Flag State Performance

In 2016, following the entry into force of amendments to the relevant IMO Conventions, the IMO Member State Audit Scheme became mandatory. This is a significant development that should not go unnoticed, making a further contribution to improving maritime safety and the prevention of pollution. 

A balance has to be struck between the commercial advantages of shipowners selecting a particular flag and the need to discourage the use of any ship register that does not meet its international obligations. While it is shipping companies that have primary responsibility for the safe operation of their ships, it is flag states that must implement and enforce the rules. 

ICS is therefore a strong supporter of the IMO Member State Audit Scheme and greatly welcomes the evolution of the current voluntary audits of maritime administrations into a mandatory programme (although it will still be several years before all the world’s maritime administrations have passed through the IMO audits). 

In the interests of transparency, and notwithstanding sensitivities about matters of sovereignty, ICS believes that the results of all IMO audits should eventually be published. In the meantime, ICS has welcomed the development of a new module within the IMO Global Integrated Shipping Information System (GISIS) through which governments have the option to make their reports available to the public. ICS also welcomes the practice of some regional Port State Control (PSC) authorities to request information from flag states as to whether the voluntary IMO audits have been conducted, including this in their criteria for targeting inspections. 

In February 2017, and as a complement to the IMO Scheme, ICS published its latest Shipping Industry Flag State Performance Table, which can be downloaded free of charge here. The Table assesses the performance of flag states using criteria such as Port State Control records, the ratification of IMO and ILO Conventions, and participation at IMO meetings. It is intended as a tool to help ship operators engage in discussion with their flag administrations about areas of performance where improvement might still be necessary. 

This year’s ICS Table continues to highlight the sound performance of all of the world’s major flag administrations, regardless of whether they are open registers or so called ‘traditional’ maritime flags. But in response to feedback from IMO Member States, ICS has made some further refinements in order to make the Table as objective and useful as possible. This includes the way in which the delegation to conduct surveys to responsible Recognized Organizations is now recorded. 

In addition, flag states which do not qualify for the United States ‘Qualship 21’ programme have not been given negative performance indicators in the latest ICS Table. The list of flag states qualifying for Qualship 21 now varies considerably from year to year and non-inclusion is therefore no longer viewed as being a sound indicator of negative performance. However, flag states that continue to qualify for the U.S. programme are still given a positive performance indicator.


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