E

SUB-COMMITTEE ON IMPLEMENTATION III 8/12/3

OF IMO INSTRUMENTS 3 June 2022
8th session Original: ENGLISH
Agenda item 12 Pre-session public release: ☒

DEVELOPMENT OF GUIDANCE ON ASSESSMENTS AND APPLICATIONS OF REMOTE

SURVEYS, ISM CODE AUDITS AND ISPS CODE VERIFICATIONS

Comments on document III 8/12/1

Submitted by Türkiye

SUMMARY

Executive summary: This document provides comments on document III 8/12/1, in

particular with regard to the content of the draft guidance.

Strategic direction, 1
if applicable:

Output: 1.18

Action to be taken: Paragraph 5

Related documents: III 8/12/1; MSC 102/22/11, MSC 102/24; MSC 104/15/3,
MSC 104/15/6, MSC 104/15/12, MSC 104/15/24, MSC 104/18;
SDC 7/10, SDC 7/16; Circular Letters Nos.4204/Add.6, Add.16,
Add.19/rev.3; and resolutions A.1118(30) and A.1156(32)

Background

1 This document is submitted in accordance with the provisions of paragraph 6.12.5 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)
and comments on document III 8/12/1 (Austria et al.).

Comments

2 Türkiye thanks Austria and the co-sponsors for document III 8/12/1 and supports the
proposed amendments to related resolutions and suggested principles for the Guidance on
assessments and applications of remote surveys, ISM Code audits and ISPS Code
verifications.

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3 Türkiye is of the view that not only extraordinary circumstances such as the COVID-19
pandemic but also the acceleration of digitalization in the shipping industry urge
Administrations to establish a legal framework to accommodate the remote survey/audit
approach due to lack of harmonization of conditions, scope, procedures and implementation.
Having said that, the standards of safety level and confidence provided by remote survey/audit
should not result in any lack for the level of the current standard.

4 Türkiye supports suggestions and concerns provided in document III 8/12/1 in general
and additionally would like to express its views as follows:

.1 ISM company audits should be conducted remotely regardless of the

difference between normal and extraordinary circumstances, if demanded;

.2 ISPS verifications should be conducted remotely regardless of the difference

between normal and extraordinary circumstances, if demanded;

.3 minimum technical requirements of communication (video, audio and internet

stability requirements) for the use of remote survey/audit/verification should
be prescribed, taking into account whether the survey or audit is performed
as real time or non-real time; and

.4 with regard to the records and evidence of the survey/audit, such information
should be time and date stamped.

Action requested of the Sub-Committee

5 The Sub-Committee is invited to consider the comments in this document and take
action, as appropriate.

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