ATTACHMENT 1 - IACS POSITION AT MEPC 41
IACS wishes to comment on the ISO papers MEPC 41/4/1 and MEPC 41/INF 15, particularly as regards the scope and work of the ISO Technical Committee 8 (ISO/TC 8), and its overlap with the work of IACS Member Societies.
IACS Members have produced rules on the basis of considerable research and development and feedback from survey reports for ship structures and essential shipboard engineering systems and applied them for many, many years. Indeed some have done so for over 100 years, well before any Administration had any ship safety legislation on its statute books. Consequently, there has not been any need to this day for individual Administrations to legislate regarding ship structures and essential shipboard engineering systems. Nor has there been any need for IMO Conventions to lay down detailed requirements for these fundamental items of ship safety.
Nevertheless, the 1960 SOLAS Convention and its successor the 1974 SOLAS Convention, require ships to which the Conventions apply to be issued with either Cargo Ship Safety Construction Certificates (SAFCON) or Passenger ship Safety Certificates. A condition of issuance of either certificate is that the ship's structure and the essential shipboard engineering systems are suitable for the service intended. Yet neither SOLAS 60 nor SOLAS 74 contain detailed regulations for these items. It has always been implicit, since 1965 when SOLAS entered into force, that compliance with rules of a major classification society would form the basis for issuance of SAFCON and Passenger Ship Safety Certificates.
On 1st July 1998 this previously implicit requirement will become explicit, by virtue of entry into force of SOLAS regulation II-1/3-1. This regulation requires that ships shall be designed, constructed and maintained in compliance with the structural, mechanical and electrical requirements of a classification society which is recognised by the Administration in accordance with the provisions of SOLAS regulation XI/1. All IACS members are so recognised.
It is clear that ISO/TC 8 involvement in the field of ship structures and essential shipboard engineering systems would be in conflict with IACS Members' involvement in the production of classification rules for these matters. At the very least ISO involvement in this field would be a duplication of effort, but it is more probable that standards produced by ISO would be different from those produced by IACS members for classification purposes. This could cause confusion in the industry and the question would arise as to whether to apply ISO standards or IACS Members' classification standards. In this respect, since impending SOLAS' regulation II-1/3-1 requires compliance with classification society requirements on a statutory basis, classification standards must surely take precedence over ISO standards.
Sir, IACS has no concern about ISO's quite correct involvement in setting standards for equipment, which is an area where there is no conflict or confusion. However, as previously stated, in the field or ship structures and essential shipboard engineering systems there is most certainly a conflict and this could cause considerable confusion.
It would seem essential that this problem be faced honestly and realistically, with a view to a satisfactory resolution. Conflict between IACS and ISO should be avoided by a clear definition of the respective areas of involvement.
