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

Action Date: Immediate

This newsletter provides a concise overview of the 110th session of the Maritime Safety Committee (MSC 110), held from 18 to 27 June 2025. Key outcomes included the adoption of SOLAS amendments to enhance the safety of pilot and personnel transfer arrangements, as well as substantial progress on the development of a non-mandatory Code of Safety for Maritime Autonomous Surface Ships (MASS Code). The Committee also completed a review of regulatory safety barriers related to alternative fuels and new technologies, initiating measures to address these challenges in support of greenhouse gas (GHG) emission reduction from a safety standpoint.

Meeting highlights

• Adopted amendments to SOLAS Chapter V and the associated new Performance Standards to improve pilot transfer safety
• Approved draft amendments to the 2011 ESP Code to include remote inspection techniques (RITs) for close-up surveys
• Approved a 2025 Code on Alerts and Indicators
• Approved a revision of Resolution A.1050(27) “Revised Recommendations for Entering Enclosed Spaces Aboard Ships”
• Approved guidelines to support the introduction of emergency towing requirements on ships other than tankers
• Approved generic interim guidelines on training for seafarers on ships using alternative fuels and new technologies 
• Agreed on draft amendments to SOLAS Chapter II-1 to clarify the IGF Code application to all gaseous fuels, regardless of flashpoint
• Initiated measures to address identified regulatory barriers that may prevent the use of alternative fuels and new technologies, including updating the Code of Safety of Nuclear Merchant Ships
• Progressed the non-mandatory Code of Safety for Maritime Autonomous Surface Ships (MASS Code)
• Invited PSC authorities to adopt a pragmatic approach to the inspection of escape arrangements from machinery spaces while the Committee reviews the clarity of the current regulations

 

Amendments to mandatory instruments

• SOLAS Chapter V – safety of pilot transfer arrangements MSC 110 adopted amendments to SOLAS Regulation V/23 and the associated new Performance Standards for pilot transfer arrangements to ensure safe arrangements for pilots and other personnel embarking and disembarking ships in all conditions of draught and trim.

• Pilot transfer arrangements installed on or after 1 January 2028 shall be designed, manufactured, constructed, secured and installed in accordance with the new Performance Standards on or after 1 January 2028.

• Pilot transfer arrangements on SOLAS ships installed before 1 January 2028 shall be designed, manufactured, constructed, secured and installed with the new Performance Standards no later than the first survey on or after 1 January 2029.

• The requirements of the new Performance Standards for the inspection, stowage, maintenance, replacement and familiarization of all pilot transfer arrangements will enter into force on 1 January 2028, regardless of the installation date.

MSC 110 also approved an MSC circular on voluntary early implementation of the amendments to SOLAS Regulation V/23.

The following related instruments were approved:

• Amendments to the Code of Safety for Special Purpose Ships (2008 SPS Code)
• Amendments to the Code of Safety for Fishermen and Fishing Vessels, 2005
• A new MSC circular on “Required Pilot Transfer Arrangements for Pilots and Other Personnel”, revoking the illustrative guidance in MSC.1/Circ.1428 on “Pilot Transfer Arrangements – Required Boarding Arrangements or Pilots”.

The assembly will be invited to revoke Resolutions A.1045 (27) and A.1108(29) from 1 April 2030 as a consequence of the new Performance Standards.

SOLAS Chapter II-2 – correction of references
MSC 110 adopted amendments to two references in SOLAS Regulation II-2/11 to refer to the correct fire integrity tables in SOLAS Regulation II-2/9. The amendments will enter into force on 1 January 2028.

High Speed Craft Codes – life jackets
MSC 110 adopted amendments to Paragraph 8.3.5 of Annex 1 of the 1994 and 2000 High Speed Craft (HSC) Codes to harmonize the life jacket carriage requirements in the codes with the corresponding requirements in SOLAS Chapter III with respect to the number of infant life jackets and accessories to adult life jackets to accommodate large persons. The amendments will enter into force on 1 January 2028.

IMSBC Code – ships carrying solid bulk cargo
MSC 110 adopted amendments to the International Maritime Solid Bulk Cargoes (IMSBC) Code. The amendments include:

• The schedule for UN 2793 FERROUS METAL BORINGS, SHAVINGS, TURNINGS or CUTTINGS amended to prohibit entering a cargo hold for temperature measurements
• Re-classification of fish meal of Group B as MHB (SH) and Class 9
• New individual cargo schedules for aluminium sulphate granular, apatite concentrates, asphalt granulates, crushed granodiorite (coarse), ferric sulphate granular, fish meal of Group C, pea protein concentrate pellets, phosphate rock fines (uncalcined), tuff (coarse) and untreated incinerator bottom ash (U-IBA)
• Introduction of the apparent density as safety criteria for DIRECT REDUCED IRON (A)
• Harmonization of the segregation table for MHB cargo and dangerous goods in packaged form with the table in the IMDG Code

The 08-25 amendments to the IMSBC Code will enter into force on 1 January 2027.

The following related instruments were approved:

-          A revision of MSC.1/Circ.1266 on the “Carriage of Dangerous Goods” to refer to the IMSBC Code in a footnote

-          A revision of MSC.1/Circ.1264/Rev.1 on “Recommendations on the Safe Use of Pesticides in Ships Applicable to the Fumigation of Cargo Holds”

-          A revision of MSC.1/Cirx.1358/Rev.1 on “Recommendations on the Safe Use of Pesticides in Ships

-          A revision of MSC.1/Circ.1395/Rec.7 containing the “List of Solid Bulk Cargoes for Which a Fixed Gas Fire-extinguishing System May Be Exempted or for Which a Fixed Gas Fire-extinguishing System Is Ineffective”

IGC Code – ships carrying liquefied gas in bulk

MSC 110 progressed draft amendments to the IGC Code to incorporate the large number of Unified Interpretations (UIs) developed since the latest major review of the code, which entered into force in 2016. The primary objective of the draft amendments is to remove ambiguity and promote the consistent implementation of the IGC Code requirements.

Proposals for substantial changes to the draft amendments will be considered by CCC 11 (September 2025) and submitted to MSC 111 (May 2026) for approval. The proposals include clarifications related to fire safety, ventilation capacity and personnel protection.

The draft amendments to the IGC Code are expected to enter into force on 1 July 2028, subject to adoption by MSC 112 (December 2026).

The following MSC circulars, containing UIs to the IGC Code, will be suspended upon adoption and entry into force of the IGC Code amendments: MSC.1/Circ.1543, MSC.1/Circ.1559, MSC.1/Circ.1590, MSC.1/Circ.1606, MSC.1/Circ.1617, MSC.1/ Circ.1625, MSC.1/Circ.1651, MSC.1/Circ.1669 and MSC.1/ Circ.1679.

The MSC circulars will however remain in effect for existing ships constructed prior to the entry into force of the IGC Code amendments.

IGF Code – ships using gaseous fuels
MSC 110 agreed on draft amendments to SOLAS Chapter II-1 to clarify that the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code) applies to ships using gaseous fuels, whether they are low-flashpoint or not. A new definition of “gaseous fuels” was introduced accordingly.

Consequential draft amendments to the IGF Code were agreed accordingly, including draft amendments to the definition of “low-flashpoint fuels”.

The draft amendments to SOLAS and the IGF Code are expected to enter into force on 1 July 2028, subject to approval by MSC 111 (May 2026) and adoption by MSC 112 (December 2026).

The “one ship, one code” policy
The “one ship, one code” policy is a principle that a ship should be subject to only one safety code for gases or lowflashpoint liquids: either the IGC Code or the IGF Code. The intention is to apply one consistent safety philosophy and to avoid unintentional consequences that could arise from selecting requirements from various codes.

MSC 110 agreed that the policy should continue to apply for IGC Code ships using cargo included in Chapter 19 of the IGC Code as fuel, and that application guidelines should be developed for low-flashpoint fuels, other than the products listed in Chapter 19 of the IGC Code, used on gas carriers. Draft amendments to SOLAS Regulation II-1/56 to capture the agreed principles, and the related application guidelines, will be considered at MSC 111 (May 2026).

Maritime Autonomous Surface Ships

MSC 110 progressed the non-mandatory, goal-based Code of Safety for Maritime Autonomous Surface Ships (MASS Code). The code addresses the emerging need for a regulatory framework to ensure the safe, secure and environmentally sound operation of autonomous and remote-controlled key functions.

The code will be applicable to autonomous cargo ships and is intended to enter into force as a mandatory code upon experience with its application.

MSC 110 made significant progress, finalizing 18 chapters in the MASS Code, leaving mainly the chapter on the human element to be finalized.

An additional key decision was that unmanned MASS should be capable of assisting persons in distress. Vessels will therefore be required to have a plan for conducting SAR operations, even without crew on board.

It is important to note that the MASS Code will be a supplement to SOLAS and does not automatically relax any of the SOLAS requirements. Any exemptions from SOLAS must be agreed upon with the flag state during the approval process.

The non-mandatory MASS Code will be progressed in an intersessional Working Group meeting planned for the autumn of 2025, focusing on the human element aspects of the code.

The non-mandatory code is expected to be adopted at MSC 111 (May 2026), followed by an experience-building phase. A mandatory code is expected to enter into force on 1 January 2032, at the earliest.

New technologies and alternative fuels

MSC 110 concluded its consideration of potential alternative fuels and new technologies to support the reduction of GHG emissions from ships from a safety perspective. The intention is to identify safety obstacles, barriers and gaps in the current IMO instruments that may impede the use of the various alternative fuels and new technologies.

Recommendations to address the identified barriers and gaps for alternative fuels and new technologies were assigned to the relevant Sub-Committees. The extensive list of fuels and technologies to be considered include:

• Updating the Code of Safety for Nuclear Merchant Ships to account for advances in technology that have occurred since the code initially came into force (SDC)
• On-board carbon capture and storage (CCC)
• Battery energy storage systems (SSE)

Maritime cyber risk management

In 2024, MSC 108 and FAL 49 approved the third revision of the 2017 “Guidelines on Maritime Cyber Risk Management” (MSC-FAL.1/Circ.3/Rev.3), providing high-level recommendations for marine cyber risk management. The revision addresses risk assessment aspects, cyber resilience, and cybersecure equipment and systems while maintaining a holistic approach.

MSC 110 agreed that the development of a non-mandatory cybersecurity code would be the preferred next step, to be followed by an experience-building phase prior to the establishment of any mandatory provisions. Such code should be goal-based and incorporate risk management principles.

The development of such a cybersecurity code would require a new output proposal, and IMO Member States were invited to submit proposals to a future session of MSC.

Ship design and construction

Emergency towing devices on ships other than tankers
MSC 108 adopted amendments to SOLAS II-1/3-4 to extend the SOLAS requirements for emergency towing devices to all new ships over 20,000 GT to facilitate emergency assistance and towing operations and thereby reduce the risk of ship wreckage and pollution. The new requirements will enter into force on 1 January 2028.

MSC 110 approved the following related guidelines:

• New Interim Guidelines for Emergency Towing Arrangements on New Ships Other Than Tankers
• Amendments to the “Revised Guidance on Shipboard Towing and Mooring Equipment” (MSC.1/Circ.1175/Rev.1), addressing fittings and the supporting hull structures associated with normal towing and mooring operations, in addition to emergency towing operations for tankers; the amendments will align the guidance with IACS Unified Requirements (UR) A1 and A2 and IACS Recommendation No. 10, which were revised in 2022
• Consequential amendments to the “Guidelines for Owners/Operators on Preparing Emergency Towing Procedures” (MSC.1/Circ.1255)

Industrial personnel
MSC 110 approved draft amendments to the IP Code to align the weight used for stability calculations for ships certified according to SOLAS Chapter I with that for ships certified according to the HSC Code. Accordingly, the dimensioning weight for industrial personnel, including their PPE, will be consistently specified as 90 kg.

The draft amendments are expected to enter into force on 1 January 2028, subject to adoption by MSC 111 (May 2026).

Enhanced Survey Programme (ESP) for bulk carriers and oil tankers
MSC 110 approved draft amendments to the 2011 ESP Code to allow the use of remote inspection techniques (RITs) for close-up surveys of existing ships. An RIT is defined as a means of survey of any part of the structure without the need for direct physical access by the surveyor and should not be mixed with the concept of remote surveys.

A correction of MSC.1/Circ.1502 of the “Guidance on Pressure Testing of Boundaries of Cargo Oil Tanks Under Direction of the Master” to reflect the tank pressure testing provisions as per the latest 2011 ESP Code (Resolution MSC.525(106)) was also approved.

Safety netting on accommodation ladders
MSC 110 approved a revision of the “Guidelines for Construction, Installations, Maintenance and Inspection/Survey of Means of Embarkation and Disembarkation” (MSC.1/ Circ.1331) to reduce the operational safety risks of crew assigned to rigging safety nets.

Guard rails
MSC 110 approved draft amendments to Regulation 25(3) of the Load Lines Protocol so that also guard rails fitted on structures other than superstructures are required to have at least three courses. In addition, chains fitted in lieu of guard rails should be tightened as much as practicable and be detachable.

The draft amendments are expected to enter into force on 1 January 2028, subject to adoption by MSC 111 (May 2026).

Remotely operated valves
MSC 110 approved a UI of SOLAS Regulation II-1/12.6.2 to clarify the term “remotely controlled valve”. For ships constructed on or after 1 January 2024, the regulation allows a collision bulkhead to be pierced below the bulkhead deck of passenger ships and the freeboard deck of cargo ships, provided that the pipe is fitted with a remotely controlled valve capable of being operated from the above the bulkhead or freeboard deck.

The UI provides illustrations of arrangements and clarifies that “remotely controlled” does not have to mean “power actuated”; in other words, that a manual deck-standing type fitted on and operated from the bulkhead or freeboard deck may be accepted as “remotely controlled” if it also meets the fail-close requirements of SOLAS Regulation II-1/12.6.2.

2009 Code on Alerts and Indicators
MCS 110 approved draft amendments to the 2009 Code on Alerts and Indicators (Resolution A.1021(26)) to reflect new and updated IMO instruments approved since 2009, and to eliminate contradictions, ambiguities and redundancies.

The 2025 Code on Alerts and Indicators will be submitted to Assembly 24 (December 2025) for adoption.

Emergency escape from machinery spaces
SOLAS Regulations II-1/13.4.1 and 13.4.2 require an escape trunk to extend from the lower part of the machinery space, without defining “lower part”, and MSC.1/Circ.1511/Rev.1 clarifies that the “lower part of the space” should be regarded as the lowest deck level, platform or passageway.

MSC 110 considered the report of SDC 11, which had confirmed that the terms “lower part of the space” therein should be regarded as either the lowest deck level or a platform or passageway.

Noting the existence and impact of divergence in interpretations of the regulations in the context of Port State Control (PSC) inspections, MSC 110 agreed to include a new agenda item in the provisional agenda of SDC 12 (January 2026) on “Review and amend, if necessary, SOLAS Regulations II-2/13.4.1.1 and 13.4.2.1, with a view to clarifying the requirements on escape arrangements from the lower part of machinery spaces”.

MSC 110 also invited PSC authorities to adopt a pragmatic approach to the inspection of such arrangements while a long-term clarification of the issue is being considered, referring to Paragraph 1.2.5 of the PSC Procedures, i.e. “The PSC officer (PSCO) should in principle accept the design arrangement approved by the flag State and when appropriate consult with the flag Administrations”. A new MSC circular was approved to reflect the agreed approach.

Human element, training and watchkeeping

Training for seafarers on ships using alternative fuels
MSC 110 approved generic interim guidelines on training for seafarers on ships using alternative fuels and new technologies to support the reduction of greenhouse gas (GHG) emissions from international shipping (STCW.7/Circ.25).

Ship systems and equipment

Simulated launching of free-fall lifeboats
MSC 110 approved draft amendments to the LSA Code to require the simulation equipment (e.g. wires, chains) used for maintenance and testing to be designed and approved to account for the shock loading that may occur when the lifeboat comes to a sudden stop on the skid in simulated launching.

The draft new Paragraph 4.7.7 requires that the arrangement to test the release system under load is designed with a safety factor of at least 6 on the basis of the calculated maximum working load and the ultimate strength of the materials used for its construction.

Amendments to the following related instruments were approved, in principle, accordingly:

• MSC.402(96) – Requirements for the Maintenance, Thorough Examination, Operational Testing, Overhaul and Repair of Lifeboats and Rescue Boats, Launching Appliances and Release Gear
• MSC.81(70) – Revised Recommendation on the Testing of Life-saving Appliances
• MSC.1/Circ.1205/Rev.1 – Guidelines for Developing Operation and Maintenance Manuals for Lifeboat Systems 
• MSC.1/Circ.1529 – Unified Interpretations of Paragraph 4.4.7.6 of the LSA Code, as Amended by Resolution MSC.320(89)
• MSC.1/Circ.1578 – Guidelines on Safety During Abandon Ship Drills Using Lifeboats 
• MSC.1/Circ.1630/Rev.3 – Revised Standardized Life-saving Appliance Evaluation and Test Report Forms

Atmospheric oil mist detectors
MSC 110 approved a revision of the non-mandatory Code of Practice for Atmospheric Oil Mist Detectors (MSC/Circ.1086) to reflect experiences, current practices and new technologies since the Code was approved in 2003.

Launching of rescue boats on cargo ships
MSC 110 approved a UI of Paragraphs 6.1.1.3 and 6.1.2.2 of the LSA Code to clarify that for cargo ships, manual hoisting of a dedicated rescue boat may be acceptable for subsequent slewing by stored mechanical power.

Implementation of the PFOS ban
MSC 110 approved a UI of SOLAS Regulation II-2/10.11 and of the 1994 and 2000 HSC Codes to clarify how the PFOS ban may be documented.

Spacing of combined smoke and heat detectors
MSC 110 approved a UI of Paragraph 2.4.2.2 of Chapter 9 of the FSS Code relating to the spacing of combined smoke and heat detectors.

Factual statement for non-certified lifting appliances
MSC 110 approved a UI providing a factual statement for the testing and thorough examination of non-certified lifting appliances.

Life jacket buoyancy test
MSC 110 approved minor corrections to Resolution MSC.81(70) and MSC.1/Circ.1628/Rev.1 on the procedure for life jacket buoyancy tests and acceptance criteria for consistency with the LSA Code.

Survival equipment for survival craft and rescue boats
MSC 110 approved a minor correction to the LSA Code to reflect the latest version of the ISO 18813:2022 standard.

Application provisions of draft amendments to the LSA Code
MSC 108 noted that the application provisions for amendments to the LSA Code were not provided in a consistent manner, and that some application provisions were placed in the associated MSC resolutions rather than in the text of the requirements.

MSC 110 agreed to harmonize the approach – to ensure the effective implementation of requirements – by including an application table in the Preamble of the LSA Code, in accordance with MCS.1/Circ.1500/Rev.3. Equipment-specific installation provisions to incorporate the application provisions in Resolutions MSC.459(101), MSC.535(107) and MSC.554(108) were also approved.

The draft amendments to the LSA Code will be submitted to MSC 111 (May 2026) for adoption.

Carriage of cargo and containers

Safety of personnel entering enclosed spaces on board ships MSC 110 adopted a revision of Resolution A.1050(27) “Revised Recommendations for Entering Enclosed Spaces Aboard Ships”.

Work programme

MSC 110 agreed on the following items:

Sub-Committee on Implementation of IMO Instruments
Implementation of the ISM Code
MSC 110 agreed to initiate a comprehensive revision of the guidelines on the implementation of the ISM Code by flag administrations and companies.

Casualty Investigation Code
MSC 110 agreed to review the Casualty Investigation Code and the associated implementation guidelines (Resolution A.1075(28)).

Provisions left to the satisfaction of the Administration
MSC 110 agreed to the development of guidelines addressing the implementation of provisions left “to the satisfaction of the Administration”.

Sub-Committee on Navigation, Communications, Search and Rescue
R-mode receiver equipment

MSC 110 agreed to develop performance standards for Ranging mode (R-mode) in radionavigation receivers.

Financial architecture of the LRIT system

MSC 110 agreed to review the financial architecture of the LRIT system.

Sub-Committee on Ship Systems and Equipment
Firefighters’ outfits
MSC 110 agreed to clarify applicable equipment standards for firefighters’ outfits in Chapter 3 of the FSS Code.

Servicing of LSA
MCS 110 agreed to consider the consistent application of Resolution MSC.402(96) to high-speed craft and mobile offshore drilling units in the HSC Codes and MODU Codes.

Testing of pyrotechnics
MSC 110 agreed to revise Chapter 4 of Resolution MSC.81(70) concerning requirements for testing the compliance of pyrotechnics.

Prevention of engine room fires
MSC 110 agreed to consider mitigation of fire risks caused by leakages from low-pressure fuel pipes and lubrication oil pipes, and the use of thermal imaging cameras when inspecting insulations, in engine rooms.

Lowering speed for fast rescue boats
MSC 110 agreed to revise Paragraph 6.1.7 of Chapter VI of the LSA Code regarding lowering speed requirements for fast rescue boats.

Floor covering materials
MSC 110 agreed to consider revisions of testing requirements for floor covering materials in SOLAS Regulation II-2/6.2.1.

Regulatory consistency on fixed fire-extinguishing systems
MSC 110 agreed to consider a revision of SOLAS Regulation II-2/20 and Chapter 7 of the FSS Code to provide consistency on fixed fire-extinguishing systems.

Sub-Committee on Ship Design and Construction
Engine control room alert management
MSC 110 agreed to the development of engine control room alert management (ECRAM) performance standards.

Escape arrangements from machinery spaces
MSC 110 agreed to review and, if necessary, amend SOLAS Regulations II-2/13.4.1.1 and 13.4.2.1 to clarify the requirements on escape arrangements from the lower part of machinery spaces.

Sub-Committee on Human Element, Training and Watch keeping
Falls from heights
MSC 110 agreed to the development of guidelines addressing the risk of falls from height.

For any questions or further assistance, please do not hesitate to contact us at technical@phrs.gr .

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

Action Date: Immediate

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