Law360, New York ( September 22, 2014, 1:02 PM EDT) -- "Effective Implementation" is the 2014 theme at the International Maritime Organization. As the IMO nears adoption of a mandatory code to regulate ship operations in polar waters, the decision to implement this scheme under a streamlined entry-into-force process reflects how IMO decision makers may define effective. Substantive changes to IMO conventions can take 10 or more years to enter into force under explicit ratification procedures. But "tacit acceptance" allows technical changes to take effect and bind contracting states much more quickly — absent a specified measure of objection.[1] A broad new regime to govern ship operations in the Arctic and Antarctic arguably represents new substance, but the IMO set up the draft Polar Code as technical amendments to existing conventions. This raises legitimacy concerns because the Polar Code seems to contain both substantive and technical requirements....