1. 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

2. 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

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

4. 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

5. 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

6. 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

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

8. The ICS/ISF Flag State Performance Table

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

10. 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

11. 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)

12. 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

13. 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

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

15. 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

16. 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

17. 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

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

19. 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

20. Positive performance indicators

21. 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

22. 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

23. Thank you www.ics-shipping.org