Lloyd's Form and the Montreal Convention

For more than seventy years the 1910 Brussels Convention on Salvage has withstood the test of time. It had bestowed upon it that rare accolade for international conventions, ratification by the United States of America. It might well have gone on to complete its century, had not the steering failed on the Amoco Cadiz in March 1978, whose subsequent grounding and oil pollution made front-page news throughout the world and brought the subject of salvage into sharp focus. The pressure for change in the law of salvage, and the search for solutions to contemporary problems, has evidenced itself in two ways. First, Lloyd's Salvage Agreement has had important additions made to its traditional form. Because of its worldwide use in major salvage cases, Lloyd's Form may fairly be said to have a quasi-convention status. Second, the Comitè Maritime International (CMI), at Montreal in May 1981, produced a new Draft Convention on Salvage. It is with these two instruments of change, and the interaction between them, that this paper is concerned.