Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Date: N/A

Dear All,

This Newsletter aims to provide guidance on implementing the requirements for ships operating in polar waters due to the additional demands for safety and protection of the marine environment imposed by the Polar Code.

BACKGROUND

With increasing ship operations and shipping traffic in the polar waters, and following several incidents in recent years, there has been a focus towards increasing the safety of vessel design and operations.

The Polar Code has been on the IMO’s agenda since the 1990s, initially as non-mandatory guidance. Now, in response to increased operations and traffic in polar waters, it has been developed and made mandatory.

The Polar Code comprises a set of additions to SOLAS (new chapter XIV) and MARPOL Conventions, that is implemented through amendments to both these Conventions.

It contains the introduction, and two corresponding parts:

• The Introduction is applicable to both parts and includes the sources of hazards which shall be taken into account when carrying out an operational assessment

• Part I-A contains the mandatory requirements on safety measures for ships (safe design and operation of ships) and forms an add-on to the SOLAS requirements.

• Part 1-B contains recommendations on safety measures for ships;

• Part II-A contains the pollution prevention measures (environmental protection of the polar regions) and is implemented through amendments to MARPOL Annexes I, II, IV and V; and

• Part II-B contains recommendations on pollution prevention measures.

The Polar Code uses ship Categories to identify application of certain requirements based on anticipated hazards encountered for the expected operating environment. Three ship Categories are defined:

• Category A ship means a ship designed for operation in polar waters in at least medium first-year ice, which may include old ice inclusions.

• Category B ship means a ship not included in Category A, designed for operation in polar waters in at least thin first-year ice, which may include old ice inclusions.

• Category C ship means a ship designed to operate in open water or in ice conditions less severe than those included in Categories A and B.

The ship Category is a reflection of the expected severity of ice conditions that the ship is anticipated to operate in. The definitions in the Introduction part of the Code uses general ice descriptions based on World Metrological Organization (WMO) nomenclature.

The principal intention of the ship Categories is to group ships by their ability to operate safely in ice – ships intended to operate in more severe conditions (Category A and B ships) having additional requirements to mitigate the perceived additional hazards.

Category A: ships should be considered ships which are IACS Polar Class PC5 or above (PC4, PC3, PC2, PC1) or ships with an equivalent level of safety, such as reference.

Category B: ships should be considered ship which are IACS Polar Class PC7 or PC6 or ships with an equivalent level of safety, such as reference.

Category C: are ships which are ice strengthened and non-ice strengthened ships which do not fall into Category A or B. As such, ships of Category C may, or may not have an ice class, depending on the ice conditions that they are anticipated to operate in

It is to be noted that the ship Category is a result of the ice class assigned to the ship and not vice versa. The key principles for developing the Polar Code have been to use a risk-based approach in determining scope and to adopt a holistic approach in reducing identified risks.

APPLICABILITY:

Regardless of flag, the Polar Code applies to all ships carrying SOLAS certification that intend to operate in polar waters.

Part I applies to all new vessels whose keel is laid on or after 1 January, 2017, and to in-service vessels from their first intermediate or renewal survey after 1 January, 2018. Guidance on the initial survey for issuance of the Polar Ship certificate and maintenance surveys of the Polar Ship certificate is provided in MSC.1/Circ.1562.

Part II applies to all vessels operating in Polar waters from 1 January 2017.

SOLAS Chapter XIV has also been amended (see reference (f)) to apply the code to:

• Fishing vessels of 24 metres in length overall and above;
• Pleasure yachts of 300 gross tonnage and upwards not engaged in trade; and,
• Cargo ships of 300 gross tonnage and upwards but below 500 gross tonnage.

These vessels, constructed on or after 01 January 2026 need to comply with the requirements in new Chapters 9-1 and 11-1, contained in the amendments to the Polar Code adopted by Resolution MSC.538(107), reference (g). Those vessels constructed before 1 January 2026 shall meet the relevant requirements of chapters 9-1 and 11-1 the Polar Code by 1 January 2027.

The Polar Code uses a risk based approach with each chapter consisting of a goal, functional requirements to fulfil the goal, and regulations. A functional requirement provides the criteria to be satisfied in order to meet the goal and is developed based on experience, an assessment of existing regulations, and/or systematic analysis of relevant hazards

The Polar Code considers hazards which may lead to elevated levels of risk due to increased probability of occurrence, more severe consequences, or both:

• ice, as it may affect hull structure, stability characteristics, machinery systems, navigation, the outdoor working environment, maintenance and emergency preparedness tasks and malfunction of safety equipment and systems;

• experiencing topside icing, with potential reduction of stability and equipment functionality;

• low temperature, as it affects the working environment and human performance, maintenance and emergency preparedness tasks, material properties and equipment efficiency, survival time and performance of safety equipment and systems;

• extended periods of darkness or daylight as it may affect navigation and human performance;

• high latitude, as it affects navigation systems, communication systems and the quality of ice imagery information;

• remoteness and possible lack of accurate and complete hydrographic data and information, reduced availability of navigational aids and seamarks with increased potential for groundings compounded by remoteness, limited readily deployable SAR facilities, delays in emergency response and limited communications capability, with the potential to affect incident response;

• potential lack of ship crew experience in polar operations, with potential for human error;

• potential lack of suitable emergency response equipment, with the potential for limiting the effectiveness of mitigation measures;

• rapidly changing and severe weather conditions, with the potential for escalation of incidents; and

• the environment with respect to sensitivity to harmful substances and other environmental impacts and its need for longer restoration.

The risk level within polar waters may differ depending on the geographical location, time of the year with respect to daylight, ice-coverage, etc. Thus, the mitigating measures required to address the above specific hazards may vary within polar waters and may be different in Arctic and Antarctic waters.

A ship shall be considered to meet a functional requirements set out in part I when either:

1. the ship's design and arrangements comply with all the regulations associated with that functional requirement; or
2. part(s) or all of the ship's relevant design and arrangements have been reviewed and approved in accordance with regulation 4 of SOLAS chapter XIV, and any remaining parts of the ship comply with the relevant regulations.

The Polar Code requires an operational assessment described in paragraph 2.2 below to be carried out by the ship’s owner/operator.in determining the scope of its application to a ship and consequently to establish procedures or operational limitations to operate safely in polar waters.

For the full text please follow the link bellow.

• Marine Notice SAF-009 Rev. 01/26

For more information, please contact us at technical@phrs.gr

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Date: Immediate

Dear All,

This Newsletter aims to inform all concerned parties about the applicable IMO Data Collection System DCS reporting formats for the upcoming reporting cycles.

Reporting Year 2025 — Current Requirement

For the 2025 reporting year, companies are required to continue using the current IMO DCS reporting format.

No submission of enhanced data elements is required for this reporting period.

Specifically, for reporting year 2025:

• Fuel oil consumption shall be reported in accordance with the existing DCS format.
• Enhanced data elements introduced by recent amendments, including expanded fuel breakdowns, operational distinctions, cargo data, shore power, and port call purpose, are not required for 2025 submissions.
• The 2025 report shall be verified and submitted in line with the established IMO DCS process and timelines.

Reporting Year 2026 and Beyond — New Format

Recent amendments adopted by the Marine Environment Protection Committee 81 introduce an enhanced IMO DCS reporting dataset.

• Data for the 2026 reporting year shall be collected in the new reporting format starting from 1 January 2026.
• The 2026 report using the new format [MEPC.389(81)], shall be submitted to the verifier in 2027, in line with the standard IMO DCS submission cycle.
• For newbuild ships delivered on or after 1 August 2025, the new format applies from the date of delivery.

Next Steps

At this stage, companies should:

• Focus on completing the 2025 reporting year using the current format.
• In parallel, prepare systems and procedures during 2025 to enable collection of the enhanced dataset from 1 January 2026.

For more information, please contact us at technical@phrs.gr