Isle of Man: advisory notice on Industrial Personnel Code

The Isle of Man Ship Registry has issued a technical advisory notice regarding the Industrial Personnel Code.

This TAN was issued on 26 May 2023.

Starting from July 1, 2024, the Industrial Personnel Code and SOLAS Chapter XV will come into effect. These instruments apply to cargo ships and high-speed cargo craft that meet specific criteria: they must exceed 500 gross tons (gt), be engaged in international voyages, and carry more than 12 industrial personnel. Compliance with the code is required during the vessel's first intermediate or renewal survey following the enforcement date.

Industrial personnel, as defined in these instruments, refer to individuals transported or accommodated on board for the purpose of conducting offshore industrial activities on other ships or offshore facilities. Although industrial personnel are considered separately from passengers or special personnel, the code treats them as a combined group when determining its applicability. For example, if a cargo ship carries 12 special personnel and at least 1 industrial personnel, it would need to comply with the code.

It's important to note that the code does not apply to ships that do not transport any industrial personnel.

Grandfathering

The current standards for carrying more than 12 industrial personnel on vessels engaged in international voyages are outlined in MSC.418(97), known as the "Interim recommendations on the safe carriage of more than 12 industrial personnel on board vessels engaged on international voyages."

For cargo ships constructed before the implementation of the IP Code, holding an authorization under MSC.418(97) prior to the IP Code's enforcement, a reduced version of the Code is applicable. This reduced version includes only regulations III/1, III/2 (except for paragraph 2.1.7), IV/7, and IV/8.

Cargo ships constructed after the IP Code's enforcement or those constructed before but without authorization under MSC.418(97) must comply with the full version of the Code.

If Isle of Man-registered ships carry industrial personnel or are likely to do so in the near future, it is recommended to consider obtaining evidence of compliance with MSC.418(97) before the Code's enforcement date.

Paragraph 6 of MSC.418(97) addresses the vessel standards eligible for authorization. Currently, 2008 SPS Code ships can be authorized (provided they meet the remaining conditions of MSC.418(97)). Vessels complying with other standards will be assessed on a case-by-case basis by the Ship Registry.

Form of Evidence of Compliance with MSC.418(97)

To benefit from the grandfathered version of the code, it will be necessary to obtain documentary evidence of compliance with MSC.418(97). While most Recognized Organizations (ROs) currently do not issue such documentary evidence, some may be in the process of developing a Statement of Compliance for the Carriage of Industrial Personnel or a similar document.

For ROs without a Statement of Compliance, the Isle of Man Ship Registry has created a template Statement of Compliance (Form Ref S085), which can be accessed in this TAN. It's important to note that either option (RO's own document or the Isle of Man Ship Registry's template) can be used by Isle of Man ships. However, the Statement of Compliance should always be issued by the RO and not the Ship Registry to avoid any confusion.

Authorisation for ROs

This TAN serves as authorization for Isle of Man ROs (as mentioned in MSN 020) to:

Conduct necessary surveys and issue the Industrial Personnel Safety Certificate and Record of Equipment.
Conduct the required survey and issue the Statement of Compliance for MSC.418(97) mentioned above.

Please note that a survey is expected to be carried out before issuance of a statement of compliance.