4 Guidance for Drafting Amendments
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Statutory Documents - IMO Publications and Documents - Circulars - Maritime Safety Committee - MSC.1/Circular.1500 – Guidance on Drafting of Amendments to the 1974 SOLAS Convention and Related Mandatory Instruments – (5 January 2015) - Annex – Guidance on Drafting of Amendments to the 1974 SOLAS Convention and Related Mandatory Instruments - 4Guidance for Drafting Amendments

4 Guidance for Drafting Amendments

  4.1 Principles

  4.1.1 A comprehensive revision of a chapter

  4.1.1.1 A comprehensive revision is a revision of a chapter which fundamentally alters the structure of the chapter and resets its application date.

  4.1.1.2 A comprehensive revision should take place only if the entire philosophy or basis of the chapter is restructured (e.g. from ship's type-based requirements to functional based requirements, or based on a new concept).

  4.1.1.3 As far as possible, comprehensive revisions should be avoided since they can make historical tracking of regulations difficult.

  4.1.1.4 When a chapter of the Convention is comprehensively revised, the following principles should be followed:

  • .1 Application date of the chapter: The application date of the chapter should be reset. The application date (e.g. date 1 in annex 1) in the statement of regulation 1.1.1 "Unless expressly provided otherwise, this chapter shall apply to ships constructed on or after (date 1)" should be kept until the next comprehensive revision of the chapter. This date should be aligned with one of the four-year cycle dates;

  • .2 List of resolutions: A list of resolutions that apply to ships constructed prior to the comprehensive revision (e.g. regulation 1.2 in annex 1) should be included in the text of the chapter; and

  • .3 Additional requirements contained in the chapter that apply to ships constructed before the application date of the chapter: When a comprehensive revision is carried out, some of the requirements applicable to ships constructed on or after the application date of the chapter may also be applicable to ships constructed before that date. These regulations should be recorded in the list of regulations applicable to existing ships (see regulation 1.4 in annex 1).

  4.1.2 Amendments adopted between comprehensive revisions or after the approval of the present Guidance

  4.1.2.1 For amendments adopted between comprehensive revisions or after the approval of the present guidance, the following principles should be observed:

  • .1 the application date of a new amendment should be clearly stated under each specific new or amended regulation, in the format given in paragraph 4.2.1 below;

  • .2 if an amendment revises a regulation, or part of a regulation, the original part of the regulation which would continue being applicable to ships constructed on or after the original application date of the revised regulation should be retained with a clear statement of its application dates (i.e. from and to);

  • .3 regardless of the dates included in the amended regulation(s), the chapter's application should include a list of amended regulations that contain provisions that apply to ships constructed on or after the general application date of the chapter (e.g. regulation 1.3 in annex 1); and

  • .4 if the new or amended regulation is also applicable to ships constructed before the general application date of the chapter, then that regulation should also be added to the list referred to in paragraph 4.1.1.4.3 (e.g. regulation 1.4 in annex 1).

  4.1.3 Amendments adopted at a subsequent comprehensive revision

  4.1.3.1 In the event of a second or a subsequent comprehensive revision to a chapter, the following principles should also be observed:

  • .1 the application date of the chapter given in paragraph 4.1.1.4.1 above should be reset;

  • .2 the list of resolutions referred to in paragraph 4.1.1.4.2 should be updated by adding any further resolutions relevant to the chapter adopted after the previous comprehensive revision; and

  • .3 application dates introduced in the regulations that entered into force between the comprehensive revisions should be removed, and the list indicated in paragraph 4.1.2.1.3 should also be reset. Moreover, the list indicated in paragraph 4.1.1.4.3 should be reset and completed with requirements contained in the revised chapter that apply to ships constructed before the subsequent revision date, if any.

  4.1.4 Referencing other instruments

  4.1.4.1 When referencing other mandatory/non-mandatory instruments in a mandatory instrument, the Guidelines on methods for making reference to IMO and other instruments in IMO conventions and other mandatory instruments, as set out in the annex to resolution A.911(22) on Uniform wording for referencing IMO documents, should be applied.

  4.1.4.2 The above guidelines provide standard text for references for inclusion in new IMO conventions and other mandatory instruments relating to maritime safety and pollution prevention and in future amendments to existing conventions and other instruments, in order to ensure that, where reference is made to IMO Conventions and other instruments, a uniform wording is used. This is to indicate clearly the legal status of the instrument in question after the IMO body concerned has decided on the status. Therefore, references to standards which are intended to be mandatory should not be included as a footnote. They should instead be included explicitly in the text of relevant regulations or amendments.

  4.1.5 Relationships between the Convention and related mandatory instruments

  General principles

  4.1.5.1 The relationship between the Convention and a mandatory instrument should be clearly identified in both the Convention and the mandatory instrument.

  4.1.5.2 Instruments are made mandatory through reference in the text of the SOLAS regulations. Thus, the application of the mandatory instrument cannot exceed the relevant SOLAS regulation.

  4.1.5.3 In drafting new instruments or amendments, care should be taken to ensure consistency between the Convention and the related mandatory instrument.

  4.1.5.4 If a decision is taken to develop a new version of an instrument with co-existing sets of requirements (refer to paragraph 3.2.1.2.4), applicability should be clearly defined within the Convention, especially regarding the scope and dates of application/implementation.

  4.1.5.5 If different parts of an instrument have different characteristics, mandatory and recommendatory, the different relationships to the Convention should be indicated in the Convention.

  Instruments providing an alternative or additional set of requirements to the Convention for particular ship types or providing supplementary requirements for specific circumstances

  4.1.5.6 For instruments providing an alternative set of requirements to the Convention for particular ship types, such as the IGC, IBC and HSC Codes, or providing supplementary requirements for specific circumstances, the following should be taken into consideration:

  • .1 the scope of application should be detailed in the instrument using the principles laid down in paragraphs 4.1.1 to 4.1.3 and 4.2.1, accordingly; and

  • .2 the relationship between the Convention and the instrument should be clearly identified in the applicable chapter of the Convention, in the definition of the instrument concerned and in any specific regulation addressing the application of the instrument.

  Instruments governing operational and survey/audit elements

  4.1.5.7 With regard to instruments governing operational and survey/audit elements, such as the ISM, the ESP or the RO codes, a clear definition of the instrument and its status, whether mandatory or recommendatory, as well as the scope of application, should be provided in the Convention. Any subsequent amendment to the instrument is understood to have the same application as the original, unless otherwise specified. Nevertheless, attention should be paid to:

  • .1 whether, either the instrument or the Convention should further clarify ship types that are subject to the proposed requirements; and

  • .2 application statements that may be indicated in the resolution adopting the amendments to clarify application criteria, for example, the first survey/audit after the given date or actual date of the activity.

  Other instruments

  4.1.5.8 In instruments other than those specified in paragraphs 4.1.5.6 and 4.1.5.7, the application principle should be clearly stated at the beginning of the instrument. In these cases, attention should be paid to:

  • .1 whether to set up a principle for application criteria of any amendment, not specifically indicating the application date of each amendment (e.g. the FSS Code, section 1.1.2) or;

  • .2 if not, whether the application provision of the amendment should be clearly stated and/or a chronological record of the amendments be maintained for each section; and

  • .3 where specific equipment is identified as necessary, the carriage of such equipment can only be required by inclusion in the Convention.

  4.1.6 Relaxation/dispensation

  4.1.6.1 General relaxation/dispensation clauses should be given at the beginning of the chapter.

  4.1.6.2 Specific relaxation/dispensation clauses applicable to specific requirements should be given under the technical regulations.

  4.2 Specific details

  4.2.1 Format of application dates

  4.2.1.1 Format of application dates should be defined, as applicable, using the criteria based on "three dates"footnote or the "keel laying date based on a single date".

  4.2.1.2 At a comprehensive revision, a decision should be made so as whether to use the criteria based on three dates or the keel laying date based on a single date. Depending on that decision, one of the following definitions of the chapter's application for "ship constructed" should be inserted in the regulation corresponding to the "application" or "definition" part of the chapter:

  • .1 In case the three dates criteria is used, the following should be the definition inserted:

    • "The expression ship constructed on or after DDMMYYYY means:

    • .1 for which the building contract is placed on or after (date 1); or

    • .2 in the absence of a building contract, the keel of which is laid or which is at a similar stage of construction on or after (date 2); or

    • .3 the delivery of which is on or after (date 3)"

    • Note: As guidance, date 2 is 6 months after date 1, and date 3 is 48 months after date 1.

  • .2 In case the single ship's construction/keel laying date criteria is used, the following should be the definition inserted:

    • "The expression ship constructed on or after DDMMYYYY means:

    • .1 the keel of which is laid or which is at a similar stage of construction on or after DDMMYYYY;

    • .2 Similar stage of construction means the stage at which:

      • .1 construction identifiable with a specific ship begins; and

      • .2 assembly of that ship has commenced comprising at least 50 tonnes or 1% of the estimated mass of all structural material, whichever is less."

  4.2.1.3 Subsequent amendments between comprehensive revisions should also address the options given in paragraph 4.2.1.2 above.

  4.2.2 All ships

  4.2.2.1 When used, a clear definition of the term "all ships" for the purpose of the chapter should be given in the "application" or "definition" part of the chapter.

  4.2.3 Conversion

  4.2.3.1 A clear definition of "conversion" and "alteration or modification of major character" for the purpose of application provisions of the chapter or a specific regulation should be given.

  4.2.4 Consequential amendments to the Convention and/or other instruments

  4.2.4.1 An amendment to the Convention occasionally introduces a change to the regulation number or paragraph number. As far as possible, this practice should be avoided because the number might be referred to in the Convention itself or in other instruments. MSC 71, when discussing the situation regarding cross-reference of regulations in and between IMO instruments, agreed to (MSC 71/23, paragraph 16.10):

  • .1 request the sub-committees, in the course of preparation of amendments to IMO instruments, to also check the references in the provisions of the instruments concerned which may not be within their purview; and

  • .2 invite Member Governments to inform the Secretariat, at an early stage, of any modifications to cross-references they would identify when introducing new amendments in their legislation, in order that necessary rectification could be made by the Secretariat.

  4.2.5 Other best practices for the drafting of amendments

  4.2.5.1 In addition to principles specified in section 4.1, the following best practices should be taken into account during the preparation and drafting of amendments to the Convention:

  • .1 General format of regulations:

    • .1 Titles of regulations: for consistency, all regulations should have a title;

    • .2 Subtitles within regulations should be numbered accordingly; and

    • .3 Numbering of paragraphs and tables within a regulation: unless the regulation contains only one paragraph or table, all paragraphs and tables should be numbered accordingly within the regulation. For tables, the format "X.x" should be used, where "X" represents the number of the regulation and "x" is a correlative number within the regulation.

  • .2 New regulations: Whenever possible, new regulations should be inserted at the end of the corresponding chapter. However, due to the nature of the regulation and/or the structure of the chapter, new regulations may be inserted sometimes between existing regulations. In these cases and in order to avoid renumbering existing regulations, the new regulation should be inserted using an existing regulation number by adding "-1" after the number. For further insertions, correlative numbers should be used.

  • .3 Deletion of regulations: To avoid renumbering existing regulations, the number of deleted regulations should be kept. A footnote could be added indicating that the regulation was intentionally deleted and left blank.

  • .4 Amending or replacing existing regulations, paragraphs or tables: Given the diversity of situations that could be presented under the current structure of the Convention, special attention should be paid to the definition of the scope of application of new amendments, as appropriate. Under these circumstances, the scope of application of new amendments should be specified as follows:

    • .1 within the amended text of the existing regulation; or

    • .2 using a dedicated separate paragraph within the same regulation; or

    • .3 adding a note within parentheses under the title of the regulation.

    • When modifying or replacing contents of existing tables, a note under the table or a dedicated separate paragraph should be used to clarify the application of existing requirements, as appropriate.

    • Duplication of regulations, paragraphs or tables should be avoided as much as possible.

  4.2.6 Format of application date to be used in mandatory instruments

  4.2.6.1 In instruments providing an alternative set of requirements to the Convention for particular ship types or providing supplementary requirements for specific circumstances (refer to paragraph 4.1.5.6), the format of application date should follow section 4.2.1 of this guidance.

  4.2.6.2 In instruments governing operational and survey/audit elements (refer to paragraph 4.1.5.7):

  • .1 where a single date of application is used and not changed, it is not necessary to track the amendments; or

  • .2 where a single date of application is not used or a previous date of application is changed, then the format described in paragraph 4.2.1 should be used.

  4.2.6.3 In other mandatory instruments (refer to paragraph 4.1.5.8), the following format of application dates may be used:

  • .1 when the installation date is used:

    • "X.X Unless expressly provided otherwise, this instrument is applicable to installations installed on board ships on or after DDMMYYYY.

    • X.X The expression installed on board ships on or after DDMMYYYY means:

      • (a) for ships the keel of which is laid or which is at a similar stage of construction on or after DDMMYYYY, installations on board those ships; or

      • (b) for ships other than those specified in (a), installations having a contractual delivery date of the equipment to the ship on or after (DDMMYYYY + x) or, in the absence of a contractual delivery date of the equipment to the ship, the actual delivery of the equipment to the ship on or after (DDMMYYYY + y). "

    • Note: x and y time frames are to be decided dependant on consideration of the equipment to be installed.

  • .2 otherwise, the format given in 4.2.1 should be used.

  4.3 Example of regulation 1

  4.3.1 An example of regulation 1 is given in annex 1.


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