3 Procedural Aspects Related to the Drafting of 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 - 3Procedural Aspects Related to the Drafting of Amendments

3 Procedural Aspects Related to the Drafting of Amendments

  3.1 Timing of entry into force of amendments

 The Maritime Safety Committee, at its ninety-third session, approved MSC.1/Circ.1481 on Guidance on entry into force of amendments to the 1974 SOLAS Convention and related mandatory instruments , which reinstated the four-year cycle of entry into force of amendments to the Convention and related mandatory instruments. In this respect, due attention should be paid to the timeline agreed for the entry into force of amendments when developing amendments to the Convention and related mandatory instruments.

  3.2 Amendment control process

  3.2.1 Process for amending the Convention and related mandatory instruments (from proposal to adoption)

  3.2.1.1 At a proposal stage and in addition to the information to be provided in proposals for planned and unplanned outputs (see annex 1 to the Committee's Guidelines), where possible, the following elements should be addressed when considering proposals for a new work programme items (planned/unplanned output) that may require the preparation of amendments to the Convention and/or related mandatory instruments:

  • .1 ship type(s) to which the proposed amendment(s) is/are expected to apply (e.g. scope, size, type, tonnage/length restriction; service areas (international/non-international); activities (e.g. supporting diving activities));

  • .2 the extent of application to existing ships,footnote along with any relevant safety measures that may be applied to existing ships;

  • .3 the intended instrument(s) that should be amended (the Convention, associated mandatory instruments, etc.); and

  • .4 the use of the check/monitoring sheet (refer to paragraph 3.2.1.3.16 below).

  3.2.1.2 During the consideration of new work programme items and approval of new planned/unplanned outputs, and in addition to the actions to be taken based on the Committee's Guidelines, the Committee should consider the elements listed below and, in this respect, should give clear instructions to the relevant technical subsidiary body/bodies (i.e. sub-committees, including its working/drafting/intersessional groups, as well as those reporting directly to the Committee), as may be applicable:

  • .1 target completion date at the sub-committee level;

  • .2 expected date(s) of entry-into-force and implementation/application date(s) (e.g. possible phase-in arrangement) of the amendment(s) or of the new requirement(s) to be developed;

  • .3 whether the proposal should be considered an exceptional circumstance, as specified in MSC.1/Circ.1481; and

  • .4 scope of application of the proposed amendment(s) or new requirement(s), along with the instrument(s) which would be required to be amended/developed. In this regard, the following should be taken into consideration:

    • .1 if a comprehensive revision to an instrument is required, a decision should be taken whether to revise the existing instrument or create a new version, which may co-exist with the existing instrument (e.g. 1994 and 2000 HSC Code); and

    • .2 if the instrument to be amended has different versions, a decision should be made whether older versions of the instrument should also be revised, especially when considering amendments to operational requirements which are likely to result in the revision to all versions of the instrument.

  3.2.1.3 At a subsequent processing stage, but before the conclusion of the approval for adoption, each allocated sub-committee should ensure that:

  • .1 at an initial engagement, sufficient time is allocated for technical research and discussion before the target completion date, especially, when the issue is needed to be addressed by more than one sub-committee where timing of meetings of relevant sub-committees and exchanges of the result of considerations need to be carefully examined;

  • .2 the intended scope of application agreed by the Committee (refer to paragraph 3.2.1.2 above) is not changed without approval of the Committee, providing clear justification for such change (e.g. in case of unintended omissions);

  • .3 the technical base document or draft amendment addresses the proposal's issue(s) through the suggested instrument(s) and, if not, an alternative method is offered to the Committee for addressing the problem raised by the proposal;

  • .4 if application to existing ships is agreed by the Committee under 3.2.1.1.2 above, due attention is paid to MSC/Circ.765-MEPC/Circ.315 on Interim guidelines for the systematic application of the grandfather clauses;

  • .5 all references have been examined against the text that would be valid if the proposed amendment enters into force (refer to section 4.2.4 below);

  • .6 the location of the inserted or modified text is correct with regard to the text that would be valid when the proposed amendment enters into force on a four-year cycle of entry-into-force date, as there may be other relevant amendments adopted that might enter into force on the same date;

  • .7 there are no inconsistencies in the scope of application between the technical regulation and the application statement of the relevant chapter that may be given in regulation 1 or 2, and application is specifically addressed for existing and/or new ships, as necessary;

  • .8 if a new term is introduced in a regulation and a clear definition is necessary, the definition is given in the relevant article of the Convention or at the beginning of the chapter, as appropriate;

  • .9 when any of the terms "fitted", "provided", "installed" or "installation" are used, a clear understanding of the intended meaning of the term is provided;

  • .10 all necessary related and consequential amendments to other existing instruments, including non-mandatory instruments, in particular, the forms of certificates and records of equipment required in the instrument being amended, have been examined and included as a part of the amendment(s);

  • .11 the forms of certificates and records of equipment are harmonized, where appropriate, between the Convention and its Protocols;footnote

  • .12 attention is paid with regard to the possible application's criteria using building contract date, keel laying date or delivery date, as and where appropriate, and to the possible impact of that decision (refer to section 4.2.1). In making such a decision, the following should be taken into consideration:

    • .1 in principle, the three-date system can be used for a chapter governing design/construction of a ship, while the keel laying date can be used for a chapter governing ship's equipment;

    • .2 the period to be established between events in the three date system versus the actual timing needed in the shipbuilding process;

    • .3 the period needed between adoption and entry into force versus the time for design, manufacture and approval of new equipment;

    • .4 that a single keel laying date implementation criteria could require a series of ships under the same building contract to apply different requirements (pre- and post- entry into force) which may cause significant changes to the design; and

    • .5 with respect to application to existing ships, the need to carefully word the three-date criteria implementation scheme (e.g. application of certain "measures" of the Noise Code) versus the more straight forward application of a single keel laying criteria;

  • .13 draft amendments are presented for consideration, as far as practically possible, as tracked changes within the context of the relevant provisions to be amended (refer to section 3.2.3 below);

  • .14 due attention is paid to the "application" and "definition" regulations of the chapter where these are likely to affect or be affected by the proposed amendments;

  • .15 when preparing amendments to mandatory instruments, the relationship between the Convention and the instrument is observed (refer to section 4.1.5);

  • .16 the check/monitoring sheet given in annex 2 is observed and completed throughout the progress at each one of the above stages. In this respect, it is intended that:

    • .1 parts I and II should be completed by the submitter of a new work programme (planned/unplanned output), as far as possible, as an annex to the submission document (refer to paragraph 3.2.1.1.4 above); and

    • .2 part III should be completed by the drafting or working group that prepares the draft amendment(s);

  • .17 the final draft text of proposed amendments to the Convention or any related mandatory instrument is reviewed by either a drafting group or by a working group to properly address the issues listed in part III of the check/monitoring sheet, as given in paragraph 3.2.2.2 below;

  • .18 the check/monitoring sheet is presented along with the draft amendments submitted for approval; and

  • .19 the record format given in annex 3 is completedfootnote by the drafting or working group that prepares the draft amendment(s).

  3.2.1.4 At the approval and adoption stages:

  • .1 the Committee should:

    • .1 carefully review the draft amendments submitted for approval, using the associated check/monitoring sheet prepared by the subsidiary body. In doing so, issues requiring further drafting consideration may be identified. Under those circumstances, the Committee may consider instructing the drafting group on amendments to review the draft amendments and the associated check/monitoring sheet before approval of the related amendments, taking into account the information contained in the related record format; and

    • .2 agree on which session of the Committee the amendments should be adopted as well as the dates on which the amendments would be accepted and would enter into force, taking into account the four-year cycle or the exceptional circumstance as per MSC.1/Circ.1481, as may be the case; and

  • .2 the Secretariat should:

    • .1 ensure that the draft amendments submitted for approval, as well as those contained in the annexes of the Committee's report after approval, are presented in tracked changes, as appropriate (refer to section 3.2.3 below);

    • .2 prepare the appropriate text of draft amendments without tracked changes for circulation to all Members of the Organization and all SOLAS Contracting Governments after approval, in accordance with the provisions of article VIII of the Convention;

    • .3 prepare documents containing the text of the approved draft amendments without tracked changes, together with the draft resolution(s), for submission to the session of the Committee that will consider the amendments for adoption;

    • .4 prepare a working paper consolidating all draft amendments submitted for adoption with tracked changes, including proposals for modifications or editorial improvements, if any, as well as notes and comments, as appropriate (refer to section 3.2.3 below). This document should be made available in IMODOCS as soon as possible after the deadline for commenting documents and should be used as the base document for the preliminary consideration by the expanded Committee and final revision by the drafting group on amendments;

    • .5 ensure that, after adoption, the final text of the amendments which are contained in the annexes of the Committee's report (i.e. the MSC resolutions) is presented without tracked changes;

    • .6 prepare authentic text of the adopted amendments after adoption, when requested, and make them available on IMODOCS; and

    • .7 keep the related record format updated in respect to relevant decisions taken at the sub-committee or committee level.

  3.2.2 Drafting group arrangements

  3.2.2.1 Drafting groups have a relevant role in the amendment control process. Although drafting groups cannot change the essence of the amendments, they should ensure that the drafting of amendments is carried out in accordance with the present guidance. Therefore, this guidance should be included as a standing reference in the terms of reference of these groups, along with references for completion of the check/monitoring sheet and record format, set out in annexes 2 and 3, respectively.

  3.2.2.2 The first stage of the engagement in the control process of drafting works should be undertaken by a drafting group or by a working group of the subsidiary body or by those reporting directly to the Committee. In doing so, the check/monitoring sheet set out in annex 2 should be observed and completed before submitting the draft amendments for approval.

  3.2.2.3 At the approval stage of amendments, the Committee should carefully review the draft amendments submitted for approval, along with the related check/monitoring sheet (refer to paragraph 3.2.1.4.1.1).

  3.2.2.4 Depending upon the findings in the check/monitoring sheet, the Committee may consider tasking the drafting group established for reviewing the amendments submitted for adoption (refer to paragraph 3.2.2.6 below) to review the draft amendments submitted for approval and the related check/monitoring sheet, including the information contained in the related record format.

  3.2.2.5 After the approval of draft amendments by the Committee, the Secretariat should review the approved draft amendments from the drafting and editorial point of view. Any findings by the Secretariat should be submitted to the session of the Committee that would adopt the amendments as part of the working paper consolidating the amendments, comments and proposals for modifications, which would be prepared in advance by the Secretariat (see paragraph 3.2.1.4.2.3).

  3.2.2.6 At the adoption stage, the above-mentioned working paper should be used as the basis document for consideration of the draft amendments by the expanded Committee and by the drafting group that would conduct the final review of the draft amendments, along with any comments provided in any of the documents submitted to that session for consideration.

  3.2.3 Use of tracked changes

  3.2.3.1 The use of tracked changes during the preparation, approval and adoption of draft amendments may facilitate the consideration of proposed amendments. It may also assist the work of translators and reduce the number of misinterpretations.

  3.2.3.2 Tracked changes should mainly be used, as far as practically possible, for draft amendments amending the text of existing regulations, paragraphs or tables, in order to easily identify the changes proposed with respect to the original text. In this respect, only the relevant part(s) of the original text should be reproduced.

  3.2.3.3 For insertions of new regulations, paragraphs or tables, or deletion of existing ones, the use of tracked changes may not be required.

  3.2.3.4 Tracked changes should be created using "strikeout" for deleted text and "grey shading" to highlight all modifications and new insertions, including deleted text (i.e. not using the track changes function of Microsoft Word), in order to ensure that such changes are not lost during further editorial work (e.g. cut and paste).

  3.2.3.5 Tracked changes should be made against the text that has already entered into force. However, subject to section 3.3.1 below, if the draft amendments under development are expected to be adopted after the entry-into-force date of other related amendments, then the adopted amendments should be included using a different colour and including a note indicating the number of the resolution by which the amendments were adopted. The note should be used as a drafting tool only and should not be considered as part of the related draft amendments.

  3.3 Points for attention in preparing an amendment

  3.3.1 An amendment to a pending amendment

  3.3.1.1 A further amendment to an already adopted amendment which is still pending entry into force may be approved by the Committee but should not be adopted until the previous adopted amendment enters into force.

  3.3.1.2 Other elements of the same regulation which are not related to a previous adopted amendment which is still pending entry into force may be amended accordingly, in accordance with the procedures for amending the Convention.

  3.3.2 Work of other bodies of the Organization

  3.3.2.1 In drafting an amendment, due attention should be paid to any possible related amendments being prepared by other bodies of the Organization based upon the information provided by the Secretariat or as may be advised.


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