This post is about interpretations of Maritime Regulations. To write something useful, I was trying to find my way through the IMO website.
Every time I find new stuff here. Now I found this IMO recommendations on how to reduce administrative work. Lots of recommendations on how to avoid and reduce administrative burdens. I think that everybody who try to find information on the IMO website can add a few more points. Probably the combination of point 2, 11, 12 and 13 will give in the future a better insight on the interpretations of maritime regulations by IMO.
Several reasons to streamline the interpretation
Interpretations of regulations is a source of confusion for different reasons:
- class rules are not the same from class to class, interpretation of a class rule is the class responsibility. Sailing on different ships you will encounter different class requirements and interpretations
- which inspector is making the interpretation. It can be a class surveyor, flag state inspector or port state inspector. All three are looking different to a certain subject.
- even there are difference between the separate inspector of for example the class, as each individual brings a different kind of experience and knowledge.
- the superintendent can have a different view, his manager can have different view. Sometimes driven also by other forces then just the regulations
- the interpretations of the master or chief engineer can also have some fluctuations
The Administration interpretation
Because I will write about unified interpretations, it must be made clear that the Administration interpretation of any maritime regulation is leading. Only if an Administration doesn’t have its own interpretation, the unified interpretation of maritime regulations will apply. Those unified interpretation are only written if the IMO or the IACS finds the wording in the regulation too vague for the ships owner and the inspectors.
One useful document, which is not so commonly know around the world is from the IMO. It states which publications from IMO are mandatory on a ship.
IMO Unified Interpretation of Maritime Regulations
To keep things simple: let’s start with the IMO Unified interpretations. Those interpretations are sometimes developed by IACS and introduced by IMO.
IMO maintain the site called IMODOCS but it is actually named as docs.imo.org, logically naming is not the strongest point. Registration is for free. Under the tab circulars all unified interpretations of the IMO can be found. I wish you good luck with this as their might be logically ordered from the administrator point of view, but finding something useful is a day task, at least for me.
IACS Unified Interpretation of Maritime Regulations
IACS is an non governmental organization and has several class societies combined. As class surveyors are often inspecting a vessel for the flag state, IACS like to give unified interpretations to their surveyors:
Stated at the IACS website:
Interpretations are circulated to Administrations concerned or are sent to IMO for information, as appropriate.
So the members of the IMO are making some kind of regulation which is so vaguely worded that IACS finds an practical interpretation more useful for their surveyors.
These Unified interpretations of IACS are differently numbered then those of the IMO. Seen the fact that each classification society has their own department which are following the IMO, one can assume that there will be no contradiction between the IMO interpretation and those of IACS. Another reason to follow the IACS interpretation in stead of the IMO is that the IMO interpretations are not mandatory but the interpretations of the Administrations are mandatory.
If the surveyor from IACS inspect a vessel for example an emergency escape, then he or she will follow the interpretations from the Administration. And the Administration is normally in a closer contact with the classification society then with the IMO.