The IMO Polar Code in force, beginning 1 January 2017: How to comply

As the Polar Code enters into force on 1 January 2017, this Technical and Regulatory News describes which ships and ship types are affected and the steps shipowners and managers should take in order to have their vessels in compliance within the different deadlines.

DNV GL helps to comply with the Polar Code
DNV GL Polar Code Antarctic
Only vessels that intend to operate within the Arctic and Antarctic areas as defined in the Polar Code need to comply with the code.

Relevant for ship owners, managers and yards.


Only vessels that intend to operate within the Arctic and Antarctic areas as defined in the Polar Code need to comply with the code. The areas are as follows:
Arctic: In general north of 60° but limited by a line from Greenland; south at 58° - north of Iceland, southern shore of Jan Mayen - Bjørnøya – Cap Kanin Nos. 
Antarctic: South of 60°.

The safety part of the Polar Code applies to ships certified under SOLAS, i.e. cargo ships of 500 GT or more, and to all passenger ships. 

Ships constructed on or after 1 January 2017 shall comply with the safety part of Polar Code at delivery.

Ships constructed before 1 January 2017 shall comply with the safety part of the Polar Code by the first intermediate or renewal survey, whichever occurs first, after 1 January 2018. 

The environmental part of the Polar Code applies to all ships certified under MARPOL Annexes I, II, IV and V respectively. Existing and new ships certified under MARPOL shall comply with the environmental requirements by 1 January 2017. This means that fishing vessels (that carry MARPOL certificates) will also have to comply with the environmental part of the code, although not carrying any SOLAS certificates.

Documentation Requirements

Polar Ship certificate:

The safety part of the code has design, construction, equipment, operational, training, search and rescue requirements related to the potential hazards of operating in polar regions, including ice, remoteness and severe and rapidly changing weather conditions. It is written in a goal based manner and provides both functional requirements and detailed requirements.

Dedicated document requirement lists will be provided.

All ships:

To obtain the certificate the manager of existing ships should submit the following to DNV GL: 

  • ƒƒReport of an operational assessment with hazards of the intended operations based on the sources of hazards listed in the Code (Hazard analysis)
  • ƒƒA PWOM – Polar Water Operational Manual. The PWOM shall address the challenges found in the Hazard Analysis and document the practical operation of the ship in polar waters.
  • ƒƒDocumentation of systems and equipment (to be) installed in order to comply with the Code and that this is fully functional at the established polar service temperature (PST) for the vessel.
  • Intact stability calculations that include allowance for icing according to the Polar Code Reg. 4.3.

The following design drawings are assumed already approved for existing ships if relevant (i.e. the ship is built to an ice class) but must be submitted and approved for new ships: 

  • For Polar Class category A: Hull drawings/scantlings and scantlings of propeller blades referring to Polar Class 1-5 
  • For Polar Class category B: Hull drawings/scantlings and scantlings of propeller blades referring to Polar Class 6-7

New ships:

Additional requirements:
For Polar Class categories A and B ships the following must be submitted:
  • ƒƒDamage Stability calculation in accordance with the requirements in Polar Code Reg. 4.3.2 

The Environmental requirements (MARPOL related) of the Polar Code:

Existing ships:

Environmental requirements in the Polar Code are operational and therefore the responsibility of the master.
In short these are:
  • P&A manual
    • The P&A manual (where required) need to be amended and endorsed. This can/shall be done by the surveyor at the initial Polar Code survey. 
  • Operational requirements, as:
    • All discharge of oil prohibited (i.e. through 15 ppm OWS)
    • MARPOL manuals and records to take into account operation in polar waters.
    • Sewage discharge restrictions near ice (treated 3nm, untreated 12 nm).
    • Garbage discharge restrictions near ice, 12 nm.

New ships:

Ships of Polar Class category C: No additional requirements 

Ships of Polar Class category A and B (or equivalent ice class):
Documentation to be submitted:

  • With an aggregate oil fuel capacity of less than 600 m3; a tank plan showing that all oil fuel tanks are separated from the outer shell (related to MARPOL requirements of the code).
  • Where oil and noxious liquid substances tanks, double bottom of minimum 760 mm.
Operational requirements:
  • Discharge of untreated sewage from cat A and B cargo ships and passenger ships of all categories is prohibited.


Polar Ship certificate:

Upon verification and approval of the submitted documentation the vessel can be surveyed and the appropriate Polar Ship Certificate can be issued. For existing ships of Polar Class category C. In urgent cases the Polar Ship Certificate may (after document verification and approval at the approval site/office) be issued without survey. In this case, for continued validity of the certificate, an on-board survey should be undertaken at the next scheduled survey. 

The certificate will be harmonized with the validity of the corresponding SOLAS certificate (CCC, PSSC).

Manning and training:

In accordance with Part I-A, Ch. 12, masters, chief mates and officers in charge of a navigational watch shall be qualified in accordance with the STCW Convention and Code (not relevant for ice free conditions).

MARPOL certificates:

At the next IOPP renewal survey the appendix to the IOPP certificate will be reissued with a tick-off mark for compliance with the environmental requirements of the Polar Code. The other MARPOL certificates are unaffected.


Managers are recommended to contact DNV GL to initiate the approval process before the certificate is needed. Managers should perform an operational assessment and develop a PWOM as soon as possible. DNV GL can provide support here as well.



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