Day 2 – How the International Maritime Organisation’s amendment cycle continuously updates the IMDG Code

The IMO brings together 176 member states, 66 intergovernmental organisations and 89 non-governmental organisations, addressing 50 conventions and protocols. These include but are not limited to the International Convention for the Safety of Life at Sea[1] (SOLAS), The International Convention for the Prevention of Pollution from Ships (MARPOL), the International Maritime Solid Bulk Cargoes (IMSBC) Code and the International Maritime Dangerous Goods (IMDG) Code.

IMDG and IMSBC are continually being updated and IMO has a standing programme alternating priority; one year for IMDG and the next for IMSBC. The work is governed through the rules of the IMO and the work of its Maritime Safety Committee and IMO Council.

There are several sub-committees addressing different safety and environmental matters with some overlapping work. But for IMDG the lead is Carriage of Cargo and Containers (CCC).

A meeting of CCC will typically field over 100 papers of varying length and topic. On top of those, delegates will encounter many additional working papers.

Documents containing more than 6 pages of text are considered ‘bulky documents’ and have to be submitted at least 13 weeks before the start of the meeting. Non-bulky documents have to be received no later than 9 weeks before the meeting.

The leadership work takes place in the main plenary hall, an impressive space capable of seating around 740 delegates. It also has overhead booths for translators providing real time Arabic, Chinese, English, French, Russian and Spanish translation.

The detailed work is undertaken by groups of experts and representatives in committee rooms under volunteer chairs ably supported by the IMO secretariat. This is often where the detail is wrung out, reviewed explored and negotiated. Typically for a Monday to Friday meeting, conclusions, drafts and recommendations have to be delivered by the close of Wednesday so that translation can be done on Thursday in time for action in the main plenary hall on Friday.

If we take a new idea for an IMDG Code amendment, perhaps introduced and passed forward at CCC 8 in September 2022, the next likely step was the Editorial and Technical meeting where experts work on drafting. However 2022 was an IMSBC priority year, so it might well have been March 2023 (E&T 38) when it was first addressed.

At fast pace, the amendment might have then gone to MSC 107 in May 2023 to be approved for inclusion in the next scheduled iteration of the Code. Perhaps more likely it would have gone back to CCC 9 in September 2023 for further consideration and possibly more work at E&T 39 in October 2023. In the case of the new IMDG Code Amendment 42-24 anything that you see new had to be approved by MSC 108 in May 2024 (for those who are wondering 42-24 is the 42nd amendment, approved in 2024). Anything that had not been landed and still under consideration at that time cycled through for potential future amendment in 2027 and beyond. Tomorrow we will look at what is new in Amendment 42-24 of the IMDG Code. For more information and ongoing updates on our work, visit www.ichca.com

[1] “The SOLAS Convention in its successive forms is generally regarded as the most important of all international treaties concerning the safety of merchant ships. The first version was adopted in 1914, in response to the Titanic disaster, the second in 1929, the third in 1948, and the fourth in 1960. The 1974 version includes the tacit acceptance procedure – which provides that an amendment shall enter into force on a specified date unless, before that date, objections to the amendment are received from an agreed number of Parties. As a result the 1974 Convention has been updated and amended on numerous occasions. The Convention in force today is sometimes referred to as SOLAS, 1974, as amended.” Text ©IMO.