Sub-Committee on Carriage of Cargoes and Containers (CCC 9), 9th session, 20-29 September 2023

Development of safety guidelines for alternative fuels 

The Sub-Committee made significant progress on the development of draft interim guidelines for the safety of ships using hydrogen and ammonia as fuel.

Taking into account the urgency of providing guidance to Administrations, shipowners and the industry at large on the safe use of hydrogen and ammonia as fuel, and in support of the Organization's emission targets, the Sub-Committee agreed to convene an intersessional working group from 9 to13 September 2024, immediately prior to CCC 10 (subject to approval by MSC 108 and endorsement by the Council), to finalize the guidelines.

Time permitting, the working group will also be invited to further develop the draft interim guidelines for ships using low-flashpoint oil fuels.

The Sub-Committee agreed to a draft MSC circular on Interim guidelines for use of LPG cargo as fuel, for approval by MSC 108, which provides additional coverage for ships under the IGC Code and complements the Interim guidelines for the safety of ships using LPG fuels (MSC.1/Circ.1666) approved by MSC 107. Meanwhile, the Sub-Committee also initiated the development of draft amendments to the IGC Code with respect to the safe use of LPG as fuel, based on the Interim Guidelines, as well as provisions for the safe use of LPG as fuel for gas carriers carrying cargoes other than LPG listed in chapter 19 of the IGC Code.

The CCC Sub-Committee plays a vital role in the development of technical provisions for alternative fuels and related technologies, ensuring that safety implications and potential risks associated with the use of alternative fuels and related technologies are duly addressed. Guidelines already developed include: Interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel (MSC.1/Circ.1621); Interim guidelines for ships using fuel cells (MSC.1/Circ.1647); and Interim guidelines for the safety of ships using LPG fuels (MSC.1/Circ.1666).

The work plan, updated at this session, foresees the further development of guidelines as follows:

  • MSC 109 (2-6 Dec 2024) - approval of the guidelines for ships using hydrogen as fuel and of the guidelines for ships using ammonia as fuel.

  • CCC 11 (Sep 2025) - further development/finalization of guidelines for low flashpoint oil fuels; if time permits, development of mandatory provisions for methyl/ethyl alcohols and start of discussions on the development of mandatory provisions for fuel cells.

  • MSC 111 (May 2026) - approval of guidelines for low-flashpoint oil fuels.

  • CCC 12 (Sep 2026) - further development/finalization of mandatory provisions for methyl/ethyl alcohols and further development of mandatory provisions for fuel cells.

Amendments to the IGF Code

The Sub-Committee agreed to draft amendments to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), which provides an international standard for ships other than vessels covered by the IGC Code operating with gas or low-flashpoint liquids as fuel. The draft amendments relate to new and amended requirements for new ships under ship design and arrangement; and regulations for general pipe design, safety functions of gas supply system, fire protection, hazardous area zones and ventilation.

The draft amendments will be submitted to MSC 108 with a view to approval and subsequent adoption at MSC 109, for entry into force on 1 January 2028.

Interim recommendations for carriage of liquefied hydrogen in bulk

The Sub-Committee agree to draft revised interim recommendations for carriage of liquefied hydrogen in bulk, for submission to MSC 108 for approval.

Review of the IGC Code

The Sub-Committee continued its ongoing revision of the International Code of the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) and made progress on the development of relevant draft amendments, with a view to finalization at CCC 10, approval at MSC 109, and subsequent adoption at MSC 110, for entry into force on 1 January 2028.

The Sub-Committee endorsed the view that high manganese austenitic steel is considered resistant to ammonia stress corrosion cracking and, therefore, suitable for ammonia cargo and/or fuel tanks containing ammonia. The Sub-Committee agreed to revisions of the Revised guidelines on the application of high manganese austenitic steel for cryogenic service (MSC.1/Circ.1599/Rev.2) and the Guidelines for the acceptance of alternative metallic materials for cryogenic service in ships carrying liquefied gases in bulk and ships using gases or other low-flashpoint fuels (MSC.1/Circ.1622), both for submission to MSC 108 for approval.

Revision of recommendations on entering enclosed spaces

A working group established during the meeting made important progress on the development of preliminary draft revised recommendations for entering enclosed spaces aboard ships. Recommendations on entering enclosed spaces on board ships were adopted in 2011 by resolution A.1050(27). However, in recent years, an alarming frequency of accidents related to entering enclosed spaces has been observed, resulting in a profoundly distressing culmination of human lives lost.

A correspondence group was established to further develop the draft recommendations, with a view to finalization at CCC 10.

Amendments to the IMDG Code

The Sub-Committee continued preparing the next set of amendments to the International Maritime Dangerous Goods (IMDG) Code and instructed the Editorial and Technical Group to finalize the draft text of amendment 42-24 to the Code, with a view to circulation and subsequent adoption at MSC 108.

Review of transport provisions for vehicles

The Sub-Committee considered the report of the Correspondence Group on the Review of Transport Provisions for Vehicles and, following discussion in a drafting group, re-established the correspondence group and encouraged interested Member States and international organizations to actively participate in its work.

The group was tasked to continue consideration of amendments to transport provisions for vehicles; based on root cause analysis of previous incidents and identified risks and hazards, to develop recommendations for the IMDG Code provisions concerning the transport of vehicles; and submit a report to CCC 10.

Maritime transport of plastic pellets

As requested by the Sub-Committee on Prevention of Pollution and Response (PPR), the Sub‑Committee discussed a draft MEPC circular on recommendations for the carriage of plastic pellets by sea in freight containers. The Sub-Committee agreed with the recommendation in the draft recommendations that plastic pellets should be packed in good quality packaging which should be strong enough to withstand the shocks and loads normally encountered during transport. Packaging should be constructed and closed so as to prevent any loss of contents which may be caused under normal conditions of transport, by vibration or acceleration forces.

The Sub-Committee noted discussions on various submissions and invited the PPR Sub-Committee to note that the views expressed could be taken into account in further developments to reduce the environmental risk associated with maritime transport of plastic pellets.  

The draft recommendations are expected to be finalized by PPR 11 in February 2024, for submission to MEPC 81 (spring 2024) for approval.

Updating the International Maritime Solid Bulk Cargoes (IMSBC) Code

The Sub-Committee initiated the preparation of the next set of amendments to the International Maritime Solid Bulk Cargoes (IMSBC) Code, with a view to adoption in 2025, and instructed the Editorial and Technical Group accordingly.