E

MARITIME SAFETY COMMITTEE MSC 104/15/17

104th session 2 July 2021
Agenda item 15 Original: ENGLISH
Pre-session public release: ☒

WORK PROGRAMME

Proposal for a new output on developing a road map to address Maritime Autonomous
Surface Ship (MASS) operations in IMO instruments

Submitted by China

SUMMARY

Executive summary: This document contains a proposal for the development of a road
map to address Maritime Autonomous Surface Ship (MASS)
operations in IMO instruments. The road map will establish
objectives, work items, methodologies, working mechanism and
timeline with a view to facilitating the Organization to integrate new
and advancing technologies in the regulatory framework in an
orderly and holistic manner.
Strategic direction, 2
if applicable:

Output: Not applicable

Action to be taken: Paragraph 29

Related documents: MSC 103/21 and MSC 103/WP.8

Introduction

1 This document is submitted in accordance with the provisions of the Organization and
method of work of the Maritime Safety Committee and the Marine Environment Protection
Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5/Rev.2).

2 The maritime sector is witnessing an increased deployment of MASS to deliver safe,

cost-effective and high-quality results. Significant academic and commercial research and
development are ongoing on all aspects of MASS.

3 MSC 98 agreed to include in its 2018-2019 biennial agenda an output on "Regulatory

Scoping Exercise (RSE) for the use of Maritime Autonomous Surface Ships (MASS)" with a
target completion year of 2020.

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4 The outcome of the RSE, approved at MSC 103, provides the assessment of the
degree to which the existing regulatory framework under its purview might be affected in order
to address MASS operations. It further provides guidance to MSC and interested parties to
identify, select and decide on future work on MASS and, as such, facilitate the preparation of
requests for, and consideration and approval of, new outputs.

5 This document contains a proposal for developing a road map to address MASS
operations in IMO instruments to enable the safe, secure and environmental operation
of MASS.

IMO's objectives

6 The proposal to develop a road map to accommodate MASS in the IMO regulatory
framework would enable IMO to holistically address the common potential gaps and/or themes
identified in the outcome of the RSE. Taking into account resolution A.1110(30) on Strategic
plan for the Organization for the six-year period 2018 to 2023, this proposal is related to
strategic direction 2 "Integrate new and advancing technologies in the regulatory framework".

7 IMO, as the regulatory body for the shipping industry, is nevertheless committed to
ensure the safety operation of MASS. Therefore, this proposal is deemed to be within the
scope of IMOʹs mission and would benefit the effective implementation of the Strategic Plan.

Need

8 According to the outcome of the RSE approved at MSC 103, there are a number of
IMO regulations that currently present a challenge to the deployment of MASS. IMO in its role
as the primary international forum for technical matters of all kinds affecting international
shipping should therefore take a proactive role to ensure there is a holistic approach to address
the issues with regard to MASS. However, the current legislation of IMO does not provide
mechanisms of influence on behaviour of Member States to make them apply the best
measures of MASS.

9 The RSE helped us to better understand the level of complexity of addressing MASS
in the IMO regulatory framework, which could be argued as one of the most challenging work
in the history. In this regard, the RSE provided vital experience on how to promote such a
unique and complex task. The framework developed prior to the scoping exercise had greatly
facilitated the process by establishing clear objectives, outputs, methodology, procedures and
timeline. Therefore, it is believed that a road map is indispensable to the even more significant
work to substantially address MASS in IMO instruments in an orderly and holistic manner.

10 Therefore, it is China’s perspective of view that there is a need to develop a road map
to address MASS operations in IMO instruments, so that there is a common understanding of
the scope of work and procedures which would be necessary to incorporate MASS in the IMO
regulatory framework with a view to enabling its safe and environmental sound operation.

Analysis of the issue

11 While the exact content of the road map would be the product of further discussion,
the road map should entail the following primary components.

12 Firstly, the road map should define the work items and their prioritization. It was
identified in the outcome of the RSE that the best way forward to address MASS in the
IMO regulatory framework could, preferably, be addressed in a holistic manner through the
development of a goal-based MASS instrument (MSC 103/WP.8, paragraph 31.1), along with

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some priority work including the revision of the definition of MASS, development of terminology
for MASS operations, consideration of common gaps and themes, development of a non-
mandatory instrument (MSC 103/WP.8, annex, table 6). Based on these findings, specific work
items and output need to be set in a Special Monitoring of Applied Response Technologies
(SMART) way to further clarify the scope of work. These work items could include the
development of a MASS Code, amendments to relevant Conventions to accommodate MASS
operations, development of a globally agreed MASS definition, establishment of a unified
understanding on the common gaps/themes, development of interim or supporting guidelines,
etc. Furthermore, the prioritization should be provided as some of the horizontal legal issues
need to be addressed first. For instance, a globally agreed definition of MASS would be a
prerequisite to define the application scope of the MASS instrument.

13 Secondly, the road map should include a practical and unified methodology. The RSE
has identified a list of common potential gaps and/or themes (MSC 103/WP.8, annex, table 2).
As some Member States pointed out, the outcome of the RSE indicates that the views on how
these issues which are to be dealt with in the context of MASS are significantly different. More
particularly, the volunteering countries had reviewed the relevant instruments with significantly
different understandings of what to presume (MSC 102/5/7, paragraphs 14 and 15). In this
regard, a consensus needs to be reached first on the approach to review these common
potential gaps and/or themes by establishing the methodology in the road map. For instance,
the risk assessment could be an effective means to ensure the safety of remote operation and
the qualification of remote operator as seafarers could be examined from the perspective of
both navigation and computer science.

14 Thirdly, the road map should identify the appropriate working bodies for each work
item. According to the outcome of the RSE, quite a number and range of IMO instruments
would be affected by the use of MASS. In this regard, the expertise of individual
sub-committees could be fully utilized during the process, especially regarding technical issues.
Meanwhile, the discussion on general and common issues should remain at the committee
level. Additionally, the need to establish a cross-committee working group should be
considered, as it is recognized by MSC 103 that future work with respect to main issues and
common potential gaps and/or themes should be coordinated between the committees and
that such coordination could be realized by establishing a joint working group or through other
means (MSC 103/WP.1, paragraph 5.32).

15 Finally, a clear and feasible timeline should be established in the road map taking into
account the prioritization of work items and the workload required. It is also recognized that
the development of MASS technology is an evolving process, thus the timeline set by the road
map should be in line with the development progress of technology, thereby to avoid the risk
of rushing into regulatory work without sufficient practical support.

16 The process of developing the road map should take full account of the outcome of
the RSE. Furthermore, China is mindful that the real-world practice of maritime industry and
Member States is of extreme importance to the regulatory work. In light of this, the
development of road map should take full use of the experiences gained in the MASS-related
trial and operation activities.

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Analysis of implications

17 The development of a road map to address MASS operations in IMO instruments

would not bring any extra cost to the maritime industry as well as the relevant legislative and
administrative burdens on itself, and the Checklist for Identifying Administrative Requirements,
as set out in annex 1, has been completed on this basis. Moreover, China believes that the
road map would facilitate the Organization to incorporate MASS operations in the regulatory
framework in an orderly and coordinated manner so as to minimize the legislation and
administrative burden.

Benefits

18 As the digital era increasingly reaches deeper into maritime transport, MASS-related
activities are taking place all over the world. It is recognized that the development of MASS
may present challenges to the maritime safety, security and environment, especially given the
fact that MASS and conventional vessels are expected to co-exist in the maritime transport for
quite a long time. Potential gaps including human-machine interface, cybersecurity,
connectivity, etc. were also captured in the outcome of the RSE. The gaps between technology
development and regulation needs to be closed timely so that the shipping industry can fully
enjoy the benefit brought by innovative technology to achieve more significant safety and
efficiency improvements.

19 Along with the deployment of MASS technologies, national regulations, guidelines

and standards are being developed and implemented based on different interpretations of
MASS operation and its impact on maritime safety, security and environment protection. The
proposal to develop a road map to address MASS operation under the IMO framework will
facilitate Administrations and the industry to establish a common ground on fundamental
issues regarding MASS legislation, including the definition of MASS, the role of the master,
terminology, etc. and thereby to better provide a universal and uniform standard for the use of
MASS.

Industry standards

20 There are a number of MASS-related industry standards and rules developed by class
and ISO and the maritime sector, some of which are already being applied in the manufacture
stage and trial operation of MASS. Up till now, the world uniform standards for MASS
operations are still absent although the work on the RSE of using MASS had been finalized
and the outcome had been approved by the Committee. No consensus has been reached
among Members and relevant Organizations on the definition and degree of MASS and the
terminology concerning MASS operation especially. This will largely be incompatible with or
hinder the future development of MASS technology.

Output

21 The proposed new output would be: "Development of a road map to address MASS
operations in IMO instruments".

22 The road map should at least consist of the following parts:

.1 Objective: to clarify the goal of incorporating MASS operations in the

IMO regulatory framework to ensure the safe, secure and environmental
sound development of MASS;

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.2 Work items and prioritization: to set specific work items to be carried out with
a view to achieving the objective, which could include development of a
MASS Code, amendments to relevant conventions to accommodate MASS
operations, development of a globally agreed MASS definition,
establishment of a unified understanding on the common gaps/themes,
development of interim or supporting guidelines, etc. A prioritization should
also be indicated in the road map;

.3 Methodology: to adopt a practical, effective and unified approach to conduct

the work items. Some overarching principles could be developed to guide the
future work;

.4 Working mechanism: to establish the best working bodies of each work item,
including distribution of work to sub-committees and/or establishment of
intersessional/cross-committee working groups. A proper way to coordinate
MASS-related regulatory work under a different working body should also be
established to ensure consistency; and

.5 Timeline: to set a clear timeline for the start and completion of each work
item.

23 The road map should be developed based on the outcome of the RSE, especially the
high-priority issues identified in document MSC 103/WP.8.

Human element

24 The proposal is to develop a road map, there would be no implications for the human
element arising from this output in itself. The Checklist for identifying human element issues,
as set out in annex 2, has been completed on this basis.

25 However, the human element would be considered when developing the MASS
instrument and discussing the common gaps and themes such as the role of the master and
remote operator and other personnel.

Urgency

26 With the maturation of commercial utilization of sensor technology, big data, Internet
of things, and artificial intelligence technology, more and more new and advancing technology
is applied in the shipping industry, leading to the continuous increased size and geographical
deployment of MASS. IMO would have to embark on the regulatory work on MASS as soon as
possible to adapt to the development and application of new technology in the maritime sector,
so as to better promote safe, secure, environmental sound, efficient and sustainable shipping.

27 As identified in the RSE outcome, numerous issues that involve several

IMO instruments remain to be addressed with a view to integrating MASS operations in the
IMO regulatory framework. Meanwhile the RSE work undertaken by the Legal and Facilitation
Committees is yet to be finalized. The discussion on some horizontal legal issues needs to be
coordinated and consolidated at the committee level. Therefore, China is convinced that the
development of a road map with a clear working framework will largely promote the process of
legislation and it needs to be initiated as soon as possible.

28 Two sessions are needed to complete the development of the road map. Following
that, the substantial work should commence and be completed in accordance with the timeline
set in the road map. Therefore, it is proposed that the discussion on the road map starts as

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soon as possible to address the urgent need for MASS legislation. It is also proposed that IMO
should consider and put the proposal in the High-level Action Plan of the 2022-2023 biennium.

Action requested of the Committee

29 The Committee is invited to consider the information provided above and agree to the
new output as proposed in paragraphs 21 to 23.

***

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Annex 1, page 1

ANNEX 1

CHECKLIST FOR IDENTIFYING ADMINISTRATIVE REQUIREMENTS AND BURDENS

The Checklist for Identifying Administrative Requirements and Burdens should be used when
preparing the analysis of implications required in submissions of proposals for inclusion of
unplanned outputs. For the purpose of this analysis, the terms "administrative requirements"
and "burdens" are as defined in resolution A.1043(27), i.e. administrative requirements are
an obligation arising from future IMO mandatory instruments to provide or retain information
or data, and administrative burdens are those administrative requirements that are or have
become unnecessary, disproportionate or even obsolete.

Instructions:

(A) If the answer to any of the questions below is YES, the Member State
proposing an unplanned output should provide supporting details on whether
the burdens are likely to involve start-up and/or ongoing costs. The Member
State should also make a brief description of the requirement and, if possible,
provide recommendations for further work (e.g. would it be possible to combine
the activity with an existing requirement?).

(B) If the proposal for the unplanned output does not contain such an activity,
answer NR (Not required).
1. Notification and reporting?
Yes
Reporting certain events before or after the event has taken NR
place, e.g. notification of voyage, statistical reporting for IMO ☐ Start-up
☒
Members, etc. ☐ Ongoing
Description: (if the answer is yes)

2. Record keeping?
Yes
Keeping statutory documents up to date, e.g. records of NR
accidents, records of cargo, records of inspections, records of ☐ Start-up
☒
education, etc. ☐ Ongoing
Description: (if the answer is yes)

3. Publication and documentation? Yes

Producing documents for third parties, e.g. warning signs, NR ☐ Start-up
registration displays, publication of results of testing, etc. ☒ ☐ Ongoing
Description: (if the answer is yes)

4. Permits or applications? Yes

Applying for and maintaining permission to operate, e.g. NR ☐ Start-up
certificates, classification society costs, etc. ☒ ☐ Ongoing
Description: (if the answer is yes)

5. Other identified burdens? Yes

NR ☐ Start-up
☒ ☐ Ongoing
Description: (if the answer is yes)

***

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Annex 2, page 1

ANNEX 2

CHECKLIST FOR CONSIDERING HUMAN ELEMENT ISSUES BY IMO BODIES

Instructions:
If the answer to any of the questions below is:

(A) YES, the preparing body should provide supporting details and/or recommendation for
further work.
(B) NO, the preparing body should make proper justification as to why human element
issues were not considered.
(C) NA (Not Applicable) – the preparing body should make proper justification as to why
human element issues were not considered applicable.

Subject Being Assessed: (e.g. Resolution, Instrument, Circular being considered)

Developing a road map to address MASS operations in the IMO instrument
Responsible Body: (e.g. Committee, Sub-Committee, Working Group, Correspondence
Group, Member State)
Maritime Safety Committee
1. Was the human element considered during the
development or amendment process related to this ☐Yes ☐No ☒NA
subject?
2. Has input from seafarers or their proxies been solicited? ☐Yes ☐No ☒NA
3. Are the solutions proposed for the subject in agreement
with existing instruments? (Identify instruments ☐Yes ☐No ☒NA
considered in comments section)
4. Have human element solutions been made as an
☐Yes ☐No ☒NA
alternative and/or in conjunction with technical solutions?
5. Has human element guidance on the application and/or
implementation of the proposed solution been provided
for the following:
• Administrations? ☐Yes ☐No ☒NA
• Shipowners/managers? ☐Yes ☐No ☒NA
• Seafarers? ☐Yes ☐No ☒NA
• Surveyors? ☐Yes ☐No ☒NA
6. At some point, before final adoption, has the solution
been reviewed or considered by a relevant IMO body with ☐Yes ☐No ☒NA
the relevant human element expertise?
7. Does the solution address safeguards to avoid single
☐Yes ☐No ☒NA
person errors?
8. Does the solution address safeguards to avoid
☐Yes ☐No ☒NA
organizational errors?
9. If the proposal is to be directed at seafarers, is
the information in a form that can be presented to ☐Yes ☐No ☒NA
and is easily understood by the seafarer?
10. Have human element experts been consulted in
☐Yes ☐No ☒NA
developing the solution?
11. HUMAN ELEMENT: Has the proposal been assessed against each of the factors
below?
 CREWING. The number of qualified personnel required and
available to safely operate, maintain, support and provide ☐Yes ☐No ☒NA
training for the system.

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 PERSONNEL. The necessary knowledge, skills, abilities

and experience levels that are needed to properly perform ☐Yes ☐No ☒NA
job tasks.
 TRAINING. The process and tools by which personnel
acquire or improve the necessary knowledge, skills and ☐Yes ☐No ☒NA
abilities to achieve desired job/task performance.
 OCCUPATIONAL HEALTH AND SAFETY. The management
systems, programmes, procedures, policies, training, ☐Yes ☐No ☒NA
documentation, equipment, etc. to properly manage risks.
 WORKING ENVIRONMENT. Conditions that are
necessary to sustain the safety, health, and comfort of
those working on board, such as noise, vibration, lighting, ☐Yes ☐No ☒NA
climate, and other factors that affect crew endurance,
fatigue, alertness and morale.
 HUMAN SURVIVABILITY. System features that reduce
the risk of illness, injury, or death in a catastrophic event
such as fire, explosion, spill, collision, flooding or intentional
attack. The assessment should consider desired human
☐Yes ☐No ☒NA
performance in emergency situations for detection,
response, evacuation, survival and rescue and the interface
with emergency procedures, systems, facilities and
equipment.
 HUMAN FACTORS ENGINEERING. Human-system
interface to be consistent with the physical, cognitive, and ☐Yes ☐No ☒NA
sensory abilities of the user population.
Comments:

(1) Justification if answers are NO or Not Applicable.

As indicated in paragraph 25, the proposal is to develop a road map to address MASS
operations in the IMO instrument, there would be no implications for the human element
arising from this output in itself.

However, it is noted that the work items set by the road map may involve the development of
mandatory instrument or interim guidelines, as well as the consideration of common gaps
and themes such as the role of master and remote operator as seafarers, which will inevitably
touch upon issues including human-machine interface, training and qualification of personnel,
etc. The human element will be fully considered during that process.

___________

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