Sub-Committee on Ship Design and Equipment (DE), 44th session: 5-9 March 20

44th session: 5-9 March 2001

New draft SOLAS regulation on access to spaces in cargo areas agreed

A draft revised SOLAS regulation aimed at improving surveys of large bulk carriers and tankers has been agreed by IMO’s Sub-Committee on Ship Design and Equipment (DE) at its 44th session.

The proposed revised regulation II-1/12-2 is intended to ensure that vessels can be properly inspected throughout their lifespan, by designing and building the ship to provide easy access. Without adequate access, the structural condition of the vessel can deteriorate undetected and major structural failure can arise.

The proposed revised draft regulation is based on a proposal by the Bahamas developed in response to the Erika incident and focusing on the fact that the continued adequacy of the strength of large bulk carriers and tankers depends on their being properly surveyed - which requires action at the design stage.

Currently, SOLAS chapter II-1 (Construction – structure, sub-division and stability, machinery and electrical installations), Part B (Subdivision and stability), regulation 12-2 specifies requirements for access to spaces in the cargo area of oil tankers (only) including cofferdams, ballast tanks, cargo tanks, etc. The minimum dimensions of horizontal and vertical openings are set out.

However, although the access to spaces in the cargo area should be sufficient to ensure their complete inspection, evidence from current ship designs suggest that a lack of detailed requirements is preventing the regulation from being fully and consistently implemented.

According to the Bahamas submission, despite the well-thought-out recommendations of the Organization, ships continue to be built with little consideration as to how they will be surveyed by flag State inspectors and classification society surveyors during their in-service life or how the crew will be able to monitor the condition of their own ship. Without adequate access, the structural condition of the vessel can deteriorate undetected, and major structural failure can arise. A comprehensive approach to design and maintenance is required to cover the whole projected life of the ship.

It has long been recognised that the only way of being assured of the adequacy of a ship’s structure is for all its components to be surveyed regularly to ensure that they are free from damage such as: scantling reduction; cracks, buckling or deformation due to corrosion, overloading or contact damage. The provision of a suitable means of access to the hull structure for the purposes of carrying out overall and close-up surveys and inspections has not been included in the Conventions, although the need to provide access has been mentioned or envisaged in several IMO instruments. Classification society rules also do not include provision for proper access.

Proposed draft regulation

The proposed draft revised regulation SOLAS II-1/12-2, on Access to and within spaces in the cargo area of oil tankers and bulk carriers is intended to apply to new ships (size and date of construction to be decided by the Maritime Safety Committee).

The regulation would require each space within the cargo area to be provided with a permanent means of access to enable, throughout the life of a ship, overall and close-up inspections and thickness measurements of the ship’s structures to be carried out by the Administration, the Company, as defined in regulation IX/1 and the ship’s personnel and others as necessary.

The Sub-Committee also prepared draft Technical provisions for means of access for inspections which would be mandatory under the new regulation for further consideration at DE 45.

Where permanent access was difficult, the Administration may allow, in lieu, the provision of portable means of access such as staging, moveable platforms and ladders, provided the means of attaching, rigging, suspending or supporting the portable means of access forms a permanent part of the ship’s structure.

The regulation would require the ship’s means of access to carry out overall and close-up inspections and thickness measurements to be described in a Ship Structure Access Manual to be kept on board.

The regulation would also include General technical specifications, while specifics would be included in the technical provisions.

The draft revised regulation will be put forward to the MSC for approval and subsequent adoption, with possible entry into force planned for 2004.

Other post-Erika issues

The Sub-Committee reviewed a number of issues relating to the elimination of substandard ships referred to it by the MSC for preliminary assessment.

The Sub-Committee agreed that consideration of protection of fuel tanks should be included in the DE Sub-Committee’s work programme since leaked fuel oil presented a real hazard.

The Sub-Committee agreed that the proposed measure to review resolution A.744(18) on the enhanced programme of inspections during surveys of bulk carriers and oil tankers, to make survey procedures stricter, could be accommodated within the current ongoing review of the resolution.

Draft amendments to enhanced survey guidelines agreed

The Sub-Committee agreed draft amendments to Assembly resolution A.744(18) (as amended) - Guidelines on the Enhanced Programme of Inspections During Surveys of Bulk Carriers and Oil Tankers, for submission to the MSC.

The amendments are intended to align the Guidelines with revisions to International Association of Classification Societies (IACS) Unified Requirements (UR) Z10.1 and Z10.2. The revisions to the Unified Requirements were based on the safety measures taken by IACS following the Erika incident. IACS Members have agreed to implement those measures from 1 July 2001 at the latest.

Draft asbestos guidelines agreed

The Sub-Committee agreed a draft MSC circular on Guidelines for maintenance and monitoring of on-board materials containing asbestos for submission to the MSC.

The draft circular is intended to provide guidance to the Administrations, companies, seafarers and others closely involved with the operation of ships, on how to deal with asbestos on board ships in service with the principal objective of minimising exposure to asbestos fibres of passengers, crew, riding crews, maintenance personnel in port, etc., while the ship is in service.

The MSC in December 2000 adopted amendments to SOLAS to prohibit the new installation of materials which contain asbestos on all ships.

Improved thermal protection – draft guidelines agreed

The Sub-Committee agreed draft guidelines aimed at improving thermal protection and covering inspections of immersion suits and anti-exposure suits.

The draft MSC Circular on Guidelines for the assessment of thermal protection is intended to address the need for systematised guidelines for thermal protection of crews and passengers according to environmental factors and for appropriate performance standards for additional thermal protective equipment. The purpose of these guidelines is to provide information to assist in assessment of the impact of environmental factors, and specifically water temperature on equipment selection

The draft MSC Circular including draft Guidelines for monthly shipboard inspection of immersion suits and anti-exposure suits by ships’ crews gives recommended procedures for carrying out monthly inspections of these suits in accordance with SOLAS regulations III/20.7 and III/36.1.

Draft guidelines on fuel oil sampling agreed

The Sub-Committee agreed draft guidelines for the sampling of fuel oil for determination of compliance with Annex VI – Regulations for the prevention of air pollution by ships of MARPOL 73/78, together with an associated draft MEPC Circular, for submission to MEPC 46 in April 2001 for approval. The primary objective of the Guidelines is to establish an agreed method to obtain a representative sample of the fuel oil for combustion purposes delivered for use on board ships.

Regulation 18(3) of Annex VI to MARPOL 73/78 requires details of fuel oil for combustion purposes delivered to, and used on board the ship, to be recorded by means of a bunker delivery note.

Draft Guidelines for Ships Operating in Arctic Ice-covered Waters

The Sub-Committee agreed draft Guidelines for Ships Operating in Arctic Ice-Covered Waters and an associated draft MSC/MEPC Circular, pending input from other Sub-Committees.

The Guidelines are aimed at ensuring safe navigation of ships and the prevention of pollution in Arctic waters. Ships operating in the Arctic environment are exposed to a number of unique risks. Poor weather conditions and the relative lack of good charts, communication systems, and other navigational aids pose challenges for mariners. The remoteness of the areas makes rescue or clean-up operations difficult and costly. Cold temperatures may reduce the effectiveness of numerous components of the ship, ranging from deck machinery and emergency equipment to sea suctions. When ice is present, it can impose additional loads on the hull, propulsion system and appendages.

The Guidelines are therefore intended to address additional provisions deemed necessary for consideration beyond existing requirements of the SOLAS Convention in order to take into account the climatic conditions of Arctic ice-covered waters and to meet appropriate standards of maritime safety and pollution prevention.

The draft Guidelines cover design, outfitting and operation of relevant ships, including crewing by adequate numbers of suitably trained personnel.

Emergency towing guidelines – amendments agreed

The Sub-Committee agreed draft amendments to the Guidelines for emergency towing arrangements on tankers (resolution MSC.35(63)) to bring the guidelines into line with the amendments to SOLAS regulation II-1/3-4 adopted by the MSC at its 73rd session in December 2000.

The revised SOLAS regulation II-1/3-4 states that - as per the current regulation -emergency towing arrangements should be fitted at both ends on board every tanker of not less than 20,000 tonnes deadweight.

For tankers constructed on or after 1 July 2002:

  • the arrangements shall, at all times, be capable of rapid deployment in the absence of main power on the ship to be towed and easy connection to the towing ship. At least one of the emergency towing arrangements shall be pre-rigged ready for rapid deployment; and

  • emergency towing arrangements at both ends shall be of adequate strength taking into account the size and deadweight of the ship, and the expected forces during bad weather conditions. The design and construction and prototype testing of emergency towing arrangements shall be approved by the Administration, based on the Guidelines developed by the Organization.

Work on lifeboat accidents needed, says Sub-Committee

The Sub-Committee agreed to request the MSC to include a new work programme item on measures to prevent accidents with lifeboats, following submissions by several delegations reporting a significant number of casualties and serious injuries arising during lifeboat maintenance, inspection and drills.

The Sub-Committee concluded that the majority of accidents were related to failure or mal-operation of on-load release equipment. Many accidents were caused by poor maintenance or mal-adjustment of equipment which did not appear to comply with the existing provisions of SOLAS regulation III/20 (Operational readiness, maintenance and inspections), while some followed failures of communication and/or procedures. The causes of such accidents needed to be established and addressed as a matter of urgency.