e. the areas within 1.5 m surrounding open or
semi-enclosed spaces of zone 1). (paragraph 12.5.2.4)

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 In lieu of paragraph 12.5.3.1 of the IGF Code, Zone 2 area shall be established in the areas surrounding
4 meters beyond the cylindrical and hemispherical Zone 1 area (6-meter radius) defined in the newly
introduced paragraph 12.5.2.4. (paragraph 12.5.3.3)

IMO News Final : MSC 109

Impact Analysis Ship owners and shipyards

Most of these amendments have been already incorporated into and implemented under class rules based on
IEC 60092-502:1999, so its impact on ship design is considered limited. However, shipyards should carefully
review the following specific issues and consider design modifications related to hazardous areas if necessary.

 (Revised paragraph 12.5.2.3): The area within 3 meters of the ventilation outlets from Zone 1 areas, such
as TCS, enclosed spaces with fuel piping, etc., has already been classified as Zone 1. These amendments
merely clarifies the point.

 (New paragraph 12.5.2.4): The ‘50% LEL’ boundary condition for the reduced Zone 1 is a new requirement.
Compared to the previous relaxation based on gas dispersion analysis, it may lead to an increase in the
size of the 'reduced Zone 1'.

 (New paragraph 12.5.3.3): Contrary to the KR Guidance Relating to the Rules for the Classification of Ships
Using Low-flashpoint Fuels 2024, Chapter 12, 503.2.(2) and (3), there is no basis in the IGF Code for
reducing the radius of Zone 2 from 4 meters to 1.5 meters around the periphery of Zone 1, which is defined
as a 6-meter radius (upper cylindrical shape with no height restriction and lower hemispherical shape).
However, if the 'reduced Zone 1' is applied, the extent of Zone 2 can be defined as up to 1.5 meters from
the boundary of Zone 1.

1.2.6 Arrangement of ventilation ducts penetrating other spaces (paragraphs 13.3.5, 13.3.8.1, and 13.3.8.2 of
the IGF Code)

Existing paragraph 13.3.5 of the IGF Code requires that an intake duct serving either hazardous or non-hazardous
space and passing through a more hazardous area shall be gastight with maintaining relative overpressure.
However, there is currently no safety requirement for air intakes serving hazardous areas when they pass through
non-hazardous spaces or comparatively less hazardous spaces.

Therefore, the amendments adopted at this session address this lack of safety requirements by deleting relevant
parts in the existing paragraph 13.3.5 and by amending sub-paragraph 13.3.8.1 and establishing new sub-
paragraph 13.3.8.2, as follows:

 Where a ventilation duct serving a non-hazardous space passes through a hazardous area, the duct must
be gastight and maintain a relative over-pressure compared to the hazardous area. This amendment is
not limited to intake ducts, unlike the deleted requirement in paragraph 13.3.5. (sub-paragraph 13.3.8.1)

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 Where a ventilation duct serving a hazardous space passes through a less hazardous or non-hazardous
space, the duct must be gastight and maintain relative under-pressure. However, for the ventilation piping
fully welded and designed in accordance with chapter 7 of the IGF Code, the under-pressure requirement
may be waived. (sub-paragraph 13.3.8.2)

IMO News Final : MSC 109

Impact Analysis Ship owners and shipyards

Shipyards should carefully consider measures, including design modifications, to apply this amendment to new
constructions.

Non-mandatory IMO instruments adopted or approved by MSC 109

After discussion under relevant agenda items, MSC 109 adopted or approved non-mandatory IMO instruments,
as shown in the ensuing paragraphs.

2.1 MSC 109, after its consideration under agenda item 19, approved IMO instruments as follows:

2.1.1 Committee’s method of work: its workload and unified interpretations

It is recalled that MSC 108 decided that the approval of unified interpretations should be based on consensus,
rather than unanimity, provided that the following conditions are met.

 UIs should not amend mandatory requirements in Conventions and associated instruments;
 UIs should not go beyond the interpretation of mandatory requirements; and
 UIs should not contradict the mandatory requirements.

MSC 108 also agreed that the assessment of capacity-building implications of new or amended mandatory
instruments should take place preliminarily by the submitters of new output proposal and finally by the Sub-
Committee which develops new or amended mandatory requirements.

In addition, MSC 109 discussed and finalized a number of countermeasures to address the workload of the
Committee and its subsidiary Sub-Committee.

Consequently, the above decisions were incorporated in the Committee’s method of work, which was approved
during this session. Once the draft document is co-approved by MEPC, it will be issued as MSC-
MEPC.1/Circ.5/Rev.6.

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Source: MSC 109/22/Annex 26

2.2 After discussing the report of SSE 10, MSC 109 adopted or approved IMO Instruments as follows:

2.2.1 Unified interpretation of SOLAS regulations III/20.8.4 and 20.11 and resolution MSC.402(96)

While the maintenance, thorough examination,

operating testing, overhaul and repair of rescue boats
has been specified under SOLAS regulation III/20.11 to
enforce resolution MSC.402(96) 2 , the repair and

IMO News Final : MSC 109

maintenance of inflated rescue boats has been also
stated under regulation III/20.8.4. Further, before the
implementation of resolution MSC.402(96), the annual
servicing of inflated rescue boats was subject to
resolution A.761(18) 3, based on IACS UR Z17 4. As such,
it was not sufficiently clear whether the annual servicing
of inflated rescue boats should be conducted in
accordance with SOLAS regulation III/20.11 and
resolution MSC.402(96).

To address the ambiguity, MSC 109 approved a unified interpretation through MSC.1/Circ.1682 to clarify that
SOLAS regulation III/20.11 and resolution MSC.402(96) should also be applicable to inflated rescue boats.

Source: MSC.1/Circ.1682

2.2.2 Unified interpretation on the piping arrangement for safe gas-freeing

A series of fire incidents on board oil/chemical tankers revealed a potential safety issue arising from cargoes
and/or cargo vapors present in the forecastle spaces, which are non-hazardous enclosed spaces. It was
commonly observed throughout the accidents that cargo vapors entered the store located in ship’s fore castle
via cargo piping connected to gas-freeing facilities. Sometimes, the connection of piping arrangements was
installed without flag Administration’s authorization but with the possibility of human errors.

Based on the general practice 5 of IACS member societies, unified interpretations of SOLAS regulation II-2/4.5.6.1
and paragraphs 3.1.2, 3.1.4 and 3.5.3 of the IBC Code were approved as MSC.1/Circ.1683 to establish new
requirements on air-supply fans and piping connected to cargo piping or tank for gas-freeing.

Air supply piping/ducts, if fitted, may only be connected to cargo piping or vent lines subject to the following
conditions:

 The connection should be done by a detachable connection (e.g. spool pieces, detachable ducts/hoses,
etc.) located in ship’s cargo area. When not in use for gas-freeing, the detachable connection should be
dismantled, and the pipe ends should be closed with blank flanges

 One non-return valve and one shut-off valve should be fitted between the detachable connection and
cargo tanks. Alternatively, a single non-return valve with a positive means of closure may be accepted.

 One shut-off valve should be fitted at the side of fans or blowers. This valve should open being
interlocked with the fan or blower’s discharging pressure after their start, and automatically close in the

2 Resolution MSC.402(96): Requirements for maintenance, thorough examination, operational testing, overhaul and repair
of lifeboats, rescue boats, launching appliances and release gear
3 Resolution A.761(18): Recommendation on conditions for the approval of servicing stations for inflatable liferafts
4 IACS UR Z17: Procedural Requirements for Service Suppliers
5 Please refer to KR Rule Part 7, Guidance Chapter 1 Section 1 Paragraph 1002.3(2)(A)
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event of their stop or loss of gas-freeing air pressure. The electric parts of this shut-off valve, if fitted in
a hazardous area, should be of a certified safe type complying with IEC 60092-502:1999 6.

Air supply fans or blowers should be of the non-sparking type, and their electrical motors should be of an
explosion-proof type when fitted in the duct or located in the cargo area. Finally, suitable procedures should be
provided to assist ship’s crew in safely operating the relevant installations.

IMO News Final : MSC 109

The interpretations apply to the arrangements installed in the non-hazardous area of oil tankers and chemical
tankers on or after 1 January 2026. In this regard, it may be noteworthy that the interpretations are not applicable
to inert gas systems installed in ship’s engine room, and that tankers with inert gas systems are not expected to
install a separate air supplying fan or blower in ship’s non-hazardous area.

Source: MSC.1/Circ.1683

Impact Analysis Ship owners and shipyards

For oil tankers and chemical tankers with a deadweight tonnage (DWT) of less than 8,000 tons, or for chemical
tankers depending on their cargoes, the installation of an inert gas system may not be necessary. Even if an
inert gas system is not installed, gas freeing of cargo tanks remains essential for vessel operations, making it
likely that separate air supply fans or blowers will be installed in non-hazardous areas.

In this regard, KR Class Rules’ Guidance Part 7, Chapter 1, Paragraph 1002.3.(2) already provides safety
requirements for cargo tank ventilation but only for oil tankers. However, MSC.1/Circ.1683 approved at this
session applies not only to oil tankers but also to chemical tankers and introduces requirements compared to
existing classification rules (e.g. detachable connections, operational procedures, etc.).

Where such arrangements are installed on or after 1 January 2026, shipyards should ensure that the unified
interpretations in MSC.1/Circ.1683 are adhered to. Additionally, shipowners should keep an appropriate
operational procedure document reflecting MSC.1/Circ.1683 requirements onboard.

2.2.3 Unified interpretation of SOLAS regulations II-2/4.5.3.2.2 and 11.6.3.2 on the secondary means for
pressure/vacuum relief

SOLAS regulation II-2/11.6.3.2 requires a secondary means to prevent over-pressure or under-pressure of cargo
tanks in the event of failure of the venting arrangements to pass large volume of vapor, air or inert gas mixtures

6 IEC 60092-502:1999 Electrical Installations in Ships Tankers

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during cargo operations. However, as an alternative to the secondary means, pressure sensors fitted in each tank
may be accepted together with a monitoring system in ship’s cargo control rooms.

In this regard, since 2011, IACS UI SC 140 (Rev.3), in its paragraph 5 and footnote, has specified that, for the
pressure sensors as an alternative secondary means of venting, the settings of over-pressure and under-pressure
alarms should be outside the pressure setting of the P/V valve but within the design pressures of the cargo tanks;
and that they should be fixed with an exception permitted for ships using different pressure settings of P/V valves
to transport different cargoes.

Given the amendments adopted by resolution MSC.392(95), the same interpretations submitted by IACS based
on paragraph 5 of IACS UI SC 140 (Rev.3) were approved at this session as MSC.1/Circ.1684.

IMO News Final : MSC 109

Source: MSC.1/Circ.1684

2.2.4 Unified interpretation on the crown of a machinery space of category A

SOLAS regulation II-2/11.4.1 requires that crowns and casings of machinery spaces of category A shall be of
steel construction with fire insulation as required by SOLAS regulation II-2/9. However, as the term "crown" is not
currently defined under SOLAS regulation II-2/3, it may lead to a possible misunderstanding when applying the
relevant requirements.

In this regard, unified interpretations were approved at this session through MSC.1/Circ.1684 to clarify that;

 The crown of a machinery space of category A means the underside of the deck and the uppermost
horizontal part of the main space of the machinery space; and

 If the upper side bulkheads are sloping, the sloping parts of the bulkheads should be included in the
crown.

The corresponding interpretation was adopted as IACS UI SC 302 for the application on ships contracted for
construction on or after 1 July 2025. The crown may be as illustrated below:

Source: MSC.1/Circ.1684

2.2.5 Revised unified interpretations of SOLAS regulations II-2 rectifying an oversight regarding references to
SOLAS regulation II-2/9.7.5.1

It is recalled that, in 2023, MSC 107 expanded the application scope of the unified interpretations in
MSC.1/Circ.1276 from galley exhaust ducts to any ducts subject to SOLAS regulations II-2/9.7.2 and 9.7.5 by

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approving MSC.1/Circ.1276/Rev.1. The interpretation clarifies how the trunks and ducts should be fire-insulated
when passing through an enclosed space.

However, while sub-paragraph 2 under SOLAS regulation II-2/9.7.5 provides the requirements of exhaust ducts
from galley ranges passing through accommodation spaces or spaces containing combustible materials, it does
not specify any requirements relating to the fire insulation of the ducts.

Therefore, the reference of entire regulation II-2/9.7.5 in the interpretations was corrected to regulation II-
2/9.7.5.1. The minor correction was approved at this session as MSC.1/Circ.1276/Rev.2.

Source: MSC.1/Circ.1276/Rev.2

IMO News Final : MSC 109

2.2.6 Unified interpretation of SOLAS regulation II-1/26.2 relating to single essential propulsion using a dual
winding electric motor on passenger ships

In accordance with SOLAS regulation II-1/26.2, special consideration shall be given to the reliability of single
essential propulsion components and a separate source of propulsion power may be required to ensure ship’s
navigable speed, especially in the case of unconventional arrangements.

With the increasing number of electric propulsion motors used as ship’s main propulsion, concerns were raised
that a single electric propulsion motor arranged with dual windings within its stator (or rotor) may not provide
sufficient redundancy, as damage to one of the windings may lead to the total loss of the propulsion motor.

After lengthy and repeated discussions within SSE Sub-Committee and MSC, unified interpretations were finally
approved through MSC.1/Circ.1685 to address winding insulation failures and excitation failures of electric
propulsion motors. The interpretations are as follows:

 A single electric propulsion motor (including both single and dual winding with a single rotor) should not
be deemed to provide sufficient reliability required for ship’s main propulsion. For such arrangements, a
separate propulsion unit is required to ensure ship’s navigable speed.

 Propulsion arrangements with two independent rotors on a single shaft may be accepted, provided it is
possible to de-excite or de-flux each rotor individually and to supply the stators independently.

The illustrations below exemplify allowable and not allowable arrangements:

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Due to strong opposition from an IMO member State, however, the application of the above interpretations is
limited to the propulsion systems installed on passenger ships on or after 1 January 2026. In this regard, it should
be noted that IACS adopted IACS UI SC 305 in December 2024, which corresponds to MSC.1/Circ.1685, but
expanded its application to all types of ships contracted for construction on or after 1 January 2026.,

Source: MSC.1/Circ.1685

2.2.7 Minor corrections relating to the assumed weight used to represent each person in self-righting tests for
totally enclosed lifeboats

IMO News Final : MSC 109

According to paragraph 4.4.2.2.1 of the LSA Code, as amended by
resolution MSC.272(85), the average weight of a person used to
calculate the capacity of lifeboats are respectively defined as 75kg for
a passenger ship and 82.5kg for a cargo ship. Although these human
weight criteria have been largely incorporated into the relevant
requirements of resolution MSC.81(70) and MSC.1/Circ.1630/Rev.2,
they were inadvertently omitted from the self-righting test
requirements for totally enclosed lifeboats in these documents.

To address the omittance, the following documents have been approved during this session:

 Resolution MSC.568(109), to amend paragraph 6.14.1.1 in part 1 of resolution MSC.81(70) 7; and

 Revised standardized life-saving appliance evaluation and test report forms (survival craft)
(MSC.1/Circ.1630/Rev.3), to update table 4.4.2.3 for application on survival craft installed on or after 15
August 2025

Source: Resolution MSC.568(109) (as found in MSC 109/22/Annex 9) and MSC.1/Circ.1630/Rev.3

2.2.8 Minor corrections relating to retro-reflective materials used on life-saving appliances

It is recalled that MSC 102 approved resolution MSC.481(102) 8

to replace resolution A.658(16), which provides the
requirements for retro-reflective materials used on life-saving
appliances. However, at that time, references to resolution
A.658(16) in revised standardized life-saving appliance
evaluation and test report forms were overlooked and not
updated to resolution MSC.481(102).

To address this oversight and detail pertinent provisions, the

following documents have been approved during this session
from application on life-saving appliance installed on or after 15
August 2025:

 Revised standardized life-saving appliance evaluation and test report forms (personal life-saving
appliances) (MSC.1/Circ.1628/Rev.3);

 Revised standardized life-saving appliance evaluation and test report forms (survival craft)
(MSC.1/Circ.1630/Rev.3);

7 Resolution MSC.81(70): Revised recommendation on testing of life-saving appliances

8 Resolution MSC.481(102): Revised recommendation on the use and fitting of retro-reflective materials on life-saving
appliances
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 Revised standardized life-saving appliance evaluation and test report forms (rescue boats)
(MSC.1/Circ.1631/Rev.1); and

 Revised standardized life-saving appliance evaluation and test report forms (launching and embarkation
appliances) (MSC.1/Circ.1632/Rev.1)

Source: MSC.1/Circ.1628/Rev.3, MSC.1/Circ.1630/Rev.3, MSC.1/Circ.1631/Rev.1, and MSC.1/Circ.1632/Rev.1

2.2.9 Revised standards for the design, testing and locating of

devices to prevent the passage of flames into cargo tanks in
tankers

IMO News Final : MSC 109

MSC/Circ.677 is footnoted under SOLAS regulation II-2/4.5.3.3
as the guidelines on the design, testing and locating of safety
devices that prevent the passage of flames into cargo tanks on
tankers. This circular was partially revised by MSC.1/Circ.1009
and MSC.1/Circ.1324.

In this context, the ISO and IEC standards referenced in

MSC/Circ.677, as amended, have been updated as follows:

Old standards referenced in

Updated standards
MSC/Circ.677, as amended
Explosion IEC Publication 79 IEC 60097, Electric Apparatus for
prevention IEC Publication 79-1 Explosive Gas Atmosphere

ISO 15364:2021, Ships and marine

ISO 15364:2000, Ships and marine
technology – Pressure-vacuum valves for
P/V valves technology - Pressure/vacuum valves for
cargo tanks and devices to prevent the
cargo tanks
passage of flame into cargo tanks

Incorporating the amendments included in MSC.1/Circ.1009 and MSC.1/Circ.1324, and updating the references
to the ISO and IEC standards, MSC.1/Circ.677 was further amended and re-issued at this session as
MSC.1/Circ.677/Rev.1. This new circular applies to the safety devices installed on or after 4 December 2026.

Source: MSC.1/Circ.677/Rev.1

2.3 After discussing the report of NCSR 11, MSC 109 adopted or approved IMO Instruments as follows:

2.3.1 Amendments to the IAMSAR Manual

IAMSAR Manual is a guidebook for international aviation and maritime search and rescue operations, which
provide standardized procedures to ship and search and rescue operators. The revision of volumes 1 to 3 of the
IAMSAR Manual was prepared by NCSR 11 and approved at this session through MSC.1/Circ.1686. These
amendments should become applicable on 1 January 2026.

Source: MSC.1/Circ.1686

2.3.2 New performance standards for digital navigation data system (NAVDAT)

The Digital Navigational Data System (NAVDAT) is an advanced communication system operating on the MF
(500 kHz) and HF (4,226 kHz) bands, designed to receive maritime safety information (MSI) and search and
rescue (SAR) data. Compared to NAVTEX, it supports both text and image data at significantly improved speeds.

In this regard, new performance standards for digital navigation data system (NAVDAT) were adopted at this
session as resolution MSC.569(109). In addition to NAVTEX, EGC and HF NBDP, NAVDAT receiver will be
accepted as one of the devices capable of receiving MSI and SAR-related information as required in accordance

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with SOLAS regulation IV/7.1.4. The installation of NAVDAT receivers is not necessarily mandatory, and NCSR
Sub-Committee will continue to discuss the effective implementation of NAVDAT at its next session.

In conjunction with the aforementioned, resolution MSC.509(105)/Rev.1, titled “Provision of radio services for
the GMDSS”, was adopted at this session to establish criteria for shore-based facilities offering NAVDAT services.
This resolution ensures that Administrations provide NAVDAT services from shore-based facilities in compliance
with SOLAS regulation IV/5, thereby supporting the effective implementation of GMDSS.

Source: Resolutions MSC.569(109) and MSC.509(105)/Rev.1(as respectively found in MSC 109/22/Annex 13)

IMO News Final : MSC 109

2.3.3 Performance standards for a universal shipborne Automatic Identification System (AIS)

It is recalled that the IMO assembly urged to promote actions to

prevent illegal operation in the maritime sector through dark fleets.
In this regard, it was recognized that there was an urgent need to
establish measures to prevent unauthorized entry or tampering of
ship’s identity information in shipborne AIS.

To enhance the security aspects of AIS, performance standards for

shipborne AIS in annex 3 to resolution MSC.74(69) was amended by
adopting resolution MSC.570(109). The amendments identify ship’s
IMO number as one of the information that should be mandatorily
included in shipborne AIS. If an IMO number is not required for a
ship 9, an official flag State number may be used.

The revised performance standards for shipborne AIS apply to the equipment installed on or after 1 January 2029

Source: resolution MSC.570(109) (as found in MSC 109/22/Annex 23)

2.3.4 Replacement or upgrade of shipborne VHF radio installations to allow communication using digital VHF
channels

The updates to appendix 18 of the ITU Radio Regulations

(edition 2020) reassigns certain VHF frequency bands to digital
VHF channels. This change presents compliance challenges
for the shipping industry, as ships should ensure their VHF radio
installations align with the latest channel arrangements. While
some ships may be able to upgrade their existing VHF radio
installations through software or firmware updates, others may
require complete replacement of their equipment to align with
the new channel arrangements.

In this regard, MSC 109 issued MSC.1/Circ.1460/Rev.5,

mandating and clarifying that all shipboard VHF radio
installations should comply with the latest channel arrangements in appendix 18 of the ITU Radio Regulations,
by the first radio survey on or after 1 January 2028.

Additionally, ships should have the capability to communicate via VHF radiotelephony with shore facilities in their
operational areas, acknowledging that some administrations may adopt the new channels before 1 January 2028.

Source: MSC.1/Circ.1460/Rev.5

9 IMO numbers shall be mandatorily assigned to all passenger ships of 100 gross tonnage and upwards and to all cargo ships
of 300 gross tonnage and upwards.
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Impact Analysis Ship owners, equipment manufacturers, and service suppliers

Shipowners are strongly encouraged to ensure their fleet complies with MSC.1/Circ.1460/Rev.5 by upgrading
software or replacing shipboard VHF installations within the specified timeframe. However, unless flag
administrations mandate compliance with MSC.1/Circ.1460/Rev.5, replacing shipboard VHF installations is
not considered mandatory. Please refer to KR Technical Information 2025-IMO-05.

2.4 After discussing the report of III 10, MSC 109 adopted or approved IMO Instruments as follows:

IMO News Final : MSC 109

2.4.1 Interim guidance to assist in the implementation of the Cape Town Agreement 2012 relating to the safety
of fishing vessels

The Cape Town Agreement 2012 10 is yet to be ratified, while its entry into force and implementation will make a
significant contribution to the safety of fishing vessels. In the meantime, interim guidance to assist in the
implementation of the Cape Town Agreement 2012 was adopted during this session by resolution MSC.571(109).

Source: resolution MSC.571(109) (as found in MSC 109/22/Annex 25)

2.5 After discussing the report of CCC 10, MSC 109 adopted or approved IMO Instruments as follows:

2.5.1 Interim guidelines for the safety of ships using ammonia as fuel

MSC 109 approved MSC.1/Circ.1687, which provides the interim

guidelines for the safety of ships using ammonia as fuel, excluding those
covered under the IGC Code. These interim guidelines offer safety
provisions for the arrangement, installation, control, and monitoring of
machinery, equipment, and systems utilizing ammonia as fuel, aiming to
minimize risks to the ship, its crew, and the environment, given
ammonia’s toxic nature.

Due to the non-mandatory status of these guidelines, their application to

a ship requires authorization from the flag Administration as an
equivalency to the IGF Code.

Source: MSC.1/Circ.1687

Approval of draft amendments to mandatory IMO instruments for subsequent adoption by

MSC 110

After discussing the reports of SSE 10, NCSR 11 and CCC 10, MSC 109 approved draft amendments to mandatory
IMO instruments for subsequent adoptions at MSC 110 in 2025, as listed below. However, these draft
amendments are not legally binding until the adoption of MSC in the future.

3.1 Lifejacket carriage requirements for high-speed craft (Expected implementation date: 1 January 2028)

To harmonize with the lifejacket carriage requirements in the 1994 and 2000 HSC Codes with those in SOLAS
chapter III, paragraph 8.3.5 of each HSC Code will be amended to require additional lifejackets for infants and
suitable accessories for oversize persons, as listed below:

 for passenger craft on voyages less than 24h, a number of infant lifejackets equal to at least 2.5% of the
number of passengers on board;

10 The Cape Town Agreement of 2012 on the Implementation of the Provisions of the Torremolinos Protocol of 1993 relating
to the Torremolinos International Convention for the Safety of Fishing Vessels, 1977
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 for passenger craft on voyages 24h or greater, infant

lifejackets for each infant on board; and

 on all craft, a sufficient number of suitable accessories for

securing oversized persons, if the adult lifejackets
provided are not designed to fit persons weighing up to
140kg and with a chest girth of up to 1,750mm,

As a result, the form of safety certificates for high-speed craft in

annex 1 of each HSC Code will be also amended to record the

IMO News Final : MSC 109

number of lifejackets suitable for infants.

If adopted at MSC 110, the draft amendments will apply to existing high-speed craft no later than the date of the
first renewal survey on or after 1 January 2028, and to new craft constructed(K/L) on or after 1 January 2028.

Source: MSC 109/22/Annexes 7 and 8

3.2 Minor corrections to SOLAS regulations II-2/11.2 and 11.4.1 relating to the applicable tables of fire integrity
and insulation (Expected implementation date: 1 January 2028)

The references to the tables under SOLAS regulation II-2/9 were inaccurate within SOLAS regulations II-2/11.2
and II-2/11.4.1 concerning fire integrity standards for bulkheads and decks. Currently, SOLAS regulation II-2/11.2
references only the tables applicable to passenger ships, while SOLAS regulation II-2/11.4.1 refers solely to those
for cargo ships. Those references should have been made to all tables regardless of ship types.

To address this error, both regulations will be amended to encompass all relevant tables under SOLAS regulation
II-2/9, ensuring comprehensive guidance for both passenger and cargo vessels. This correction aims to enhance
clarity and consistency in the application of fire safety standards.

Source: MSC 109/22/Annex 10

3.3 Pilot transfer arrangements (Expected implementation date: 1

January 2028)

To enhance the safety and standardization of pilot transfer arrangements,

SOLAS Regulation V/23 has been comprehensively revised and approved
during this session. These revisions aim to enhance safety practices and
ensure better compliance with pilot transfer arrangements throughout the
shipping industry. To support these changes, new technical provisions
have also been prepared and consolidated as mandatory performance
standards.

Based on the draft amendments to SOLAS regulation V/23, the forms of

safety certificates in SOLAS, 1994 HSC Code, 2000 HSC Code and 2008
SPS Code will be revised to include the entries of pilot transfer
arrangements.

It was also decided to consequentially amend the Code of Safety for

Fisherman and Fishing Vessels, 2005, to simply refer to the draft
amendments to SOLAS regulation V/23 with regard to pilot transfer
arrangements.

Once adopted by MSC 110, the amendments will apply to pilot transfer
arrangements installed on or after 1 January 2028. For the arrangements
installed prior to this date, the revisions will retroactively apply as follows:

 For SOLAS ships, by the first survey on or after 1 January 2029; and
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 For non-SOLAS ships, by 1 January 2030

Source: MSC 109/22/Annexes 15 to 19

3.4 Draft amendments to the IGC Code addressing a broad range of safety issues (Expected implementation
date: 1 January 2028)

Through the comprehensive review of the IGC Code conducted since 2022, the CCC Sub-Committee developed
the draft amendments to the IGC Code covering numerous safety issues and MSC 109 approved them. Once
adopted by MSC 110, they will be issued as a consolidated version of the IGC Code.

IMO News Final : MSC 109

Key updates include:

 Incorporation of existing unified interpretations: The draft amendments incorporate various unified
interpretations approved as MSC circulars since the adoption of the 2014 amendments to the IGC Code
(i.e. resolution MSC.370(93)).

 Cargo tank filling limits: Isolated vapor pockets within cargo tanks are no longer prohibited to allow the
filling limit of cargo tanks greater than 98%. In addition, the filling limit greater than 98% is only applicable
to type C tanks or tanks with MARVS exceeding 0.7 bar, provided that the arrangement has been verified
and accepted by the Administration or its recognized organization (RO) based on appropriate risk
mitigation measures to address higher design pressure.

 LPG and ethane cargoes as fuel: LPG and ethane are now included as cargoes that may be used as
ship’s fuel subject to compliance with relevant safety provisions newly established based on
MSC.1/Circ.1679 11.

 Carriage of CO2 cargo: The classification of CO2 products, previously divided into two categories, i.e.
Carbon Dioxide (high purity) and Carbon Dioxide (Reclaimed quality), has now been combined into a
single product, i.e. Carbon Dioxide. Furthermore, it has been determined that Carbon Dioxide will only be
re-categorized as a toxic product under the IGC Code, thereby, significantly waiving the requirements
applicable to flammable products.

These amendments, in principle, apply to ships constructed on or after 1 July 2016, unless otherwise determined
in the respective modified provisions. However, except for certain specific provisions, amendments impacting
ship’s design or construction will apply to ships constructed(K/L) on or after 1 January 2028.

Source: MSC 109/22/Annex 24

11 MSC.1/Circ.1679: Interim guidelines for use of LPG cargo as fuel

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3.5 Draft amendments to SOLAS chapter II-1 relating to the application of the IGF Code towards gaseous fuels
(Expected implementation date: 1 January 2027)

Please refer to section 5.3 of this News Final.

Source: MSC 109/22/Annex 4

Autonomous ships: development of a goal-based MASS Code

4.1 MSC 109 established Working Group on MASS and continued to develop the draft non-mandatory MASS

IMO News Final : MSC 109

Code. The Working Group finalized chapters 7 (Risk Assessment), 12 (Connectivity) and 18 (Remote operation)
of the draft Code, and discussed chapter 23 (Search and rescue).

It was decided that chapter 28 (Emergency Response) need not be retained but some of its components not
overlapping with other chapters may be reorganized and incorporated into chapter 11 (Management of safe
operation). Further, interested parties were invited to submit proposals for consideration at MSC 110 on the
framework for development of ConOps.

Based on the discussion made to date, the draft MASS Code is structured with three parts, as summarized below.
However, more discussion is needed to finalize the draft Code.

 Part 1 (introduction) addresses purpose, application, code structure, and terms and definitions.

 Part 2 (main principles for MASS and MASS functions) specifies certificate and survey, approval process,
risk assessment, operational context, system design, software principles, management of safe operations,
radiocommunication, alert management, human element, and maintenance and repair.

 Part 3 provides goals, functional requirements and expected performance of all 13 chapters consisted of
safety of navigation, connectivity, remote operations, etc.

Source: MSC 109/WP.8/Annex 1

4.2 To expedite the completion of the work on the non-mandatory MASS Code, it was decided that the fourth
session of Inter-Sessional MASS working group will be convened between MSC 110 and MSC 111.

4.3 The Committee also updated the road map for developing a goal-based MASS Code, as found in MSC
109/22/Annex 3. The milestones of the road map were again postponed as shown below.

 finalization and adoption of the non-mandatory MASS Code at MSC 111 in 2026;
 an experience-building phase from 2026;
 commencement of developing the mandatory MASS Code from 2028; and
 the adoption of the mandatory MASS Code at a future session before 1 July 2030 for entry into force on 1
Jan 2032

Alternative fuels and new technologies for GHG reduction

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5.1 Updating the list of alternative fuels and new technologies

During MSC 108, a wide range of alternative fuels and new technologies was identified, including but not limited
to nuclear energy, solar and wind power, energy storage systems, energy-saving technologies, and onboard
carbon capture and storage systems. MSC 109 continued the discussion on alternative fuel and new
technologies for GHG reduction building upon the work of the correspondence group established by MSC 108.

Following the deliberations through a dedicated working group, MSC 109 updated the list of alternative fuels and
new technologies. Amongst others, “swappable traction lithium-ion battery containers" was newly included as
potential power sources for ships. Further work will be undertaken by a correspondence group to identify
regulatory gaps, barriers, and relevant IMO bodies with a view towards addressing the reduction of GHG

IMO News Final : MSC 109

emissions from ships

5.2 Application of the IGF Code to gas carriers subject to the IGC Code

Based on the decision made at MSC 95, the IGF Code has not been applied to gas carriers subject to the IGC
Code. However, the increasing use of LNG and alternative fuels has prompted the question about whether SOLAS
regulation II-1/56.4 prevents the simultaneous application of the IGC and IGF Codes on gas carriers. In this regard,
CCC 10 (September 2024) explored whether the IGF Code or other IMO instruments aligned with it may apply to
the fuel containment and supply system - independent of cargo systems - on gas carriers subject to the IGC Code.
This issue was subsequently referred to MSC 109 for further consideration.

In this regard, MSC 109 engaged in extensive discussions but failed to reach a policy decision regarding the one-
ship and one-code principle for gas carriers due to divided views and insufficient time. Consequently, the
discussion will be carried forward to the next session.

5.3 Application of the IGF Code on ships using gaseous fuels with a flash point of 60°C and above

SOLAS part G, which mandates the IGF Code, provides requirements for ships using low-flashpoint fuels having
a flash point below 60°C. This has created ambiguity on whether or not the IGF Code applies to ships using
gaseous fuels with a flash point exceeding 60°C.

Following the discussions at MSC 108 and CCC 10, MSC 109 agreed to define the term “gaseous fuel” and include
it to the application scope of the IGF Code by amending SOLAS regulations II-1/56 and 57. These amendments
were approved during this session, with a view towards the adoption at MSC 110 and the entry-into-force from 1
January 2027 outside the four-year amendment cycle. Further works will be continued at MSC 110 to refine the
definition of low-flashpoint fuel in SOLAS regulation II-1/2.29.

Source: MSC 109/22/Annex 4

New work programs

MSC 109 deliberated on the new output proposals submitted to this session and approved them as listed below.
The new output categorized as “Biennial” will be initiated with urgency by the Committee or responsible Sub-
Committees within the period of the year 2026-2027, and the one categorized as “Post-biennial” will get started
at an appropriate point after the period of the year 2026-2027.

New outputs approved by MSC 109 Responsible bodies

Development of a transition scheme for the introduction of digital technology for Biennial
NCSR
Very High Frequency (VHF) voice communications (2026-2027)

Development of guidance to establish a framework for data distribution and global

Biennial
IP-based connectivity between shore-based facilities and ships for ECDIS S-100 NCSR
(2024-2025)
products

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Any other issues

7.1 IACS Recommendation No.34 (Rev.2) provides an

updated wave data set of North Atlantic Ocean, which will
be used as a basis of amending IACS Common Structural
Rules (CSR) for oil tankers and bulk carriers. In this regard,
the outcome of GBS verification audit on IACS
Recommendation No.34 (Rev.2) was considered during
this session.

IMO News Final : MSC 109

After extensive discussions, it was decided that IACS
Recommendation No. 34 (Rev.2) would be revised to
provide sufficient technical evidence and that the revised
version, along with the IACS Common Structural Rules (CSR) developed based on it, would be verified through
GBS audits. It was also emphasized that close collaboration between IACS and industry stakeholders is crucial
during this process. Furthermore, it was recommended that the application of structural rules developed based
on IACS Recommendation No. 34 (Rev.2) be refrained from until the revision is completed.

7.2 In accordance with SOLAS regulations V/7, V/10, and V/15, and COMSAR.1/Circ.32/Rev.2, GMDSS radio
installations are required as summarized below to operate in sea area A3 through duplication of equipment.

Primary GMDSS radio installations Duplicated GMDSS radio installations

VHF, MF and RMSS SES VHF and RMSS SES

VHF, MF and RMSS SES VHF and MF/HF

Through document MSC 109/21/2, concern was raised on the different understandings amongst stakeholders
on whether a duplicated MF/HF radio installation, highlighted in bold in the table above, may simultaneously
serve as a primary MF radio installation for sea area A3 based on COMSAR.1/Circ.32/Rev.2.

In this regard, MSC 109 reaffirmed that a duplicated MF/HF radio installation may simultaneously function as
the primary MF radio installation for sea area A3. Furthermore, the IMO Secretariat was instructed to update the
existing footnote No.6 in the table under paragraph 2.3 of COMSAR.1/Circ.32/Rev.2 to reflect this reaffirmed
understanding. The update will be issued as COMSAR.1/Circ.32/Rev.3.

Source: COMSAR.1/Circ.32/Rev.3

Impact Analysis Ship owners and shipyards

Based on COMSAR.1/Circ.32/Rev.3, a single MF/HF radio installation may be accepted simultaneously as a

primary MF and a duplicated MF/HF. Therefore, unless flag Administrations otherwise instruct and where a
ship opts for duplication of equipment and shore-based maintenance for compliance with SOLAS regulation
IV/15.7, the ship with two(2) VHF, one(1) MF/HF and one(1) RMSS SES may be permitted for navigation in sea
area A1+A2+A3. Such a case will be recorded in Safety Radio Certificate as having a primary MF (NOT a primary
MF/HF) and a duplicated MF/HF.

7.3 ISO reported through document MSC 109/21 that ISO 18813:2006 12 referenced to paragraphs 4.1.5.1.18 and
4.1.5.1.19 of the LSA Code, i.e. food ration and fresh water, was withdrawn and had been replaced with ISO
18813:2022. After reviewing the updated ISO standards and considering the discrepancies between the updated
ISO standard and the LSA Code, MSC 109 decided to refer it to the SSE Sub-Committee for further review and
invited ISO to offer relevant information.

12 ISO 18813: Survival equipment for survival craft and rescue boats
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Should you have any questions, please contact P.I.C. Thank you.

General Manager Disclaimer

Convention & Legislation Service Team
Korean Register While every possible effort has been made to ensure
accuracy and completeness of the contents contained in
this technical information, the Korean Register assumes no
P.I.C Kim Kyoungyong / Principal Surveyor responsibility for any errors or omissions contained herein,
nor shall it be held liable for any actions taken by any party
as a result of information retrieved from this technical
Tel: +82 70 8799 8328
information.
E-mail: convention@krs.co.kr / kykim@krs.co.kr

IMO News Final : MSC 109

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