Frequently Asked Questions & Industry Updates

RightShip RISQ 3.2 — Key Differences from RISQ 3.1

RightShip’s RISQ (RightShip Inspection Ship Questionnaire) framework continues to evolve to strengthen consistency, comparability, and risk-based inspection outcomes across the global fleet.

RISQ 3.2 represents an incremental development from RISQ 3.1 rather than a structural redesign. The core inspection scope remains broadly aligned; however, several important refinements influence how inspections are conducted and interpreted.

1. Shift from Compliance Confirmation to Verification

RISQ 3.1 focused primarily on confirming the presence of procedures, equipment, and documentation.

RISQ 3.2 places greater emphasis on verification, including:

• Demonstration of operational use
• Review of supporting records
• Crew explanation of practical application
• Physical confirmation of condition and readiness

This reflects a move toward assessing effectiveness rather than existence.

2. Increased Emphasis on Human Factors

RISQ 3.2 introduces stronger integration of human-factor considerations within technical questions. Inspectors are encouraged to assess:

• Usability of equipment and interfaces
• Crew familiarity with safety-critical systems
• Clarity of markings, instructions, and alarms
• Workarounds and normalised deviations
• Practical understanding of risk controls

This aligns inspections more closely with operational reality onboard.

3. Barrier and Safety-Critical Equipment Focus

RISQ 3.2 reinforces a barrier-based perspective, with greater attention to lifecycle control and reliability of safety-critical systems, including:

• Lifesaving appliances (LSA)
• Firefighting systems
• Mooring arrangements
• Emergency response equipment
• Personal protective equipment lifecycle management

Observations are increasingly interpreted in terms of barrier effectiveness rather than isolated defects.

. Evidence and Consistency Expectations

RISQ 3.2 introduces clearer expectations regarding evidence to support inspection responses, including:

• Maintenance verification
• Calibration records
• Drill performance evidence
• PMS alignment with physical condition
• Traceability of corrective actions

This supports improved consistency between inspectors and inspections.

5. Enhanced Question Clarity and Structure

Many RISQ questions have been refined to:

• Reduce ambiguity
• Improve inspector alignment
• Encourage scenario-based evaluation
• Support consistent grading
• Limit purely binary responses

The intent is to strengthen comparability of inspection outcomes across the fleet.

6. Stronger Treatment of Recurring Observations

RISQ 3.2 places greater emphasis on trend visibility and repeat findings. Observations are increasingly considered within the context of:

• Previous inspection history
• Corrective action effectiveness
• Systemic vs isolated issues
• Evidence of continuous improvement

This supports a more risk-based interpretation of inspection results.

What Remains Unchanged

RISQ 3.2 does not fundamentally alter:

• Overall inspection scope
• Vessel categories
• Core technical inspection themes
• Requirement for physical onboard verification
• Role of inspector judgement

The framework remains an evolution of RISQ 3.1 rather than a replacement.

Practical Implications for Ship Operators

Operators should recognise that RISQ 3.2 places greater weight on operational effectiveness. In practice this means:

• Procedures must be demonstrably implemented
• Safety-critical equipment lifecycle management must be robust
• Crew familiarity and explanation are increasingly relevant
• Minor condition signals may carry greater contextual significance
• Closure of previous findings is more visible

Preparation therefore benefits from focusing on consistency of practice rather than documentation alone.

Aaron Right Perspective

From a marine assurance standpoint, RISQ 3.2 reinforces a broader industry shift toward reliability-based assurance.

Inspection outcomes increasingly reflect:

• Normalisation of small deficiencies
• Alignment between documented systems and practice
• Barrier integrity over time
• Evidence of verification culture

As a result, preparation for RISQ inspections is most effective when embedded in routine operational management rather than treated as a pre-inspection exercise.

Key IMO Regulatory Updates Entering into Force (2025)

IMSBC Code Amendments (07-23) — MSC.539(107)

Amendments to the International Maritime Solid Bulk Cargoes (IMSBC) Code, applied voluntarily since 1 January 2024, will become mandatory on 1 January 2025.

A key update requires shippers to declare the bulk density of cargo in accordance with SOLAS regulation XII/10 (MSC.1/Circ.1664), supporting improved cargo planning and vessel safety.

STCW Amendments — Electronic Seafarers’ Certificates

MSC.540(107) & MSC.541(107)

To support global digitalisation, amendments to the STCW Convention (regulations I/1 and I/2) and STCW Code (section A-I/2) now allow seafarer certificates to be issued electronically. The amendments also define the minimum information required on electronic certificates.

Guidance is provided in MSC.1/Circ.1665.

MARPOL Annex I — Red Sea & Gulf of Aden Special Areas

MEPC.381(80) — Effective 1 January 2025

The Red Sea and Gulf of Aden are now designated Special Areas under MARPOL Annex I following confirmation that adequate reception facilities are available across coastal States.

From this date, discharge of oil or oily mixtures from ships 400 GT and above is prohibited within these regions, except where strict conditions are met, including:

• Ship is en route
• Oil filtering equipment meets regulatory requirements
• Effluent oil content does not exceed 15 ppm
• Discharge does not originate from cargo pump room bilges (tankers)
• Mixture is not combined with cargo residues

Discharges from cargo areas of oil tankers are prohibited, except for clean or segregated ballast.

MARPOL Annex V — Red Sea Garbage Special Area

MEPC.382(80) — Effective 1 February 2025

The Red Sea has been confirmed as a Special Area under MARPOL Annex V. Discharge of garbage is restricted and permitted only while the vessel is en route and in accordance with Regulation 6 requirements.

BWM Convention — Ballast Water Record Book (BWRB) Update

MEPC.369(80) — Effective 1 February 2025

Appendix II of the BWM Convention has been revised to improve clarity and consistency of Ballast Water Record Book entries, following frequent PSC deficiencies.

Ships are required to adopt the updated BWRB format. Guidance is provided in BWM.2/Circ.80.

Mediterranean Sea Emission Control Area (ECA)

MARPOL Annex VI — MEPC.361(79)
Effective 1 May 2025

The Mediterranean Sea becomes an Emission Control Area (ECA) for SOx and particulate matter. Ships must:

• Use fuel with sulphur content ≤ 0.10% m/m, or
• Operate an approved exhaust gas cleaning system (EGCS)

Hong Kong Convention on Ship Recycling

MEPC.210(63) — Effective 26 June 2025 / 1 August 2025

The Hong Kong Convention applies to ships over 500 GT engaged in international voyages and aims to ensure safe and environmentally sound ship recycling.

Key requirements include:

• Inventory of Hazardous Materials (IHM) required for new ships from 26 June 2025
• Existing ships must comply by 26 June 2030
• Material Declarations (MD) and Supplier Declarations of Conformity (SDoC) required for supplied equipment
• Surveys required throughout operational life and prior to recycling
• Recycling permitted only at HKC-compliant facilities

MARPOL Annex VI — Fuel, Engine & IMO DCS Updates

MEPC.385(81) — Effective 1 October 2025

Key changes include:

• Revised definition of gas and low-flashpoint fuels aligned with the IGF Code
• Bunker Delivery Note (BDN) requirements extended to gas fuels
• Replacement of steam systems with marine diesel engines classified as a major conversion
• Expanded IMO DCS reporting requirements including:
  • Onshore power supplied
  • Transport work
  • Innovative technology installation
  • Laden distance travelled (voluntary)

Ships ≥5,000 GT should update SEEMP Part II accordingly.

BWM Convention — Electronic Record Books

MEPC.383(81)

Amendments permit the Ballast Water Record Book to be maintained electronically, aligning with MARPOL and NOx Technical Code approaches. Guidance is provided in MEPC.372(80).

A ship vetting inspection is conducted to evaluate a vessel’s compliance with international law and industry standards, in order to enable a prospective charterer to determine the suitability of the vessel for their cargo needs

A marine warranty surveyor provides independent third-party technical review and approval of high-value and high-risk marine construction and transportation project operations – from the planning stages through to the physical execution.

The MWS is ultimately part of the project team with the same aim, to complete the offshore operation, loading, and or construction safely and with no undue risks. The competent MWS's that Aaron Right provides, can therefore guide the project on potential methods, what works well and what doesn’t. 

In our role as a marine warranty services (MWS) provider, we at Aaron Right, assure your advanced engineering solutions while meeting planning and efficiency requirements. We apply a risk-based approach focusing on the greatest risks while minimising interference on less critical elements. Aaron Right has contractual leading industry experts,  to support your need for project-specific clarifications.  

Aaron Right marine service experts have issued marine warranty approvals for some of the world's largest field developments and numerous offshore wind farms. As a leading authority, we have developed a comprehensive set of standards, guidelines, and recommended practices for planning and execution of marine operations.

We provide efficient solutions based on the breadth of our organization and global network. 

There is an increased focus on the proper operation of firefighting equipment and cleanliness of Machinery Spaces. Specifically, the following items are consistently noted by Port State Control Officers:

1. Engine Room Water Mist system set in “Manual” mode.

2. Fuel Oil Quick Closing valves blocked open by use of wedges or wires.

3. Pipes insulation laggings wrongly installed, soaked in Fuel Oil or missing.

4. Excessive Fuel, Oil accumulation and Lubrication Oil leaks in Machinery Spaces, Auxiliary Engines, Steering Gear Room or Purifier Room.

5. Inoperable Fixed Gas Detection systems, missing ships procedures on how to test the system, lack of crew knowledge on the proper operation of fixed gas detection systems, ships lacking the appropriate span gas to test the system or not having any span gas available, and missing specific testing equipment (adapter to connect to the sample point, appropriate regulator to hook up to the span gas, inflatable bags to hold the gas).

https://www.liscr.com/sites/default/files/online_library/Marine%20Advisory%2023-2023.pdf

The IMO Maritime Safety Committee (MSC) has issued new requirements related towing and mooring equipment. The requirements are incorporated in the amendments to SOLAS Regulation II-1/3-8 and will come into force on 1 January 2024. The IMO has also issued interpretations on the scope for review by the administration or Recognized Organization (RO).

https://www.dnv.com/news/towing-and-mooring-equipment-update-january-2024-preparation-for-solas-regulation-ii-1-3-8-248367