Flag

Shipping Industry Guidelines on

State
Performance
Second edition
 Flag
Shipping Industry Guidelines on

State
Performance
Published by Maritime International Secretariat Services Limited
12 Carthusian Street, London EC1M 6EZ
email publications@marisec.org
web www.marisec.org/flag-performance
Second edition © 2006

These guidelines have been developed using the best information available, but they
are intended for guidance only, to be used at the user’s own risk. No responsibility
is accepted by any firm, corporation or organisation who or which has been in any
way concerned with the furnishing of data, the compilation, publication or authorised
translation, supply or sale of this guidance, for the accuracy of any information or advice
given herein, or any omission herefrom or consequences whatsoever resulting directly or
indirectly from use of these guidelines or from compliance with or adoption of guidance
contained therein.
Foreword Contents
The Round Table of international shipping associations - page 3 Purpose and scope
BIMCO, INTERCARGO, INTERNATIONAL CHAMBER
OF SHIPPING/INTERNATIONAL SHIPPING 4 Introduction
FEDERATION and INTERTANKO - believe it is essential 4 Why produce these guidelines?
that standards of safety, environmental and social 4 The role of the flag state
performance are maintained and enforced by flag states, 4 Why flag state performance is important
in full compliance with international maritime regulations.
These guidelines on flag state performance have been
produced to help the international shipping industry 6 Section One
contribute to this objective. Flag state responsibilities
The guidelines are addressed to shipping companies 6 Infrastructure
owning and/or operating merchant cargo or passenger 6 International maritime treaties
ships trading internationally. Although developed for 6 Implementation and enforcement
shipping companies, they should also be of interest 7 Supervision of surveys
to policy makers involved in maritime safety, and flag 7 International Safety Management Code
administrations themselves. 7 Maritime security
7 Seafarers’ competence standards
Guidelines such as these can only be recommendatory 8 Employment standards
in nature, and companies may need to adapt them to 8 Safe manning and seafarers’ working hours
fit their particular needs and circumstances. On this 8 Casualty investigations
understanding, the guidelines are intended to provide 8 Movement of ships between flags
useful advice on what a shipping company might 8 Repatriation of seafarers
reasonably expect, in its capacity as a customer, of an 9 IMO Member State Audit Scheme
administration whose flag it chooses to fly. 9 Participation at IMO and ILO meetings
9 Consultation with shipowners

Note on the Second Edition 10 Section Two

This is the second edition of the Shipping Industry Guidelines Selected summary data on
on Flag State Performance, following initial publication in flag state performance used in the
2003 (although the accompanying Flag State Performance Flag State Performance Table
Table has been updated annually).
10 How to use the data
The guidelines have been revised to reflect recent 10 Port state control
developments including the adoption by the International 10 Ratification of major international
Maritime Organization (IMO) of the Member State Audit maritime treaties
Scheme, and its accompanying Code on the Implementation 11 Use of Recognized Organizations complying
of Mandatory Instruments, whereby maritime with A.739
administrations are subject, on a voluntary basis, to external 12 Age of fleet
audits by other IMO Member States, in order to identify any 12 Reporting requirements
shortcomings with regard to the full implementation of IMO 12 Attendance at IMO meetings
regulatory requirements. The Round Table of international
shipping associations is a committed supporter of the IMO
audit scheme, which it is hoped will eventually become
mandatory. These Shipping Industry Guidelines are intended Insert Table of summary data on
to serve as a complement to the IMO scheme, contributing Flag State Performance
to the objectives of maintaining safe shipping and clean seas.
This latest edition of the guidelines also reflects other
important developments, such as the adoption by the
International Labour Organization (ILO) of the Maritime
Labour Convention, 2006, and the entry into force of Annex
VI (prevention of atmospheric pollution) of the IMO MARPOL
Convention. This edition also takes account of numerous and
helpful comments received from maritime administrations
around the world, in order to make the guidelines as relevant
and objective as possible.

4
 Purpose and scope
There is nothing inherently unusual in an international ship registry system in which the owner
of a ship may be located in a country other than the state whose flag the ship flies. However, a
balance has to be struck between the commercial advantages of selecting a particular flag and
the need to discourage the use of flags that do not meet their international obligations.
The purpose of these guidelines is twofold:

1
•To encourage shipowners and operators to examine whether a flag state 1
has sufficient
The common legal substance before using it.
understanding of
‘flag state’ is the •To encourage shipowners and operators to put pressure on their flag administrations to
administration or the effect any improvements that might be necessary, especially in relation to safety of life at sea,
government of the state
whose flag the ship is
the protection of the marine environment and the provision of decent working and living
entitled to fly. conditions for seafarers.

Section One of these guidelines contains a list of the responsibilities that a shipping
company might reasonably expect of a flag state. For simplicity and practicality, this list is
general in nature and makes no claim to be comprehensive. It is nevertheless intended to
provide some criteria for determining whether a flag administration takes its responsibilities
seriously.

Section Two (and the accompanying Flag State Performance Table)

summarises some essentially factual information that may be helpful in assessing the
performance of flags, derived from data available in the public domain. The format of the table
is intended to provide a general appreciation of a flag’s performance, and an indication of
whether further questions may need to be asked. The conclusions that can be drawn from this
data are largely self-explanatory. The performance table is updated annually (see www.marisec.
org/flag-performance).

5
Introduction

Why produce these guidelines?

Shipping is one of the safest and most environmentally benign modes of transport, yet several
high profile casualties have prompted questions from politicians and the media about the
performance of flag states. There is understandable concern about shipping companies’ use of
flags that may not comply fully with international regulations. Moreover, contemporary worries
about maritime security have added a new slant to these concerns.

While it is shipping companies that have primary responsibility for the safe operation of their
ships and the safety and welfare of their crews, the flag state plays a critical role with regard to
the safety of life at sea and the protection of the marine environment. It is the flag state that
has overall responsibility for the implementation and enforcement of international maritime
regulations for all ships ‘flying its flag’. Effective regulation by governments of the technical
and social aspects of shipping is therefore vital to ensure safe, secure and pollution-free ship
operations, and good employment conditions for seafarers.

The United Nations International Maritime Organization (IMO) has made considerable efforts
to restore confidence in the flag state. But it is also important for the industry to promote
satisfactory flag state performance, and for shipping companies to discourage the use of flags
that perform poorly.

The role of the flag state

The flag state, as defined by the United Nations Convention on the Law of the Sea
(UNCLOS), has overall responsibility for the implementation and enforcement of international
maritime regulations for all ships granted the right to fly its flag. However, the flag state may
conduct the larger part of its activities through entities located in other countries.

Most national maritime administrations have other roles, in their capacity as port and coastal
states, which may involve the enforcement of regulations with regard to visiting foreign ships.
However, in the context of the regulation of shipping, it is a nation’s role as a flag state that is
the first line of defence against potentially unsafe or environmentally damaging ship operations.
This is the focus of these guidelines.

The enforcement of IMO rules that apply to the operation of ships is, in the first instance,
dependent on IMO member governments in their capacity as flag states. Flag states also
have responsibility for the implementation and enforcement of rules adopted by other
intergovernmental bodies, including the International Labour Organization (ILO) and the
International Oil Pollution Compensation (IOPC) Fund. ILO governs standards of seafarers’
employment. The IOPC Fund ensures that victims of any major maritime oil pollution incident
receive adequate compensation without undue delay.

Why flag state performance is important

The owner of a high quality fleet, operated under one or more flags to a uniform standard
in full conformity with international requirements, might well ask why the performance of the
flag is relevant to his operation. Since a shipping company has primary responsibility for the
safety of its vessels, a ship’s quality should ultimately be judged on an individual basis. Indeed,
excellent ships may be registered with less effective flags, while some well-administered flags
may have some less satisfactory tonnage.

6
However, the performance of a flag being used by a fully compliant shipping company may
impinge directly on that company’s performance. Ships flying a flag whose vessels have
shown higher than average levels of non-compliance during port state control inspections
are generally subject to special port state control targeting and thus greater numbers of
inspections. For the compliant operator this can mean unnecessary delays, plus greater
potential for charterers’ penalties. Moreover, on ships using flags with a poorer record,
port state control inspectors may be more inclined to make an issue of routine non-critical
deficiencies caused by genuine ‘wear and tear’ during the preceding voyage.

The shipping company, and not least its charterers, may also have general concerns about the
implications for its corporate reputation of being associated with a poorly performing flag, even
if the company’s ships are fully compliant.

But the overriding interest in promoting high performing flag states is that they are less likely
to tolerate sub-standard operators. This small minority of shipping companies enjoys an unfair
commercial advantage over the vast majority of fully compliant operators, and damages the
overall reputation of the industry.

A shipping company whose ships comply fully with international standards may still have
legitimate reasons for using a flag that has a below average record. The state may be the
country in which the company is located, there may be implications for the employment of
certain nationalities of seafarers, or else the use of particular flags could be determined by the
terms of a ship’s charter (eg government contracts).

But if there is reason to believe, perhaps from analysis of the data summarised in Section 2, that
a flag has a poor performance, then shipowners may wish to consider carefully whether using
such a flag is in the interests of either the company or the industry at large. In co-operation,
where relevant, with national and international shipowners’ associations, shipowners who have
concerns about the performance of particular flags are strongly encouraged to enter into a
dialogue with such administrations, and to urge an improvement in their record.

7
Section One

Flag state responsibilities

Infrastructure
A flag state should clearly have sufficient infrastructure, in terms of qualified and competent
staff, offices and equipment, to meet its obligations under international treaties. Different flags
have different approaches, eg staffing may depend on the extent to which flags delegate certain
functions to bodies such as classification societies. But if a flag state does not appear to have
separate inspection or crewing departments, for example, it is possible that the flag’s only
effective function may be the collection of registration fees.

International maritime treaties

All flag states should endeavour to ratify the principal international maritime treaties, including
those adopted by IMO and ILO.
As a minimum, flag states should be expected to have ratified the following core international
maritime conventions:
1 International Convention for the Safety of Life at Sea, 1974 as amended, including the 1988
Protocol, the International Safety Management (ISM) Code and the International Ship and
Port Facility Security (ISPS) Code (SOLAS 74).
2 International Convention for the Prevention of Pollution from Ships,1973 as modified by
the Protocol of 1978, including Annexes I - VI (oil, bulk chemicals, dangerous packaged
goods, sewage, garbage and atmospheric pollution) (MARPOL 73/78).
3 International Convention on Load Lines, 1966, including the 1988 Protocol (LL 66).
4 International Convention on Standards of Training, Certification and Watchkeeping for
Seafarers, 1978 as amended, including the 1995 amendments (STCW 78).
5 International Labour Organization Merchant Shipping (Minimum Standards) Convention
1976, including the 1996 Protocol (ILO 147), until superseded by the Maritime Labour
Convention, 2006.
6 International Convention on Civil Liability for Oil Pollution Damage, 1992, and the
International Convention on the Establishment of an International Fund for Compensation
for Oil Pollution Damage, 1992 (CLC/Fund 92).
A responsible flag state should be able to provide a valid explanation for not having ratified
any of the above, and in practice should be expected to implement and enforce national
regulations that comply with the vast majority of the detailed requirements contained within
these international regulations.

In addition to the ‘core’ maritime conventions mentioned above, and the United Nations
Convention on the Law of the Sea (UNCLOS), flag states are particularly encouraged to ratify
and implement the following more specific IMO Conventions: Control and Management of
Ships’ Ballast (BWM); Anti-fouling Systems (AFS); Limitation of Liability for Maritime Claims
(LLMC) and its 1996 Protocol; Liability and Compensation for Damage in Connection with the
Carriage of Hazardous and Noxious Substances by Sea (HNS); and Civil Liability for Bunker
Oil Pollution Damage (Bunkers). However, because these instruments still lack widespread
ratification, even amongst what might be regarded as leading flag states, they are not currently
referred to in the accompanying Flag State Performance Table.

Implementation and enforcement

As a minimum, it is reasonable to expect flag states to have implemented the detailed
requirements of the international maritime treaties listed above, and to have established

8
effective mechanisms for their enforcement. For example, SOLAS, amongst other conventions,
provides for regular ship surveys and the issue of certificates of compliance by the flag state,
while STCW requires certification of crew competence.
A simple means of assessing the extent to which international regulations are being properly
enforced is through an examination of externally published data concerning the performance
of ships registered with particular flags, not least port state control data (see Section Two and
the table accompanying these guidelines).

Supervision of surveys
In accordance with IMO Resolution A.739, flag states should establish appropriate controls
over organisations, such as classification societies, nominated to conduct statutory surveys of
ships on their behalf.
Such controls should include determining that the organisation has adequate resources for
the tasks assigned, and entering into a formal written agreement covering the issues specified
in A.739. Flag states should specify instructions detailing actions to be followed in the event
that a ship is not found fit to proceed to sea, and provide information concerning national
regulations that give effect to international maritime conventions. A verification and monitoring
system should also be established to ensure the adequacy of work performed by organisations
acting on a flag state’s behalf.
The delegation of statutory survey work should be restricted to ‘Recognized Organizations’ that
comply with IMO Resolution A.739. In practice this will usually mean internationally recognised
bodies, such as members of the International Association of Classification Societies (IACS).

International Safety Management Code

Flag states should have implemented the requirements of the ISM Code concerning the
auditing of safety management systems (SMS), both on ships flying their flag and the shore
based companies responsible for their safe operation. Flag states should also have established
procedures for the issue and withdrawal of ships’ Safety Management Certificates (SMCs) and
companies’ Documents of Compliance (DOCs).
Flag states should also adhere to the Guidance contained in IMO Resolution A.788 concerning
the implementation of the ISM Code.
Flag states delegating ISM Code auditing and certification to other bodies should only delegate
to organisations that comply with IMO Resolution A.739.

Maritime security
Flag states should have implemented the relevant requirements of the SOLAS Convention and
the International Ship and Port Facility Security (ISPS) Code concerning the approval of Ship
Security Plans, the issue of International Ship Security Certificates and the provision to ships of
Continuous Synopsis Records.
Flag states delegating approval of plans and/or the issue of security certificates to other bodies
should only delegate to organisations that comply with the requirements for Recognized
Security Organizations as specified by the ISPS Code.
Flag states are also encouraged to ratify and implement the ILO Seafarers’ Identity Documents
Convention, 2003 (ILO 185).

Seafarers’ competence standards

Flag states should be placed on the IMO STCW ‘white list’ of governments that have
demonstrated compliance with the administrative measures needed to implement the 1995
amendments to the STCW Convention concerning the competence and certification of
internationally qualified seafarers. As required by STCW, flag states should submit quality
standards reports to IMO at five year intervals, outlining any deficiencies in their training and

9
certification systems and measures taken to rectify them, in order to maintain a place on the
updated STCW ‘white lists’ periodically issued by the IMO Maritime Safety Committee.
Flag states should issue STCW recognition endorsements to foreign officers serving on ships
flying their flag, even when they have been issued with certificates of competence by another
country. The flag state should have procedures in place to ensure that the foreign certificate
issuing country complies with STCW training and certification standards.
Flag states should maintain databases of the certificates they have issued to national seafarers
and of STCW endorsements issued to foreign officers, and respond immediately to requests
from companies seeking confirmation of the validity of any certificate or flag state recognition
endorsement issued by the flag state.

Employment standards
Flag states should implement the requirements of the ILO Maritime Labour Convention,
2006, including, but not limited to, the inspection and enforcement of ILO standards covering
conditions of employment, food and catering, medical care and accommodation; the approval
of ships’ Declarations of Maritime Labour Compliance; and the issue of Maritime Labour
Certificates.

2
Safe manning and seafarers’ working hours As amended by
Resolution A.955 to
Flag states should approve safe manning levels for ships flying their flag and issue safe manning take account of the ISPS
Code.
documents, in accordance with the provisions of IMO Resolution A.8902.
3
The work/rest hour
Flag states should strictly enforce minimum seafarers’ rest hours that comply with the ILO
requirements of the
Maritime Labour Convention (MLC 2006)3 in addition to the IMO STCW Convention. Flag ILO Maritime Labour
states should require work/rest hours to be recorded in accordance with joint IMO/ILO Convention are essentially
Guidance4. the same as the
requirements of ILO 180.
4
IMO/ILO Guidelines
Casualty investigations on Work Hour Record
Formats, published by
In accordance with IMO Resolution A.849, and taking into account the provisions of SOLAS IMO in 1999.
and MARPOL, a flag state should carry out investigations of any ‘serious’ and ‘very serious’
casualty occurring to its ships, as soon as practicable after the casualty. Flag states should
also co-operate with other nations investigating casualties in which ships flying its flag may be
involved. The relevant findings of such investigations should be forwarded promptly to IMO,
and should be made available to the industry and other interested parties.

Movement of ships between flags

A flag state accepting a ship transferring from the flag of another state should only accept
such a ship when it is satisfied that it is in compliance with international requirements, and has
survey reports confirming that the ship is in class. Flag states whose ships transfer to other
registers have an obligation to provide all necessary information to the new flag state in which
the ship is registered.

Repatriation of seafarers
In normal circumstances the employer is responsible for the repatriation of seafarers.
Nevertheless, as required by the ILO Maritime Labour Convention, a responsible flag state
should institute arrangements to ensure that in the rare event of normal procedures failing
(eg due to bankruptcy of a shipping company) the seafarers working on board any ships flying
its flag, including those that are nationals of other states, are repatriated to their country of
residence.

10
IMO Member State Audit Scheme
Flag states should participate in the IMO Member State Audit Scheme in order to identify areas
for possible improvement with regard to the implementation of IMO instruments, and which may
benefit from IMO technical assistance programmes.
In the interests of transparency and continuous improvement, the industry organisations believe that
flag states should publish the results of the IMO audits for the benefit of the industry as a whole.

Participation at IMO and ILO meetings

In order to keep appraised of the latest international maritime regulatory developments
(and contribute to the decisions made by IMO), flag states should be expected to attend all
meetings of the following IMO committees:
• Maritime Safety Committee (MSC)
• Marine Environment Protection Committee (MEPC)
• Legal Committee (LEG)
• Biennial meetings of the IMO Assembly.
If possible, flag states should also participate in IMO Diplomatic Conferences and relevant
technical sub-committees of IMO, including the Sub-Committee on Flag State Implementation,
as well as major maritime meetings of the International Labour Organization. All flag states,
particularly those from developing countries which might benefit from technical assistance
programmes, should also be encouraged to attend meetings of the IMO Technical
Co-operation Committee.

Consultation with shipowners

Flag states should have some form of consultative process to enable ship operators to
engage in discussions about maritime regulatory developments and other issues relevant to
the safe operation of ships flying their flag, for example, through the mechanism of a national
shipowners’ association.

11
Section Two

Selected summary data on flag state

performance used in the
Flag State Performance Table
(To be read with accompanying inserted table)

How to use the data

Summary data on certain aspects of flag state performance, derived from information available
in the public domain, are shown in the inserted table accompanying these guidelines. This Flag
State Perfomance Table is updated annually (see www.marisec.org/flag-performance).
Like all statistics, the data shown need to be used with care. A single indicator may provide
an unreliable measurement of performance (eg although a flag state might be unable to
ratify a convention due to conflict with domestic law, it may nevertheless implement its main
requirements). However, when a variety of indicators suggests that a flag may suffer from
unsatisfactory performance, shipping companies using, or considering using, that flag should ask
further questions of the administration concerned.

Port state control

A simple means of assessing the effective enforcement of international rules is to examine the
5
collective port state control record of ships flying a particular flag. There are various other
regional and national PSC
The three principal regional Port State Control (PSC) authorities5, which maintain regimes worldwide, but in
the interests of simplicity
comprehensive statistics, are the countries of the Paris Memorandum of Understanding the performance table
(MOU), the Tokyo MOU and (though a single country) the United States. All three authorities only uses data from the
target particular flags on the basis of deficiencies and detentions recorded for ships flying three principal regional
PSC authorities.
that flag. The targeting methods differ slightly, and some poorly performing flags may be
omitted because the number of their ships trading to particular PSC regions is too small to be 6
The Paris and Tokyo MOU
statistically significant. However, the table identifies flag states that appear on the Paris MOU, data relates to their ‘black
lists’, but not their ‘grey
Tokyo MOU and United States Coast Guard (USCG) target lists of flag states6.
lists’ of flags whose record
As a further indication of performance, the tables also identify those flags which, though not is worse than average but
better than those on the
necessarily performing poorly, are not included on the Paris MOU ‘white list’, the Tokyo MOU ‘black list’.
‘white list’ or in the US Coast Guard ‘Qualship 21’ programme, and whose ships may therefore
7
be subject to a greater likelihood of inspections7. Some flags may not be
included on regional PSC
‘white lists’ because the
Ratification of major international maritime treaties low number of port calls
by their ships may make
Ratification of international maritime conventions does not necessarily confirm whether the them ineligible to qualify.
provisions of these global instruments are being properly enforced. However, a flag state The fact remains, however,
that ships flying such flags
should be able to provide good reason for not having ratified any of the instruments referred will be more likely to be
to in the table. subject to inspection.

The list of conventions referred to in the Performance Table is not as extensive as that
contained in Section One of these guidelines, the Performance Table including only those ‘core’
conventions, relevant to flag state responsibilities, which already enjoy widespread ratification
and enforcement. For this reason, because the ILO Maritime Labour Convention (MLC 2006)
was adopted as recently as February 2006, the table still refers to the ILO Merchant Shipping
(Minimum Standards) Convention (ILO 147) as the main maritime labour convention that
flag states should reasonably be expected to have ratified. However, the Maritime Labour
Convention 2006 supersedes ILO 147 and will therefore replace it in the Performance Table in
due course, once states have had sufficient time to ratify it.

12
The criteria for the conventions listed in the table are as follows:
• International Convention for the Safety of Life at Sea, 1974 as amended (SOLAS 74) -
includes the 1988 Protocol.
• International Convention for the Prevention of Pollution from Ships, 1973 as modified by
the Protocol of 1978 (MARPOL 73/78) - the table includes one column for the ratification
of MARPOL and its mandatory Annexes I (oil) and II (bulk chemicals); and
a second column for the remaining Annexes III (dangerous packaged goods), IV (sewage),
V (garbage) and VI (atmospheric pollution).
• International Convention on Load Lines, 1966 (LL 66) - includes the 1988 Protocol.
• International Convention on Standards of Training, Certification and Watchkeeping for
Seafarers, 1978 as amended (STCW 78) - includes the 1995 amendments.
• International Labour Organization Merchant Shipping (Minimum Standards) Convention,
1976 (ILO 147) - excludes the 1996 Protocol.
• International Convention on Civil Liability for Oil Pollution Damage, 1992, and the
International Convention on the Establishment of an International Fund for Compensation
for Oil Pollution Damage, 1992 (CLC/Fund 92) - includes the 1992 Protocols.
.
Use of Recognized Organizations complying with A.739
There are no published data for determining whether each of the various Recognized
Organizations conducting survey work on behalf of flag states complies with IMO Resolution
A.739. For the purpose of these guidelines it is assumed that IACS members comply.
Nevertheless, there are several other organisations that are not members of IACS that meet
the standards required by IMO, and the fact that a flag administration may recognise a non-
IACS member does not therefore mean that the flag is deficient. However, if a flag state
recognises large numbers of organisations that are not IACS members, there may be reason to
doubt whether all of the bodies conducting surveys on behalf of the flag state actually comply
with IMO requirements.
The table therefore indicates the number of organisations that are not members of IACS
which are recognised by different flag states. The table also identifies those flag states that have
not submitted their Recognized Organization data to IMO in line with A.739.

13
Age of fleet
It must be emphasised that the age of a ship is not an indicator of quality and the condition of
a ship is ultimately determined by the standard of its maintenance. That said, a flag which has a
concentration of older tonnage is likely to attract poorer quality vessels, and a flag state that has a
very high age profile may prompt further analysis.
The table therefore shows the 25% of flags whose ships have the highest average age amongst
those listed, in terms of both numbers of ships and tonnage.

Reporting requirements
To encourage implementation of international instruments, there are various reporting
requirements, both mandatory and recommendatory, concerning the submission of information by
flag states to bodies such as IMO and ILO.
Information covering the extent to which flags have complied with certain reporting requirements
is not always available in the public domain. However, as an indicator, the table shows flags that
have failed to submit adequate reports of independent evaluations to IMO confirming continuing
compliance with the STCW Convention, and have thus failed to maintain a place on the most
recent STCW ‘white list’. The table also shows flag states which have failed to submit compliance
and practice reports required by ILO.

Attendance at IMO meetings

Although in itself not an indicator of their safety and environmental record, flag states that do not
attend the major IMO meetings (Maritime Safety Committee, Marine Environment Protection
Committee, Legal Committee and Assembly) may be thought unlikely to be seriously committed
to the implementation and enforcement of IMO rules. Attendance at these meetings is also
important to keep abreast of regulatory developments.

The table identifies flag states that have not been represented at all meetings of these three major
IMO committees or the biennial meeting of the IMO Assembly during the previous two years.

14
BIMCO
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N-0308 Oslo
Norway
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Published by
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London EC1M 6EZ
Telephone +44 20 7417 8844
Fax +44 20 7417 8877
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