Open consultation

Annex A - Consultation Document - The Merchant Shipping (Safety Measures for Ships Carrying Industrial Personnel and Special Personnel) Regulations 2025

Published 6 December 2024

Section 1:  Overview of this consultation

Aim

1.1 This consultation seeks your views on a proposed new Statutory Instrument, the Merchant Shipping (Safety Measures for Ships Carrying Industrial Personnel and Special Personnel) Regulations 2025 (“the proposed Regulations”).

1.2 The proposed Regulations will implement new Chapter XV in the International Convention for the Safety of Life at Sea, 1974 (“SOLAS” or “the Convention”) relating to the safe carriage of industrial personnel (“Chapter XV”) into UK law. The proposed Regulations will also implement the safety standards of the International Code of Safety for Ships Carrying Industrial Personnel (“the IP Code”), which is incorporated into the Convention by Chapter XV.  Finally, the proposed Regulations will also make provision for the safe carriage of special personnel.

1.3 Chapter XV applies to cargo ships and high speed cargo craft of 500 gross tonnage or more operating on international voyages, but the proposed Regulations will extend the application of Chapter XV to such ships of below 500 gross tonnage and to ships operating on non-international voyages. Noting the synergies between the IP Code, which Chapter XV makes mandatory, and the Special Purpose Ships Codes of 1983 and 2008 (“SPS Codes”), it is also proposed to make the SPS Codes mandatory. An ambulatory reference provision is also proposed to ensure that future amendments to the IP Code referred to in the proposed Regulations are given direct effect in UK law. Chapter XV is contained in International Maritime Organization (IMO) Resolution MSC.521(106) and is available on the IMO website at this link:

https://www.imo.org/en/KnowledgeCentre/IndexofIMOResolutions/Pages/MSC-2022-23.aspx

Views sought

1.4       Consultees are invited to comment on any aspect of this consultation; however, you are specifically invited to respond to the consultation questions in section 5.1. A more in-depth explanation of the areas for consideration can be found in section 2.

Deadline for responses

1.5       Responses are welcomed from 9 December 2024 to 17 February 2025.

Section 2:  Areas for consideration

Background

2.1   SOLAS Chapter XV – safety measures for ships carrying industrial personnel - contains the requirements governing the carriage of industrial personnel. The need for this new Chapter in SOLAS has arisen due to the expansion of offshore industrial activities in recent years, most notably in the wind farm sector. It has been recognised that the safety standards found in existing IMO instruments do not adequately cover the specific risks associated with maritime operations more widely in the offshore sector, such as the transfer of personnel between the ship and offshore structure.  Accordingly, Chapter XV supplements the core requirements of SOLAS, providing bespoke requirements for the safe carriage of industrial personnel on board cargo ships and high speed cargo craft.

2.2   A fundamental principle of SOLAS is that a cargo ship can carry up to 12 passengers, and a passenger ship is a ship which carries more than 12 passengers. The construction and equipment standards for passenger ships are higher than for cargo ships in recognition of the likelihood that they will be carrying larger numbers of persons on board. Vessels operating in the offshore sector as cargo ships are therefore limited in the number of passengers they can carry. However, where such persons regularly work on board a ship, are certified medically fit and have received relevant safety training, historically the MCA has considered these persons to be special personnel rather than passengers (further information on special personnel is provided below).

2.3   It is recognised that the definitions of “crew” and “passenger” in SOLAS do not adequately address personnel who are neither part of the crew nor are passengers. Such personnel are considered to be “industrial personnel” and the lack of a clear definition of industrial personnel in SOLAS, and the absence of an international standard for the carriage of industrial personnel, has created difficulties in the interpretation of applicable standards for vessels operating in the offshore sector.

2.4  Underpinning SOLAS Chapter XV is the IP Code. The IP Code provides a standard which supplements existing requirements in SOLAS in order to enhance safety, in particular for industrial personnel on vessels operating in the offshore sector, to overcome the difficulties in interpreting the existing standards.  Chapter XV and the IP Code will apply when a ship is carrying an aggregate of more than 12 industrial personnel, which figure includes special personnel and passengers up to a maximum of 12.

2.5   Chapter XV and the IP Code apply to cargo ships and high speed cargo craft of 500GT and above which undertake international voyages. However, it is recognised that many vessels operating in the offshore sector may be undertaking non-international voyages and are of less than 500GT. Therefore, IMO Member States are encouraged also to apply the requirements to these ships. As such, the proposed Regulations will also apply the IP Code, as well as the SPS Codes, to cargo ships and high speed cargo craft <500GT, and to such ships on non-international voyages; in other words the new requirements will apply to vessels of all sizes, whether on international or non-international voyages.

2.6   UK policy concerning the carriage of industrial personnel, and special personnel, is currently set out in Marine Guidance Note (MGN) 674 (M) – Application of the Special Purpose Ships Code (SPS Code). The current position, as stated in MGN 674 (M), is that the SPS Codes are applied to both special personnel and industrial personnel. Special personnel work primarily on the ship, in contrast to industrial personnel, who work primarily off the ship and on a separate structure. Industrial personnel undertake “walk to work” activities, i.e., they walk from the ship to the offshore structure, and are, therefore (by definition), industrial personnel.

Proposed Changes        

2.7   The primary objective of the proposed Regulations is to implement the new SOLAS Chapter XV and the IP Code. Additionally, the proposed Regulations aim to achieve the following policy objectives:

.1   Preserve, so far as possible, the current “grandfathering” arrangements for ships already carrying industrial personnel, as approved in accordance with MGN 674 (M) in order to minimise disruption to existing ship operations. The proposed Regulations make provision reflecting the grandfathering arrangements permitted by SOLAS Chapter XV; this means that any cargo ship or (if applicable) any high speed cargo craft which was authorised by its flag administration before 1st July 2024 to carry more than 12 industrial personnel, will be able to comply with slightly reduced requirements in the IP Code. The authorisation can only be given by a flag administration where the vessel complies with the recommendations contained in IMO Resolution MSC.418(97), which include compliance with the SPS Code 2008 (or equivalent standard – but note that the UK has not specified an alternative equivalent standard).  UK policy is to ensure that vessels which were complying with the SPS Code 2008 continue to do so, should they wish to benefit from the grandfathering arrangements. MCA has issued authorisations in accordance with SOLAS XV/3.2 and 3.3 to relevant UK-flagged vessels. Further information regarding this can be found in MIN 708(M).

.2  Noting that the SPS Code 1983 does not provide a standard considered to be equivalent to the SPS Code 2008 or the IP Code, vessels certified in accordance with the SPS Code 1983 will not be able to transport industrial personnel on entry into force of the proposed Regulations;

.3  In view of the close synergies between ships operating in the offshore sector carrying industrial personnel and/or special personnel, make the SPS Code 1983 and the SPS Code 2008 mandatory in relation to the carriage of more than 12 special personnel, where there are no industrial personnel also being carried on board; and

.4   Apply both the IP Code and SPS Codes to cargo ships under 500GT including those undertaking non-international voyages.  In this regard, cargo ships under 24m in load line length carrying an aggregate of not more than 12 passengers and industrial personnel must comply with the Merchant Shipping (Small Workboats and Pilot Boats) Regulations 2023 (SI 2023/1216) or the alternative requirements in other merchant shipping legislation relating to core safety requirements, including construction, fire protection, life-saving appliances, navigation and crew training.

.5   The proposed Regulations amend the Merchant Shipping (High Speed Offshore Service Craft) Regulations 2022 (SI 2022/41) to allow operators of smaller, domestically operated, high speed cargo craft carrying industrial personnel to be able to choose whether to comply with the domestic standard in SI 2022/41 or the international standard implemented in the proposed Regulations. In other words, such high speed craft have the option of complying with either the Merchant Shipping (High Speed Offshore Service Craft) Regulations 2022 (SI 2022/41) (“the HSOSC Regulations”), or the Merchant Shipping (High Speed Craft) Regulations 2022 (SI 2022/1219) (“the High Speed Craft Regulations”) and the proposed Regulations.   

    - 1   Where the preference is to comply with the High Speed Craft Regulations and the IP Regulations, to ensure that high speed craft under 500GT are within scope of the High Speed Craft Regulations and that there is no overlap between the two regimes.  Currently, high speed craft under 500GT must comply with the HSOSC Regulations, which is a domestic regime only, and there is no alternative regime for these smaller vessels.

    - 2    To achieve this, two key amendments are made. The first involves removing the words “which is carrying cargo for hire or reward” from regulation 4(1)(c)(iv) of the High Speed Craft Regulations, and also the words “for hire or reward” from regulation 4(1)(c)(ii). These words otherwise imply that a high speed cargo craft must be actually carrying cargo to be within the scope of the Regulations, or in the case of other non-passenger craft, carrying passengers for hire or reward. This condition is not necessary to bring these types of craft within scope of the High Speed Craft Regulations.

    - 3   The second key amendment creates a disapplication of the High Speed Craft Regulations where a vessel is certificated under the HSOSC Regulations. An amendment is also made to the HSOSC Regulations to clarify that the Regulations only apply to vessels where an application for certification is made exclusively under the HSOSC Regulations.

.6   The HSOSC Regulations are also amended to clarify that the application of the instrument is to an aggregate of more than 12 industrial personnel (including special personnel and passengers).  The High Speed Offshore Service Craft Code (known as the HSOSC Code), which is made mandatory by the HSOSC Regulations, will be amended to reflect the changes made by the amendments to HSOSC Regulations, but there are no substantive amendments otherwise needed to the Code.

.7  Include an ambulatory reference provision in the SI to ensure that future amendments to the IP Code are given automatic effect in UK law without the need for amending legislation.

Application of the Regulations

2.8       The proposed Regulations will apply to all UK and non-UK cargo ships and high speed cargo craft which carry industrial personnel and/or special personnel on international and non-international voyages irrespective of vessel size.  They will apply to UK ships wherever they are in the world, and to non-UK ships while they are operating in UK waters (primarily the territorial sea).

Summary of Options and Recommendation

2.9   The following options were considered:

Option 0. Do nothing. The current position regarding the application of requirements for the carriage of special personnel is contained in Marine Guidance Note (MGN) 674 (M). This MGN (and its predecessor MGN 515) were published before the work on the carriage of industrial personnel was completed by the IMO. Both MGN 515 (M) and MGN 674 (M) recognised that SPS vessels could also carry personnel involved in “walk to work” or “step to work” activities (i.e. industrial personnel).

Now that SOLAS XV and the IP Code have been accepted by the UK and come into force (on 1 July 2024), doing nothing with the UK’s current policy approach is not an option. As a party to SOLAS, the UK has a treaty obligation to implement amendments to the Convention that it has accepted (or not objected to).  If we do not implement these new requirements, operationally the UK offshore sector will be at a disadvantage compared to other flag States. This is because the nature of the work means that UK vessels compete with vessels flagged to other States for contracts which could be anywhere in the world. Carrying a recognised international certificate will reduce the likelihood of a port State control detention in foreign States. Additionally, for non-UK flagged vessels operating in UK waters, the powers of detention for such vessels can only be exercised in the context of the current international regulatory framework (which also requires States to treat non-Convention ships in the same way as Convention ships).   

Option 1. Implement SOLAS Chapter XV and the IP Code into UK law. MGN 674 (M) would also be revised and replaced to reflect the updated UK policy concerning the carriage of industrial personnel. This includes an exception for “existing” vessels carrying industrial personnel, for which grandfathering arrangements for the carriage of industrial personnel on SPS vessels is permitted and would be given effect in accordance with SOLAS Chapter XV/3.2 and 3.3.

Option 2. Implement SOLAS Chapter XV, the IP Code and the SPS Codes into UK law for vessels >500GT and undertaking international voyages only. This would mean that the UK would comply with the international requirements for the carriage of industrial personnel and with the recommended requirements for the carriage of special personnel, but would not recognise the non-international nature of the work often undertaken by these vessels. It would leave a regulatory gap for cargo ships <500GT, which currently require certification as cargo ships, and carry a Statement of Compliance with the SPS Code (although some of these may be certified in accordance with the Merchant Shipping (Small Workboats and Pilot Boats) Regulations 2023 if they carry no more than 12 persons on board).

Option 3. Apply the requirements of SOLAS Chapter XV, the IP Code and the SPS Codes on a mandatory basis to all vessels of all sizes and areas of operation carrying an aggregate of more than 12 industrial personnel. The application would therefore include vessels <500GT and those undertaking non-international voyages. High-speed vessels <500GT would have the option of complying with either the HSOSC Regulations 2022, which make mandatory the HSOSC Code, or the proposed Regulations and the High Speed Craft Regulations.

2.10 Compliance with the SPS Codes is already undertaken by many operators in accordance with MGN 674 (M), but only on a non-mandatory basis, and ships carrying special personnel do not carry a Special Purpose Ship Safety Certificate (“SPS Certificate”). If the vessel is carrying a recognised international certificate (the SPS certificate), it is considered that any port State control inspection in a foreign port will be simplified because the Port State Control Officer will be referring to the SPS Certificate, rather than a Cargo Ship Certificate with a UK bespoke SPS Code statement of compliance.

2.11     The preferred option is Option 3

Supporting Information

2.12  Marine Notice:

2.13     It is intended to publish one Marine Guidance Note (MGN xxx) and two Merchant Shipping Notices containing the SPS Codes to support the proposed Regulations (included as Annexes B, D and E in the consultation documents). Annex C contains the text of the IP Code which is included for completeness, although it is not proposed to publish this in a Merchant Shipping Notice because of the ambulatory reference provision.

2.14     MGN xxx is intended to replace MGN 674 (M) and provides advice pertaining to various issues in the specific application of both the IP Code and SPS Codes. It is envisaged that this MGN will be updated in due course in the light of experience gained in the application of SOLAS Chapter XV and the Codes going forward.

2.15     MSN xxx provides the text of the SPS Code 2008. Unlike the IP Code, the SPS Code is outside the scope of the ambulatory reference provision or international instruments in the proposed Regulations but can still be updated under regulation 3(2) of the proposed Regulations. The intention is to publish amendments to the Code made in the IMO by means of a further MSN.

2.16     Finally, MSN xxx provides the text of the SPS Code 1983. As with the SPS Code 2008, it is intended to update this MSN periodically in the light of future amendments to the Code being made in the IMO.

2.17  Offences and Penalties

2.18     The MCA, as the UK’s maritime regulatory and enforcement authority, has responsibility for both delivering and enforcing the Government’s maritime policy relating to ships, seafarers and the seas around the UK. The MCA’s approach to breaches of maritime legislation relies on a range of civil and criminal remedies which, like in many other regulatory regimes in the UK, sit alongside each other to enable the MCA to take the most proportionate action in relation to a particular breach. The decision on what is the most proportionate approach is determined by matters such as the importance of the requirement being breached, the gravity of the contravention, the effect of the contravention on third parties etc.

2.19     MCA surveyors have enforcement and sanction powers which can be applied locally to ships calling at UK ports. The MCA’s powers to use civil sanctions are primarily contained in the Merchant Shipping Act 1995 (“the Act”). These powers, including improvement and prohibition notices, are available only for specific purposes.  Because these civil sanctions are contained in primary legislation, if they are needed, the sanctions will be enforced directly under the Act. The general policy approach, in line with the MCA’s published enforcement policy, is to use these civil sanctions whenever possible before using criminal offences.

2.20     Maritime regulatory requirements govern both safety and pollution prevention. As such, their purpose includes the prevention of loss of life or injury to persons and the protection of the marine environment and adjoining coastlines. These very compelling objectives necessitate the availability of criminal sanctions in the more serious cases, and also provide a vital deterrent. To this end, criminal offences are included in the proposed Regulations.

2.21     All the offences in the proposed Regulations and those in the amended Merchant Shipping (High Speed Offshore Service Craft) Regulations 2022 and the Merchant Shipping (Survey and Certification) Regulations 2015 relate to requirements imposed on the owner and master. In each case, it is a defence for a person charged with an offence to prove that the person charged took all reasonable steps to avoid the commission of the offence.  A small number of offences relate to requirements imposed only on the master. The same defence is available in such cases.

2.22     The offences are detailed in the table below:

Offences in the Merchant Shipping (Safety Measures for Ships Carrying Industrial Personnel and Special Personnel) Regulations 2025
Provision/offence	Subject matter	Person liable	Penalty on summary conviction/ indictment
Regulation 9(2)	Requirement for cargo ships and high speed cargo craft constructed on or after 1 July 2024 to comply with Part III of the IP Code	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 9(3)	Requirement for cargo ships constructed on or after 1 July 2024 to comply with Part IV of the IP Code	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment - imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 9(4)	Requirement for high-speed cargo craft constructed on or after 1 July 2024 to comply with Part V of the IP Code	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 10(2)	Requirement for certain cargo ships constructed before 1st July 2024 carrying more than 12 industrial personnel to comply with the IP Code	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 10(4)	Requirement for certain high-speed cargo craft constructed before 1st July 2024 carrying more than 12 industrial personnel to comply with the IP Code	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 11(1)	Requirement for a ship to comply with the SPS Code that applies to it	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 12	Requirement for special personnel to have received training	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Offences in the Merchant Shipping (High Speed Offshore Service Craft) Regulations 2022 (SI 2022/41)
Provision/offence	Subject matter	Person liable	Penalty on summary conviction/indictment
Regulation 4(A1)	Requirement for a high speed offshore service craft to be certified under either the Merchant Shipping (Survey and Certification) Regulations 2015 or the Merchant Shipping (High Speed Craft) Regulations 2022	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Offences in the Merchant Shipping (Survey and Certification) Regulations 2015 (SI 2015/508)
Provision/offence	Subject matter	Person liable	Penalty on summary conviction/indictment
Regulation 9B	Requirement for survey of cargo ships and high-speed cargo craft carrying industrial personnel	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment - imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 9C	Requirement for survey of special purpose ship	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 23(5C)	Prohibition on United Kingdom cargo ships or high-speed craft proceeding to sea without an Industrial Personnel Safety Certificate	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 23(5D)	Prohibition on non-United Kingdom cargo ships or high-speed craft operating in United Kingdom waters without an Industrial Personnel Safety Certificate or equivalent certificate	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 23(5E)	Prohibition on United Kingdom special purpose ships proceeding to sea without a Special Purpose Ship Safety Certificate	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 23(5F)	Prohibition on non-United Kingdom special purpose ships operating in United Kingdom waters without a Special Purpose Ship Safety Certificate or equivalent	Owner/Master	On summary conviction – fine (E&W unlimited, S and NI not exceeding the statutory maximum) On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 25B	Limit on the number of persons on cargo ships and high-speed craft carrying industrial personnel	Owner/Master	On summary conviction – fine not exceeding £50,000. On indictment – imprisonment for a term not exceeding two years, or a fine (unlimited), or both
Regulation 25C	Limit on on the number of persons on special purpose ships	Owner/Master	On summary conviction – fine not exceeding £50,000. On indictment –imprisonment for a term not exceeding two years, or a fine (unlimited), or both

Section 3:  Responding to this consultation

3.1   There are specific questions highlighted in section 5.1 of this consultation document and information on how to respond to them.

Consultees

3.2   Anyone may respond to this consultation and consideration will be given to all responses. We will be particularly interested to hear from ship owners and operators.

Duration

3.3   This consultation is open for eight weeks from 9 December 2024. However, because of the Christmas break, the deadline for responses has been extended to 17 February 2025.

Submitting your response

3.4   Consultation responses should be emailed to [email protected]. Any questions should also be sent to this email address.

3.5   When responding, representative groups are asked to give a summary of the people and organisations they represent, and, where relevant, who else they have consulted in reaching their conclusions.

Freedom of Information

3.6   Information provided in response to this consultation, including personal information, may be published or disclosed in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA) and the Environmental Information Regulations 2004).

3.7   If you want the information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department.

Data Protection

3.8   The MCA is carrying out this consultation to gather evidence to inform the development and implementation of policy and legislation as required by section 86 of the Merchant Shipping Act 1995. If your answers contain information that allows you to be identified, under data protection law, the MCA, as an Executive Agency of the Department for Transport, will be the controller for the purposes of this information.

3.9   The MCA will use your contact details to send you information about the consultation, for example if we need to ask follow-up questions. You do not have to give us this personal information but if you do choose to provide it, it will not be used for any other purpose without your permission.

3.10  Details about how the MCA looks after personal data, your rights and how to contact our Data Protection Manager can be found on gov.uk at:

https://www.gov.uk/government/organisations/maritime-and-coastguard-agency/about/personal-information-charter

3.11  Your information will be kept securely on the MCA’s IT system and any written responses will be held in a secure file and cabinet and kept for up to five years, until a post-implementation review has been completed.

3.12  If you do not wish to remain on this list, please let us know at [email protected].

Section 4:  Outline of plans beyond this consultation

4.1   Once this consultation closes, we will review all responses. In considering the responses we will apply appropriate weight to those from organisations and individuals with specialist knowledge of the subject area.

4.2   We will be analysing the responses between 17 February and 17 March 2025. Our aim is to publish an overview of the responses and the MCA’s comments by 14 April 2025, which will be available from: www.gov.uk/government/publications

4.3   Where appropriate, the proposed Regulations and accompanying guidance will be revised to take into consideration the consultation responses.

4.4   Our aim is for the Merchant Shipping (Safety Measures for Ships Carrying Industrial Personnel and Special Personnel) Regulations 2025 to be laid in late April or early May and come into force during May 2025. The Regulations will be published on www.legislation.gov.uk.

An overview timetable is below for reference:

Section 5: Consultation Questions

Section 5.1 Consultation Questions

5.1.1 It is an assumption of the analysis that all UK flagged vessels already carrying industrial personnel comply with MGN 674 (M). Do you have any evidence in support of, or with which to challenge, this rationale? If so, please provide evidence of likely costs implications for your business.

5.1.2 Outside of this assumption, do you know of any costs that a vessel that is compliant with the current UK framework would need to incur to be compliant with the proposed changes? If so, please provide any evidence of this.

5.1.3 SOLAS Chapter XV/3.2 (and 3.3) allows ships already operating on the basis of the Interim Recommendations (MSC.418(97)) to continue operating provided that regulations III/1, III/2 (except paragraph 2.1.7), IV/7 and IV/8 are complied with. Please describe the cost implications of having to comply with these requirements.

5.1.4 The proposed Regulations will not allow the carriage of industrial personnel on special purpose ships which operate in accordance with the SPS Code 1983. This is because it is considered that the 1983 Code does not provide a standard equivalent to the SPS Code 2008 or the IP Code. What will be the operational impact of this policy objective?

5.1.5 Please describe any difficulties you anticipate in complying with the medical fitness and safety training requirements set out in Section 5 of the MGN.

5.1.6 High-speed cargo craft <500GT can already transport industrial personnel on the basis of the requirements in the High-Speed Offshore Service Craft Code and the proposed Regulations will allow operators of high speed cargo craft the option of complying with the IP Code and the High Speed Craft Code 2000  instead. What are your views on this?

5.1.7 Are you aware of any unintended consequences that removing the words “which is carrying cargo for hire or reward” in regulation 4(1)(c)(iv), and “carrying cargo for hire or reward” in regulation 4(1)(c)(ii) of the High Speed Craft Regulations might have?

5.1.8 Do you know if any businesses will be disproportionately affected by the proposed changes?

5.1.9 What are the key areas, if any, where costs and benefits may arise for your business due to the proposed changes?

5.1.10 Generally, do you know of any likely unintended consequences resulting from the proposed changes?

5.1.11 What impact do you think the proposed changes will have upon safety standards? Please provide evidence to support your response.

Section 5 - Response Form. This can be found here

Section 5.2

Please provide any additional comments you wish to add in the box above

Please return completed response forms to [email protected]

Alternatively, responses may be posted to:

Ship Safety Lead
Maritime and Coastguard Agency
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Section 6:   Conduct of this consultation

6.1.  This consultation has been conducted in accordance with the Cabinet Office Consultation Principles.

Consultation principles

6.2.  The Cabinet Office Consultation Principles can be found at:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/492132/20160111_Consultation_principles_final.pdf

Feedback on conduct of consultation

6.3.  If you have any comments regarding the conduct of this consultation, please contact the Consultation Co-ordinator at [email protected].

6.4.  We are continually trying to improve the way in which we conduct consultations and appreciate your views.  We would be grateful if you could complete and return the attached feedback form.  These should be submitted to the Consultation Co-ordinator and are not affected by the deadline for this consultation.

6.5   If you require this consultation in an alternative format, please contact either the Consultation Co-ordinator or the named official conducting this consultation.

Section 6 - Consultation Feedback Form