This post is a part of the Maritime Commons blog-post series on the process forward for adopting a Polar Code for ships operating in Arctic and Antarctic waters. Thursday, the Coast Guard hosted a workshop on the Polar Code in Seattle. For those of you who could not attend, Maritime Commons is providing key an after-action blog post for each of the Coast Guard spokespersons that presented at the workshop. You are encouraged to submit your comments to the Federal Docket before it closes on September 1, 2014.

One of the five Coast Guard spokespersons at the workshop Lt. Andrew Gibbons from the Coast Guard’s Office of Design and Engineering Standards.

The Polar Code is divided into two parts, which are governed by two committees, the Marine Environment Protection Committee and the Maritime Safety Committee. Gibbons spoke on updates to the Polar Code under the purview of the MSC.

Gibbons’ presentation focused on three key areas: IMO timeline updates, overview of the safety chapters and areas to be developed.

Update on the IMO timeline

Gibbons described the regulatory process and the IMO committee involved to create the Polar Code.

“We work from broad goals to functional requirements and then we turn those into regulations… This is our way of thinking through the problem and developing regulations to create a methodology to address the different risk factors identified,” said Gibbons.

The IMO follows a two-step process, which starts with regulation approval and then, six months later, adoption of that regulation. There is generally a two to three year phase-in period before compliance with an adopted rule is enforced.

There are two MEPC meetings coming in October. The IMO expects the environment chapters of the Polar Code and amendments to MARPOL associated with the Polar Code to be approved by the conclusion of these two meetings.

There is an MSC meeting scheduled for November where the IMO expects adoption of the safety part of the Polar Code and the SOLAS amendments.

In April there is another environmental meeting where the IMO expects the environmental parts of the Code to be adopted. After that, it is generally a two to three year phase-in period before compliance is required.

Overview of the safety chapters

The Code applies to cargo ships over 500 GT and passenger ships carrying more than 12 passengers, consistent with the applicability of SOLAS Chapter I.

“The Polar Code was written with a ship-specific focus so we’re looking at the crew on the ship, the equipment as well as plans and manuals used in day-to-day operations. This is important to demonstrate what the Polar Code is and what it is not. We’re not talking about geographic access or ship’s routing or infrastructure, this is all just for the ship and is in addition to IMO requirements,” said Gibbons.

Gibbons provided an overview of the chapters pertaining to the safety part of the Polar Code. The chapter titles are listed as bold bullets below:

• General Chapter within the Polar Code:
o Certification: the safety part of the Polar Code has a certificate that is separate from the SOLAS certificates
o Survey: will be done in a harmonized method to align with SOLAS methods
o Performance standards: the Polar Code requires a lowest temperature be set for equipment on board a ship. This is still under development as industry works with IMO to develop low temperature testing requirements for different equipment categories.
o Operational limitations: the different class societies are working on a proposal to the MSC in November. This will look at ship’s structure and equipment and set limitations for ice thicknesses, ice concentrations and ship speed

“The Polar Water Operational Chapter is a separate chapter of the Polar Code and a new concept. It’s about bringing in all different plans and manuals on the ship. In an effort to reduce administrative burden on industry, this can be rolled into a ship’s Safety Management System materials. If the plans and manuals already exist and the content required is already covered then these can be referred to. If not, then plans will need to be developed,” said Gibbons.

• Polar Water Operations Chapter (covers several different sections):

o Ships capabilities and limitations: look to guidance from Chapter 1 to develop
o Procedures for normal operations: includes voyage planning, crew endurance and provisions
o Contingency planning: search and rescue including strandings in ice and abandonment on ice or land
o Icebreaker escort or convoy (as applicable): if this is a part of a ship’s operations

• Ships Structure and Stability Chapters: identifies three different ship categories for ship structure and hull strengthening in ice, discusses ice accretion calculations for intact stability calculations, and ice damage conditions for damage stability calculations.

• Machinery and Fire Protection Chapters: protecting ships from damage from ice, ice accretion, snow ingestion, and freezing of liquids

• Life Saving Chapter: focuses on escape routes, evacuation and on board survival equipment required in addition to existing SOLAS requirements

• Navigation and Communication Chapter: addresses the effect of high latitude operations on ship’s navigation and communication equipment and includes additional communications equipment to communicate with search and rescue resources

• Crew Training Chapter: looks at cold weather familiarization training for all crew members, and STCW certifications for basic and advanced ice navigation training

Gibbons also discussed some areas still under development. 

The crew training chapter references STCW requirements that are currently being developed. The IMO will address and develop crew training standards at a sub-committee meeting in February. The Polar Code will require different levels of training based on these standards to be developed. This will include training on cold temperature familiarization for all crew members as well as STCW certification for ice navigation training.

Other areas still being discussed and developed within IMO committees and subcommittees are risk assessment, performance standards and certificates.

Presentations from Thursday’s workshop are available on the Docket. Submit your comments on the Polar Code by September 1, 2024 and subscribe to Maritime Commons for additional after-action blog-posts from the workshop!

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.