IMO III 12: Initiation of ISM implementation guidelines revision and progression of survey requirements revision

Information for: Shipowners and managers, flag administrations, Recognized Organizations and Port State Control authorities.

Introduction

The 12th session of the IMO Sub-Committee on Implementation of IMO Instruments (III 12) took place on 20–24 July 2026. The Sub-Committee initiated the comprehensive revision of the guidelines on the implementation of the ISM Code by Administrations and companies, continued updates to the “Survey Guidelines under the Harmonized System of Survey and Certification (HSSC)”, advanced work on harmonization of Port State Control (PSC) activities, and reviewed lessons learned from marine casualty investigations.

Comprehensive revision of the guidelines on the implementation of the ISM Code by Administrations and companies

III 12 initiated the comprehensive revision of the Guidelines on the implementation of the ISM Code by Administrations and companies, with the objective of improving the effectiveness and consistency of the ISM Code implementation across the industry.

Key outcomes included:

• Identified areas for further consideration during the comprehensive review, which may lead to revisions on the guidelines for implementation of ISM Code for Administrations and Companies
• Agreed a roadmap to develop draft amendments for consideration at III 14
• Established a Correspondence Group, which will deliver a report to III 13
• Agreed that submissions relevant for the comprehensive revision of the guidelines may be sent to III 13

Updated “Survey Guidelines under the Harmonized System of Survey and Certification (HSSC)”

III 12 continued the periodic update of the HSSC survey guidelines, and agreed a range of draft amendments aimed at supporting the uniform implementation of new IMO requirements and emerging survey practices.

Key decisions included:

• Updated the HSSC survey guidelines to reflect IMO amendments entering into force through 2027, including new survey requirements related to fire safety, navigation equipment and lifting appliances
• Agreed more detailed survey requirements for pilot transfer arrangements, introducing clearer compliance checks linked to the revised SOLAS V/23 requirements
• Endorsed a new coding system for determining remote survey eligibility of individual survey items, with further development to continue inter-sessionally, while recognizing the need for establishing a methodology for a harmonized approach to more digital, hybrid survey techniques
• Finalized amendments to the IMO list of certificates and documents required to be carried on board, helping to ensure that statutory documentation requirements remain aligned with recent amendments to IMO instruments
• Initiated development of survey guidelines for the Hong Kong Convention, with a view to future incorporation into the HSSC framework
• Commenced further consideration of how Safe Return to Port requirements should be reflected in future HSSC survey guidance

III 12 Finalized amendments to the IMO guidance on the transfer of ships between states (change of flag), including updated information-sharing arrangements during flag transfers.

Harmonized Port State Control (PSC) procedures and PSC officer training

III 12 continued work to improve the consistency and effectiveness of Port State Control (PSC) inspections worldwide, with particular focus on PSC officer competence, machinery and maintenance inspections, and the development of training tools for new PSC officers.

The discussions recognized the need for greater harmonization, while maintaining the risk-based nature of PSC inspections and preserving clear boundaries between PSC activities and the responsibilities of flag administrations and Recognized Organizations.

Key discussion points included:

• Progressed the development of harmonized guidance for machinery, electrical and maintenance-related PSC inspections, with the aim to improve consistency between PSC regimes
• Reviewed qualification and competence requirements for PSC officers, recognizing the importance of appropriate training and competence while identifying a need for further work on the future competency framework
• Considered that PSC inspections should remain risk-based, proportionate and distinct from flag state and Recognized Organization survey activities
• Identified the need for further development before machinery and maintenance inspection guidance can be incorporated into the IMO Procedures for Port State Control, including verification of technical content and inspection boundaries
• Updated the list of instruments relevant to PSC procedures as part of the ongoing revision of the PSC framework
• Progressed the development of the framework to the proposed entrant training manual for PSC officers, intended to promote a more consistent baseline level of training without duplicating the PSC procedures themselves

Casualty investigations and lessons learned

III 12 approved a circular containing 63 new lessons learned from marine casualties. These will be published on the IMO website for industry dissemination.

III 12 reviewed 59 marine safety investigation reports, and recurring safety issues included deficiencies in safety management system implementation, risk assessment, permit-to-work processes, enclosed space entry, maintenance, communication, and bridge resource management.

III 12 considered the following lessons learned and follow-up:

• High-pressure cylinder failures (analysis finalized for dissemination through an IMO circular)
• Fire safety standards for cargo handling spaces of self-unloading bulk carriers (new output recommended for MSC approval)
• Risks associated with inflatable lifejackets (new output recommended for MSC approval)
• BNWAS operation and traceability of system status (further analysis assigned to the Correspondence Group)
• Safety issues identified from the MV Dali casualty and implications for ISM Code implementation guidelines (further intersessional review agreed)
• Enclosed space fatalities, falls from height, cargo handling accidents and collision avoidance continue to feature prominently among the lessons learned from casualty investigations.

III 12 initiated a comprehensive review of the Casualty Investigation Code and its associated implementation guidelines, with the aim to improve the quality, consistency and timeliness of marine casualty investigations and reports. A Correspondence Group was established to further develop proposals for consideration at future sessions, with a target completion year of 2028.

Recommendations

DNV recommends that shipowners/managers note the ongoing revision of ISM implementation guidance; developments of the HSSC survey guidelines, including remote survey eligibility and pilot transfer arrangements; continuing efforts to harmonize PSC inspections and procedures; and the lessons learned from casualty investigations.

DNV will continue monitoring the development of these IMO discussions and support customers in understanding any practical implications.

As III is a Sub-Committee, all decisions concerning rules, regulations and dates are subject to further consideration and approval by the Maritime Safety Committee (MSC), the Marine Environment Protection Committee (MEPC) or the Assembly.