Andrew Lemmis questions the regulator’s global role from a lifeboat industry perspective.
Imagine a football match where the referee is paid by the teams and has no power to issue a red card. He can suggest the rules, sure, but it’s up to the players whether to follow them.
Sound absurd?
That’s essentially how the International Maritime Organization (IMO) functions. And nowhere is this more painfully clear than in the regulation of lifeboat systems.
The IMO, the UN agency responsible for maritime safety, sets the rules, but enforcement rests entirely with member states. These same states vote on the rules, fund the organisation, and are expected to regulate themselves. It’s a system built on trust. But when it comes to lifeboats, that trust often feels dangerously thin.
To its credit, the IMO has introduced important measures: MSC.402(96), for professionalising service, and amendments to SOLAS. But regulation is one thing. Enforcement is something else entirely.
Take lifeboat servicing. Only “authorised” service providers are supposed to carry out maintenance. Who decides who’s authorised? The flag state.
Some flags, like the Marshall Islands, outsource their entire registry operation. Others, like Liberia, charge providers up to $300 per lifeboat inspection, with over 5,000 vessels under their flag, that’s millions in fees. But where does that money go? Is it reinvested into stronger oversight or simply collected and just another cost of doing business.
Most flags don’t engage meaningfully at all. They delegate to Recognized Organizations (ROs) or accept approvals from other flags without direct scrutiny. In practice, this means a vessel flagged with Country A might use a service provider approved only by Country B, no consistent oversight, no shared enforcement standard.
And classification societies? While IACS provides some unified requirements, each class society applies its own standards. Application often varies by region, office, or individual surveyor. One vessel’s approval in one port may be challenged by the next surveyor somewhere else.
This inconsistency raises a critical question: how much protection does the IMO framework really offer when its enforcement varies so widely?
Even when progress is made, when new regulations are adopted, challenges remain. To secure consensus, regulations are often broad, with key details left to “Unified Interpretations” or guidance notes. The result is an evolving patchwork of assumptions and uneven implementation.
Then there’s the language itself. The debate between “shall” (mandatory) and “should” (guidance) may seem minor, but the consequences are real. When survival-critical actions are labelled as “should,” compliance becomes optional. In aviation, such ambiguity would never be acceptable.
Representation within the IMO also raises concerns. Influence is often shaped more by politics and budget contributions than fleet size or safety responsibility. And during regulatory discussions, flag states frequently bring external advisors, many with direct commercial interests. While industry input is valuable, this opens the door to conflicts of interest. Those who stand to gain or lose from regulation are helping write the rules.
Transparency? Still limited. Meeting outcomes are published, but working group access is often restricted, and deliberations behind key decisions remain opaque. Critics, including NGOs and seafarer groups, have long questioned whether the IMO’s processes serve public safety or protect private interests.
And what happens at sea?
We see the cycle repeat:
- A lifeboat accident.
- An investigation.
- Recommendations.
- Delayed amendments.
- Years later, similar issues re-emerge.
Inspections vary by flag. Some service providers operate with minimal scrutiny. Crew confidence in safety equipment is often low. And yet, the certificates are still issued.
So, is the IMO fit for purpose?
If its purpose is to create baseline global standards, then yes, it plays a vital role. Without it, we’d face fragmented regulation and greater risks.
But if we expect the IMO to drive fast, independent, and uniform enforcement, to ensure every lifeboat is genuinely fit for purpose, then no, it falls short. The system was never built for that level of oversight.
If we want real reform, we have to ask:
- Should flag states be subject to stronger external audits?
- Should safety-related fees be transparently tied to measurable safety outcomes?
- Should commercial advisors have limits on regulatory influence?
- Should ambiguity between “shall” and “should” finally be resolved?
- Should transparency be a default, not a request?
Until these questions are answered, lifeboat safety, and seafarer safety, will continue to rest on something fragile: trust.
And in this industry, trust alone is never enough.
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