The ICS/ISF Shipping Industry Flag State Performance Table Joe Francombe, Policy Officer International Chamber of Shipping Sixth IMO Workshop for PSC MoU/Agreement Secretaries and Database Managers 3 July 2013

ICS The principal trade association for the shipping industry National shipowners’ associations from 36 countries (all sectors and trades, 80% of world fleet) Representing the industry at international regulatory level – especially IMO, but also ILO, UN, OECD, CSG and EU etc

Scope of presentation The shipping industry’s role (and interest) in promoting flag state performance The ICS Flag State Performance Table

Why is flag State performance important to the industry? Direct implications for a company’s performance: Greater frequency of PSC inspections Impact on corporate reputation Tolerance of sub-standard operators provides unfair commercial advantage, and damages industry’s reputation

Transparency Ships and company procedures are rightly subjected to inspection by governments Flag states should also be subjected to a degree of scrutiny A principle endorsed by IMO – Member State Audit Scheme

The shipowner’s expectations of responsible flag State Shipowners have primary responsibility for safe operations – but flag states must enforce the rules: Infrastructure Ratification of international maritime treaties Implementation and enforcement Supervision of surveyors

Other flag state responsibilities Overseeing the movement of ships between flags Casualty investigations Repatriation of seafarers, where necessary

The ICS/ISF Flag State Performance Table

Criteria Port State Control Ratification of Conventions Recognized Organizations complying with IMO A.739 Average age of fleet Reporting requirements Attendance at IMO meetings

Aims of the Table 1) To encourage shipowners and operators to examine whether a flag state has sufficient substance before using it   2) To encourage shipowners and operators to put pressure on their flag administrations to effect any improvements that might be necessary

Port State Control Port state control records of ships on a flag = a means of assessing the effective enforcement of international rules On Paris MoU and Tokyo MoU ‘White Lists’ Not on Paris MoU and Tokyo MoU ‘Black Lists’ On USCG Qualship 21 Not on USCG Target List (Safety)

Port State Control - issues Concerns relating to flags with few port calls in an MoU region Flags with fewer than 30 inspections in the last 3 years will not appear on any MoU lists Quality flags may receive a negative indicator on the white lists

Port State Control – issues Explanatory text Open to considering PSC data on quality flags with few inspections/port calls, e.g. USCG Qualship 21 Currently considering treatment of PSC in 2013 Table, in liaison with PSC authorities

Ratification of Conventions SOLAS MARPOL (incl. Annexes I – VI) LL Conventon (and 88 Protocol) STCW 78 (incl. 2010 Amendments) ILO 147/MLC CLC/Fund 92

Use of Recognised Organisations IMO Resolution A.739 – Guidelines for the authorization of organizations acting on behalf of the administration No published data on which ROs conducting work on behalf of flag states comply with A.739 > ICS has developed criteria Positive indicator for those flags that recognise no more than 6 non-IACS ROs

Use of Recognised Organisations – rationale Several non-IACS members do meet the standards required by IMO Res A.739 Flag states using several non-IACS ROs are not substandard Large number of non-IACS ROs – may be reason to doubt compliance with IMO standards

Average age of fleet The age of an individual ship is not necessarily an indicator of quality However, high concentration of younger ships = more likely to attract quality tonnage Positive indicator for the 90% of flags with the lowest average age

Compliance with reporting requirements Positive indicator for those flag states that have submitted compliance and practice reports to ILO IMO STCW 95 ‘white list’

Attendance at IMO meetings MSC MEPC LEG Assembly Positive indicator for flag states with 100% attendance record for these meetings over the previous two years

Positive performance indicators

Only factual information from the public domain is used within the Table e.g. Annual Reports from the Paris MoU, Tokyo MoU and USCG IMO chart on the status of conventions IMO GISIS database

Distinction between traditional and open registers unhelpful Top performing flags include Bahamas, Liberia and Marshall Islands A number of OECD nations have a number of negative indicators

Thank you www.ics-shipping.org