I am rather puzzled by the purpose of this list. The ICS states that it is to encourage ship owners to provide decent working and living conditions on the registered ships and yet it has no criteria for compliance with UNCLOS which specifies this in Article 94. It also specifies that the company and flag state should have genuine link. If these criteria had been included, then most of the states would have a red square in this section. The compliance with the Vienna convention is not mentioned either probably for good reason.
The heading of ratification of conventions is meaningless. Many of the flag states ratify these conventions without the slightest intention of compliance.
A benchmark of attendance at the IMO is again rather pointless.
A more meaningful one of compliance with the IMO conventions would have more relevance. Indeed, it may be better if many of these flag states avoided attendance and then so many good legislative proposals would not be blocked.
The Chamber also claims that this document is to encourage ship owners to put pressure on their flag administrations to effect be any improvements that may necessary, especially in relation to safety of life at sea.
The fact that we still have safety equipment so out of date and not fit for purpose and seafarers dying in enclosed spaces without any legislation shows that the ship owners are well versed in putting such pressure on, unfortunately in the wrong direction.
It is regrettable that the ICS has not made more use of its facilities to make a serious attempt to deal with the flagrant abuse of the flag state system by many countries that now sell their registrations like postage stamps with no intention or ability to comply with their responsibilities. You have the feeling that the document is designed to allow their members to feel more comfortable about the flag states they have registered their ships in. It will do nothing to improve safety or improve conditions for those at sea.
Why would the ICS want to do that? They’re called flags of convenience be cause they’re convenient for ship owners. The ICS represents owners. Don’t see why they’d want to rock the boat, so to speak.
One thing that the ICS Table has demonstrated for many years is the lack of substance to arbitrary distinctions that are sometimes made between the performance of open registers and so called traditional flag states. While they might have been relevant 20 years ago, the ICS Table continues to show that such distinctions are no longer helpful. Almost two thirds of the world fleet is now registered with the eight largest open registers (Panama, Liberia, Marshall Islands, Singapore, Bahamas, Malta, Cyprus and Isle of Man) all of which show impressive levels of performance.
ICS represent Shipowners from all over the world, with vessels under a lot of different flags, incl. USA, UK, Canada, Norway etc.
“Open Register” does NOT mean inferior rules and regulation, nor lack of safety standard compliance. The term Flag of Convenience refers to the convenience of low tax regime and the ability to register a vessel without having any real presents in that jurisdiction.
Of course it is one of the many US based and managed FOC registers, that probably help to explain it.
Now is left to be seen if the “underpaid 3rd world villagers” that man the ships under Liberian flag will be able to handle such a thing, or if the greedy Owners of the ships (many of them Americans) will force them to falsify the records.
