A defence of the International Maritime Organization

Greg Atkinson reckons much of the criticism aimed at the IMO is misguided.

In recent months there has been an ever increasing and broad range of criticism directed towards the International Maritime Organization (IMO), much of which ranges from being mildly critical to downright brutal. Often though, these criticisms highlight that some people appear to have a poor understanding of what the IMO is and what it can, and cannot do.

Before proceeding allow me to state, by means of a disclaimer, that I am not employed by the IMO nor have I ever worked for the organisation. Furthermore, I have a natural aversion to bureaucracies in all their forms and at times, the pace at which issues seem to be processed via the IMO has also frustrated me. But this type of criticism could be directed at most large organisations, complex project structures or bodies dealing with complicated issues. Simple but wrong decisions can often be made quickly, but making correct decisions for more complex problems can often require more time.

Before expressing their displeasure with the IMO some companies could review the skills diversity of their own senior management teams

It’s important to note that the IMO is not a shipping or ocean policy enforcement agency. Rather, it is the Member States (currently 174) that need to take the necessary actions after a treaty or regulation is ratified. The IMO could for example only introduce a blunt instrument such as a carbon trading market similar to what the European Commission is suggesting for shipping, if this were agreed upon by the Member States since the IMO itself, is an organisation of Member States and its activities are controlled by them.

To improve my understanding of how the IMO functions I submitted several questions to them (via e-mail) and in response, Natasha Brown from IMO Public information Services, was kind enough to set-up a short online meeting with Frederick Kenney, director, Legal Affairs and External Relations Division.

During this meeting I came to understand that the IMO formulates the following:

  1. Treaties – these include the Safety of Life at Sea (SOLAS) & International Convention for the Prevention of Pollution from Ships (MARPOL). Treaties cover five categories; safety, environment, security, liability and compensation, pollution response and search & rescue.
  2. Protocols – amendments to treaties.
  3. Regulations – which are binding and form part of a treaty. These are often included in the annexes to the treaty since this makes it less complicated to make any necessary future amendments.
  4. Codes – these include the International Ship and Port Facility Security Code (ISPS) and International Code for Ships Operating in Polar Waters (Polar Code).
  5. Guidelines – these are recommendations. Over time these may become the industry standard.
  6. Circulars, explanatory notes, unified interpretations.

These treaties, protocols and regulations may be the result of discussions and deliberations related to scientific research and studies, but the IMO itself is not a scientific body. This is an important point because in science the aim is to discover the truth and this is not determined primarily by agreement, but via experiment and observation. On the other hand, policy decisions are often reached via negotiation and compromise. In other words, a good policy is not the same as good science and vice versa. Therefore, in my opinion we should consider that the output of the IMO might be primarily based on scientific research, but that’s not a certainty due to the negotiations that may have been required to reach consensus amongst the Member States. Consequently I believe there should be some form of independent science-based review of proposed treaties, protocols and regulations when required. But that could be a complicated process and further delay the implementation of new policy initiatives.

In regards to how the IMO functions I often read comments from senior executives at shipping companies complaining that amongst other things, the IMO is not moving quickly enough to implement measures aimed at decarbonisation (whatever that means) or reducing emissions. These criticisms puzzle me for two main reasons; firstly, there is no force of nature that I’m aware of that has prevented ship owners proactively reducing vessel emissions and/or improving energy efficiency and to the credit of some, they have been doing this for years. I am also not aware of any IMO related reasons why the uptake of digital technologies across shipping has lagged behind other sectors and dare I suggest (and I do), that one reason for this may be due to the lack of relevant technology knowledge and experience amongst the ranks of shipping executives. So before expressing their displeasure with the IMO perhaps some companies could review the skills diversity of their own boards and senior management teams?

Secondly why do some companies, organisations and lobby groups direct their angst mainly towards the IMO alone and not at the Member States or even classification societies? Perhaps shipping companies could also engage more with the IMO rather than simply being critical when the IMO doesn’t move in the direction or at the speed they prefer? This also might be more productive than forming associations (that are often essentially lobby groups) to promote specific solutions and hire PR consultants to engage in a war of words with those who don’t share the same views.

Based on my experience it’s often been shipowners that have been reluctant to embrace emerging technologies or take part in joint research and development (R&D). Some of the loudest critics of the IMO for instance could have focused their efforts on supporting R&D at start-ups or conducting trials of new technologies as opposed to making frequent appearances on discussions panels to talk about what needs to be done…by somebody.

I’m not suggesting though that the IMO does not need to improve, make changes and adapt to a world where technologies evolve quickly, however the same could be said for most organisations and companies. When the workings of the IMO elicit criticism, then these criticisms should be made, but let’s be sure we are directing our comments in the right direction and also when possible, suggesting some ideas that will help improve how it functions.


  1. Thank you for that succinct description if the IMO which was more than I had hoped it would be. It was very amusing as well as informative. I hope not too many noses have been put out of shape.

    1. Thank you David. I was just trying to outline things as I see them in an objective way. Of course others will see things differently and that’s of course all good in a rationale debate & discussion.

  2. This should be said more often. It is the same thing with the International Labour Organisation (ILO) and the MLC, where I did my research. These organisations are secretariats (on their own, if this can be said). Decisions are made by members states, the same countries where ships are flagged, owners reside and establish businesses. They look for the ones with the least “resistance.” Countries negotiate these treaties and sign, but do not necessarily ratify. Or they ratify but do not have the necessary regulations for a myriad of reasons. The only means of “compliance” for these organisations is name and shame, and the IMO less so when compared to for eg. the ILO. It is all down to Member States (horizontal governance) to ensure these treaties work by self-policing and policing each other to the extent they can (for eg. with Port State Control). Negotiated compromise does not necessarily deliver treaties that are fit for purpose but to suit the negotiators. As for the article above, if the shipowners who complain want to see differently they have the power (money) and status to form, joint organisations and lobby in their countries and cross boarders for changes at the international level.

    1. Thanks for your comment Carolyn. If there is no international organizations that discusses these issues then what’s the alternative? Of course some of these organizations need to be improved and some reformed, but let’s be fair with our criticisms, I don’t know much about the International Labour Organisation (ILO) by the way so I’ll have a look into that.

  3. The last year has produced a lot of criticism among the members of the shipping community, in the way the Crew Changes crisis has been dealt with.
    Attention has been drawn to Heads of State and the need for them to declared Seafarers as Keyworkers and to open their borders for Seafarers to return home or go back to their ships .
    I assume ( and hope so) that most of the IMO representatives have been lobbying within their countries for Crew Changes, for Vaccines, for opening borders, so Seafarers can go home, unfortunately they have not been successful.

    Heads of States and Shipping Ministers usually appoint an Ambassador and a Delegation to IMO to represent their country and discuss shipping matters.
    They are probably NOW while I am writing this, drawing up plans, strategies and exchange votes, etc, for the campaign for the next elections to the IMO Council in Nov-Dec 2021; engaging also their Foreign Affairs Ministries.
    We may see in few months that countries that have closed their borders completely preventing Seafarers returning to their homeland, may retain or get a seat on the Council .. this is morally wrong .. Countries that have abandoned their Seafarers ….. they do not deserve a seat to steer IMO.

    1. Hello Marina. The crew change crisis is one of those issues I’d be booking looking very hard at the Member States especially the nations that control the major ports. I’m a bit mystified myself how thousands of people can fly to Japan for the Olympics including the news media and yet we can’t seem to get pathways open for the ship’s crew to move. The lock-down mentality in many countries also isn’t helping

  4. Well said and about time that someone started to hit back at the tactic, used by many different players, to attack the IMO rather than the real “culprits”. As you say IMO is simply a secretariat without teeth. Nothing should deflect from the responsibilities of those who own and operate the ships, and those government members of IMO, especially those who are represented by shipping companies or collective shipping industry representatives – which is where I would have to disagree with your assertion that shipping companies need to engage more. Owners and builders have some weighty government voices fighting their corner already.
    I am not so sure why you reference Classification Societies in the way you do in your article. Nothing is perfect but they do, through their membership of IACS, tend to contribute the most in terms of technical veracity and consistency, albeit without a single vote amongst the many flag states (good, bad, or “pretend” that do.

    1. It is currently very trendy with those of a particular political bent to criticise the UN and all its agencies. Sadly the weak of mind and bigots believe what they say.

    2. Hello Olav. I mentioned the Classification Societies because they also need to move quickly so that we can get new technologies out there. Sometimes they appear a little slow to move ahead with the required design guidelines for example. But I’ll be writing more about that in the future when I get time 🙂

      1. Having been a Class surveyor I can confirm Classification Societies tend ti be tardy. They speeded up for a few years but seem to have gone back to wind again.
        Look forward to reading your take.

  5. A long time observer of the IMO has often said the IMO will change when either one of two things happens. The first a band of angels descends on the IMO, replaces the staffing, provides transparent leadership as well as innovative sustainable honest technical expertise. The second would be a miracle. The IMO has so corrupted the language and process that seafarers understand the IMO’s raison d’etre to be the protection of the IMO’s status quo. Nexus of owner to flag? Owners Flag and Class hopping? Insurers blind eye? Banks financing the unsustainable? What is and where is the beneficial owner? The 12 largest flag states are responsible for 80% of the world’s shipping tonnage, the top 25 beneficial owner countries have 80% of the tonnage and together they own the IMO’s agenda? Ships slip under the radar until they end up on a reef, rocks or breaking in two. Under regulated, resistant to change and overly adept and reliant on playing the injured party. The IMO is an anachronism. A 19th century model that belongs in a case study of how not to regulate international shipping.

      1. Like Mr Walsh, I am very familiar with the regulation of international shipping and the ineffective role of the IMO. Trade groups, flag states, or some select enlightened owner/operators might try to improve some practices in their fleets but the minimum standards are the real problem and these never improve because the IMO is in the way of change because of their perceived authority. The unfortunate perception is if the IMO is not effectively regulating it, then it doesn’t need better regulation.

        1. Unike Mr Walsh, who has a money making axe to grind, I am very familiar with the regulation of international shipping.
          Interesting that you two just happen to have exactly the same address isn’t it.
          You obviously know little of the history of maritime safety and te IMO. As I posted earlier “It is currently very trendy with those of a particular political bent to criticise the UN and all its agencies. Sadly the weak of mind and bigots believe what they say.”

          1. David good afternoon. I do hold the author of the article in high regard. He is both principled and honest. The IMO not so much. I’ve reread the article
            a few times – my representation of the second largest open registry at the IMO informs my observations. My first hand response to ship board abandonment and in person discussions with ship owners colors my take of the IMO’s lack of leadership. My ship visits and discussions with seafarers from most maritime nations provides a unique perspective. Not all knowing. Just well informed by the people most impacted. Regarding “address sharing” believe that might be due to the site’s posting requirements. As for “money making axe to grind” full disclosure no monetary/financial interest what so ever – I’m retired. In business one can hope that things will get better – pouring good money after bad; digging a deeper hole and the sunk cost bias. The IMO system – according to honest owners, doesn’t work. Responsible owners want a level playing field and the IMO hasn’t provided that. Best Jim

    1. “Regarding “address sharing” believe that might be due to the site’s posting requirements. ” Really? That proves how dishonest you are.
      111 N Belcher Road, Suite 204, Clearwater. has nothing whatsoever to do with the site.
      I do have a little bit of experience in the industry, as Class, flag state, P&I/H&M surveyor, expert witness and so ob. and sailing as Master on various kinds of ship.
      ” I’m retired.” At Global Group. OK. Very retired.
      Sorry, Jimbo, you’re not even good at being superior or dishonest.

      1. David thank you for pointing out that the address of ActGlobal for the US office is out-of-date. The new address is 1617 Beacon St. NSB Florida. The address was changed two years ago and the new address can be found in the Florida.Gov business licenses. As for retired from “working” for AGG you can check with my wife on that. Regarding your resume; did someone challenge your bona vides? The only personal attacks on this thread are the ones you have made. David I’m curious where and what ships did you ship as Master? And were you an employee of which Class society, which flag administration?
        Best Jim

        1. David thank you for pointing out that the address of ActGlobal for the US office is out-of-date. The new address is 1617 Beacon St. NSB Florida. The office address was changed two years ago and the new address can be found in the Florida.Gov business licenses. The web site has been updated. It was my understanding that the “address” you and I were referring to at first was the IP address of my submission. My mistake for jumping to a conclusion. As for retired from “working” for AGG you can check with my wife on that. Regarding your resume; did someone challenge your bona fides? The only “personal” attacks on this thread are the ones you have made. I’m curious, based on our backgrounds we probably have more in common than not. The welfare of seafarers, the sustainable operation of merchant shipping, responsible good governance… Where we disagree may just be how we see the process not the people. Our backgrounds shipping as Master yes? Working with Class on their technical committees yes? Driving innovation in the teams we’ve led; all would indicate that our hope for the future of shipping is similar. We differ on how to reach the goal and what needs to be done to break the status quo… Different perspectives make the world an interesting place. Would gladly discuss off line any points. All the best Jim

    2. Hi Jim. As I mentioned in the article I am not suggesting that the IMO could not be improved & perhaps greater transparency into how it operates & how decisions are reached might be some of the areas that need to be looked at. But I think we also have to appreciate that the Member States control its activities and so perhaps we also need to focus more on their actions as well?

      1. Greg thank you for the note. I believe I understand your perspective regarding the IMO. If i may, the IMO can be salvaged. Mine perspective is different. I’ve been in the meetings where Members/Flag, PSC, and Class suborn the whole premise of good regulatory process. Have seen the how the on board safety and environmental standards are further diluted as a solution to responsible regulation. The owners/flag/members pay for the IMO. It is the reason why the EU and other responsible governments are fed up with the organization. As built it doesn’t work. The seafarers deserve better. Responsible owners deserve a level playing field. Time to move a global maritime legislative/regulatory body into the 21st century. My opinion. Best Jim

        1. Hi Jim. I’m open to all suggestions but generally it works like this: if an organization makes decisions & can enforce them then people are happy if it’s the decisions they agree with, otherwise they start complaining that it has too much power & it’s being authoritarian. I’d probably struggle to deal with 174 Member States and keep my sanity but what’s the alternative? Remove some to streamline the process? Or perhaps just go with a majority vote, but then what will the Members States do that didn’t approve of a treaty? Or maybe we should be turning the spotlight around and be looking more closely at the actions of the Member States?

  6. If ever there was a sober assessment of the IMO’s true nature, this is it! Many observers do not appreciate the fact that the IMO has no enforcement role, only the member states have the authority to enforce the instruments agreed at the IMO, and that enforcement cannot happen until the respective member states themselves enact and apply related national laws.
    Once explained, that should make sense – but it’s more complicated. Where to begin? How about this; A major player at the IMO, the United States, is often criticised for not ratifying UNCLOS. Such criticism might be justified – but there is another side to the story. With so much attention on protecting the marine environment, other than the US, how many other IMO member states have prosecuted vessel operators employing the “magic pipe” trick? I reckon it is a short list, probably in the single digits.
    Much good work is done at the IMO, and the staff at the IMO Secretariat is dedicated and hard-working. A constant hurdle hampering the effectiveness of the efforts made at the IMO is a lack of enthusiasm amongst many member states in enforcing measures that have been agreed.
    Meanwhile, as the public becomes increasingly concerned with the impact of climate change, there is a possibility that national governments will be pressured to take unilateral steps that include measures impacting merchant shipping if IMO member states fail to deliver and enforce effective global measures.
    Does this possibility keep any of the delegates representing the 174 member states awake at night? That’s a question only they can answer.

    1. Hi Thomas. In addition to my mislocated comment elsewhere I do think looking at the past actions of the Member States in more detail would be very interesting. I wonder if there are any public records available of how each of them acted after a Treaty etc was ratified?

  7. Thanks Thomas for adding a few points that I did not cover. Action by the Member States to address things like the “magic pipe” trick is a good example and perhaps I should have mentioned that there is no force of nature prevent them from being proactive either.

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