IN 1714 – Inspection of USVs and ROCs

The IMCA eCMID system provides the marine and offshore industry with standardised formats for vessel inspection. It offers a safety management system (SMS) ‘health check’ and can help improve the quality and consistency of inspections, as well as reducing the frequency of inspections on individual vessels through the adoption of a commonly recognised inspection process. Full details can be found at www.ecmid.com.

The system has long offered two inspection templates:

• IMCA M149 (eCMID Vessel Inspection (≥500gt)), and
  
  
• IMCA M189 (eCMID Small Vessel Inspection (<500gt)), previously eMISW for small workboats.

Vessel inspections are undertaken by independent Accredited Vessel Inspectors (eCMID AVIs), who are assessed as competent personnel experienced with the vessel types being inspected, under a scheme operated by the International Institute of Marine Surveying (IIMS). A quality assurance review process is undertaken by IMCA to monitor and improve both the system and inspector feedback.

Aggregated findings covering over 1000 inspection reports is analysed and published in the eCMID database, allowing common risks to be prioritised for vessel operator work, IMCA guidance and other actions.

This supplement explains how USV and ROC inspections differ from traditional vessel inspections in terms of preparation, content, and approach.

2.1   Overview

The ROC inspection is linked to a specific USV inspection, and the two are intended to be used together.

The format follows existing eCMID vessel inspection templates for consistency, using familiar response options: Yes, No, Not Seen, Not Applicable.

Unlike vessel inspections, which are based on clear regulatory requirements and closed questions, USV/ROC inspections involve more open, descriptive questions due to the lighter regulatory framework.

Completed USV and ROC inspection reports should be used alongside the CONOPS and SMS to help Clients assess if the system is suitable for the intended work scope. The inspection does not need to repeat the full detail of these documents.
Report handling, filing, distribution, and storage, follows the standard eCMID process.

Clients must ensure that:

• the inspector is briefed on what is required
  
  
• appropriate operator personnel are available at the ROC and USV during the inspection.

These inspections are designed for USVs under 24 m, as per the MASS UK Code of Practice and Workboat Code Annex 2. They can be applied to smaller or larger craft, but their relevance may reduce outside that range.

2.2   Structure of the Inspection

Separate inspection reports are required for the USV and its associated remote operation centres (ROCs). The USV inspection report is the primary document.

The USV inspection confirms that onboard systems and equipment – also detailed in the ROC inspection – are present and operational. It includes checks on local personnel (e.g. maintenance staff or local operators) to verify their understanding and use of Safe Systems of Work such as PTW and risk assessments. The Inspector should also assess the USV as a safe working environment, including signage, lockouts, and fire systems.

The ROC inspection focuses on the remote operation of the USV. It covers:

• procedures, records, and vessel documentation normally found on the bridge
  
  
• control and communication systems between ROC and USV
  
  
• training, qualifications, and competency of personnel both at the ROC and USV
  
  
• redundancy and cybersecurity aspects (more detailed than traditional CMID).

ROCs may be fixed, local, or remote. A local ROC may only support port transits or maintenance and may lack full documentation. The Inspector must identify all ROCs and inspect each appropriately, confirming control redundancy and that qualified personnel are always supervising the USV.

Both the USV and the ROC must be “live” during their respective inspections to demonstrate control and communication. The USV need not be underway or even afloat but must be operational.

Inspections can be carried out in any order and by different Inspectors, but the second Inspector must review the earlier report for consistency.

If the USV occasionally operates with crew onboard, applicable elements of IMCA M189 should also be considered.

2.3   Client Responsibilities and Inspection Preparation

The client may be the USV operator or a company that has contracted the USV for a specific task. The client must inform the Inspector of:

• the regulations and guidance they want applied during the inspection
  
  
• the USV’s intended work scopes (e.g. operating near structures, use of emergency anchoring).

The inspector should clarify that USV/ROC inspections are descriptive, not prescriptive, to help the client assess whether the USV is suitable for its intended role.

The client or operator must provide the CONOPS (or equivalent), which outlines the systems and operations of the USV and ROC, including the safety management system. This should accompany the inspection report to reduce repetition.

If an ROV audit is required, the client must advise the inspector. This is covered by IMCA R006 and applies to ROVs remotely operated from a ROC (which may differ from the main USV ROC).

Similarly, there is a Survey Supplement in both USV and ROC inspections. If survey systems are used, the Client must inform the Inspector and clarify if the Survey ROC is separate. Alternatively, a dedicated IMCA S016 audit may be requested for survey spreads.

Finally, the client, operator, and inspector must coordinate the inspection schedule, ensuring qualified personnel are available at both the ROC(s) and USV during inspections.

2.4   Inspector Competence and Accreditation

2.4.1 IMCA Policy

Inspector competence and accreditation is a key part of delivering a consistently good eCMID inspection report. However, USV technology is new and fast developing so the process of becoming an Accredited USV or ROC Inspector is still under development. It is likely to eventually mimic the process for accreditation of a vessel inspector.

2.4.2 Accredited Inspector Scheme

It will be necessary for a USV or ROC Inspector to be an Accredited Vessel Inspector (AVI).

In the short term, IMCA will implement a competency scheme based on knowledge of USV and ROC guidance documents produced by different organisations in different countries. This may lead to an inspector being only competent to inspect a USV and ROC for offshore operations in countries where the inspector has knowledge of their USV/ROC regulation and guidance. It may be necessary for an inspector to acquire specific knowledge on some technical aspects of USV and ROC systems – specifically cybersecurity and/or computer networks.

2.5   Inspection Findings

The regulatory framework (international/national/regional) for uncrewed surface vessel (USV) operations is still in its infancy. At this stage, there are no universally recognised international regulations from International bodies such as IMO or EU, and only limited guidance exists from flag states. Consequently, inspections cannot be based solely on compliance with specific regulations or legislation, as these are not yet fully established.

Instead, inspection findings can:

1. Provide descriptive information: Clearly describe the systems, processes, and operational setups in use. This includes detailing how these align with best practices, industry standards, and available guidelines provided.
   
   
2. Apply judgement based on guidelines: Evaluate the degree of compliance with existing recommendations and guidelines issued by professional bodies and regulatory authorities. This requires inspectors to exercise informed judgement, considering the context and intent behind the guidelines.
   
   
3. Acknowledge the evolving landscape: Recognise that full compliance with formalised regulations may not yet be possible. Instead, focus on identifying good practices and areas for improvement in preparation for forthcoming regulatory frameworks.

2.6   Inspection Templates

2.6.1 M270 – USV Inspection

IMCA M270 provides voluntary guidance and does not direct or require members to act in a particular way. Members must make their own independent decisions and follow all applicable competition laws. Nothing in this document should be seen as influencing prices, customers, suppliers, or other competitive matters. The adoption of this inspection format is voluntary and does not constrain members’ use of alternative practices consistent with applicable law.

The Inspector should perform the USV audit in the knowledge that a manned ROC controls the vessel and will have the SMS and CONOPS documentation for the USV. The USV audit will be of the vessel and its equipment that are controlled by a ROC. Inspection of the USV’s documentation will be carried out as part of the ROC inspection.

The USV may have an ROV, AUV and/or Survey spread installed which may be controlled from a ROC in a different location from the USV ROC. The requirement to include an ROV, AUV or Survey spread in the USV inspection should be defined in advance of the inspection.

The USV need not be under the control of an ROC at the time of the inspection. However, sufficient personnel should be present in the ROC to prove USV equipment and systems are working. There will also need to be personnel familiar with the USV at the USV to respond and provide the evidence to the Inspection points. These personnel may take the role of vessel master in receiving the findings of the inspection if the master in the ROC is not available for a meeting.

2.6.2 M271 – ROC Inspection

A remote operations centre (ROC) for uncrewed surface vessels (USVs) is a shore-based facility where operators monitor, control, and manage USVs during their missions. It provides the necessary communications, situational awareness tools, and control systems to enable safe and effective remote operation, including navigation, payload management, and emergency intervention. The ROC acts as the central hub for human oversight, typically supporting semi-autonomous or fully autonomous vessel operations.

A ROC may include redundancy of USV control systems or achieve redundancy by use of a secondary ROC which will need to be included in the inspection. Similarly, there may be a temporary and/or mobile ROC at the USV port. This needs to be inspected with appropriate rigour for its role in controlling the USV.

The ROC need not be controlling the USV at the time of the inspection and therefore not be fully manned. However, sufficient personnel should be present to respond and provide the evidence to the Inspection points. There will also need to be personnel at the USV so that its systems can be operated from the ROC.

There is little internationally accepted regulation of USVs and ROCs. National and international regulatory authorities are developing regulation at different pace and to different detail.

Authorities and organisations, including IMCA, have published guidance documents outlining requirements that are likely to be reflected in future regulations.

A lot of the guidance for USVs and ROCs is based on vessel and marine regulation adjusted for unmanned and uncrewed operation.

IMO is developing a code for MASS which is expected to be ready for non-mandatory use from May 2025, leading to a Mandatory MASS Code being introduced in 2030 and entering into force in 2032.

3.1   Applicability of National Regulation and Guidance

It is not clear what regulation and guidance would apply for a USV working in one country’s waters whilst under the control of a Master based in a ROC in another country.

The Inspector should establish from the Client the location of the USV’s operations and the location of the ROC that will control the USV – and which regulations and guidance documents to apply in the inspections.

3.2   Reference Regulations and Guidance Documents

Inspectors should be familiar with the documents listed below. It is assumed that Inspectors are fully conversant with regulations and law, such as SOLAS and COLREGS, governing conventional vessels.

The USV and ROC inspection documents are based on transferable questions from M149 and M189. These are supplemented by questions mainly based on the requirements of the UK MASS Code and UK Workboat Code Annex 2. Guidance documents issued by other countries may have different requirements. The Inspector(s) shall provide the responses to the questions in the inspection document(s). It is the responsibility of the Client to decide if the USV and ROC is acceptable for the work scope and work location.

National regulatory bodies are introducing or updating their guidance and regulation for USV operations. IMCA will periodically update the applicable references but Inspectors should follow the Client’s requirements as to the basis for the inspection.

Table 1 – Current list of available relevant industry documents

Doc Ref	Title
IMCA M149	eCMID Vessel Inspection (≥500gt)
IMCA M189	eCMID Small Vessel Inspection (<500gt)
IMCA M257	Safe and efficient use of an uncrewed surface vessel (USV)
IMCA C002	Guidance on competence assurance and assessment: Marine Division
IMCA C017	Guidance on competence assurance and assessment: Marine roles for small workboats
IMCA IN 1508	Cyber security considerations for autonomous and remotely controlled systems
MASS Code	Maritime Autonomous Ship Systems (MASS) UK Industry Conduct Principles and Code of Practice
MGN 702	Maritime and Coastguard Agency – Marine Guidance Note 702 General Exemption
MGN 705	Maritime and Coastguard Agency – Marine Guidance Note 705 General Exemption – ROUVs of 2.5 metres to less than 4.5 metres in length overall
Australian Maritime Safety Authority	Guidance Notice – Small unmanned autonomous vessels
UK MCA Workboat Code Edition 3 Annex 2	Maritime and Coastguard Agency, The Workboat Code Edition 3, The safety of small Workboats and Pilot Boats – a Code of Practice, Annex 2 Remotely Operated Unmanned Vessels
Dutch USV Guidance	Project 21.118 Doc 000.111Rev D Technisch kader varende drones (Technical Requirements for USVs)
Dutch USV Guidance	Norwegian Maritime Authority – Guidance in connection with the construction or installation of automated functionality aimed at performing unmanned or partially unmanned operations
Norwegian RSV-12-2020	Norwegian Maritime Authority – Guidance in connection with the construction or installation of automated functionality aimed at performing unmanned or partially unmanned operations
Brazil NORMAM-205/DPC	Normas da Autoridade Marítima para Embarcações Autônomas
IMO MSC.1/Circ.1455	Guidelines for the Approval of Alternatives and Equivalents
IMO MSC.1/Circ. 1683	Outcome of the Regulatory Scoping Exercise for the Use of Maritime Autonomous Surface Ship (MASS)
BIMCO SmartCon	AUTOSHIPMAN – Contract for operation of remotely controlled or autonomous ships
UNCLOS	United Nations Convention on the Law of the Sea

 

BLOS	Beyond line of sight
Client	Organisation commissioning the Inspection
CoC	Certificate of competence
CONOPS	Concept of operations – detailed description of USV and ROC
Crewed	Personnel on a USV to operate marine/vessel systems
Cy	Cybersecurity
CyO	Cybersecurity officer
DPA	Designated person ashore (ref ISM)
eCMID	electronic Common Marine Inspection Document
ESS	Energy storage system
LOS	Line of sight
MASS	Maritime autonomous surface ships (synonym for USV)
Manned	Personnel on a USV to operate systems other than marine/vessel systems
NA	Not applicable
NS	Not seen
Operator	Organisation/company operating the USV and ROC
OTH	Over the horizon
RCC	Remote control centre (synonym for ROC)
ROC	Remote operations centre
SME	Subject matter expert
SMS	Safety management system
USV	Uncrewed surface vessel

For more information, please contact Richard.Purser@imca-int.com.