19.Fire is regarded as one of the greatest risks to seafarers and passengers on ships. The International Maritime Organisation’s (IMO) requirements on firefighting and fire protection matters were last implemented into UK law in 2003. Since when 20 further IMO resolutions have been agreed that apply to ships of more than 500 gross tons whether carrying cargo or passengers.6 (Provision for smaller ships is set out in the Merchant Shipping (Fire Protection: Small Ships) Regulations 1998.7)
20.The Department for Transport (DfT) states that there are 440 ships on the UK flag that are subject to the IMO requirements implemented by this instrument, of which 324 are wholly or partially UK owned. DfT adds that the routine surveys of these ships carried out by the Marine and Coastguard Agency have established that these ships are already “mostly in compliance” with the updated requirements, otherwise they could not trade internationally as they would risk detention in overseas ports. Only when these Regulations come into effect will the UK be able to enforce those same requirements on foreign-flagged ships in UK waters. We note that DfT is gradually addressing its backlog of implementing international maritime legislation but these Regulations illustrate why we were so concerned that it was allowed to accumulate in the first place.
6 The 20 resolutions are listed in the EM, the first dates back to June 2004 and relates to the stowage of dangerous goods below deck, others specify fire fighting equipment and passenger evacuation requirements.
7 Merchant Shipping (Fire Protection: Small Ships) Regulations 1998 (SI 1998/1011).