The IMO’s Sub-Committee on Ship Systems and Equipment held its 1st session (SSE 1) from Monday 10 through Friday 14 March 2014 under the chairmanship of Dr S Ota (JAPAN) and his Vice-Chair, Mr K Hunter (UK); both were subsequently re-elected for 2015. This Sub-Committee, acronym SSE, has assumed responsibility for many matters formerly dealt with by DE, FP and SLF; the remaining issues became the province of SDC (Ship Design and Construction) in line with the new, leaner IMO Sub-Committee structure. Three working groups (WG) and a drafting group (DG) were formed as follows:
WG1 Fire Protection, Mr Eberly (USA)
WG2 Life-Saving Appliances, Mr Yoshida (JAPAN)
WG3 Onboard Lifting Appliances and Winches, Mr Lakeman (NL)
DG1 Consideration of IACS Revised Unified Interpretations and proposed amendments to MARPOL Annex 1, Mrs Kristensen (NORWAY)
Following is a selection of points emerging from the meeting of particular interest to InterManager members:
- SHIPS CARRYING HYDROGEN AND COMPRESSED NATURAL GAS, VEHICLES. WG1 produced a draft MSC Circular, subsequently agreed by the Sub-Committee for submission to MSC 93, which recommends that the shipper should provide a signed certificate or declaration that the vehicle fuel system, as offered for carriage, has been checked for leak-tightness and the vehicle is in proper condition for carriage prior to loading. In addition, each vehicle shall be marked, labelled or placarded that these conditions have been met accordingly.
- SMOKE CONTROL AND VENTILLATION. The Sub-Committee noted WG 1’s considerations on development of a draft Performance Standard, that it would be best to first develop broad functional requirements to benchmark intended smoke control system objectives and then to develop a recommended list of action items as the basis for future work. Possible amendments to SOLAS chapter 11 – 2 will no doubt follow in train.
- DEVELOPMENTS OF AMENDMENTS TO SOLAS REGULATION 11 – 2/20 AND ASSOCIATED GUIDANCE ON AIR QUALITY MANAGEMENT FOR VENTILATION OF CLOSED VEHICLE SPACES, CLOSED RO-RO AND SPECIAL CATEGORY SPACES. It was agreed that the air quality control system should not be applicable to the new SOLAS regulation 11 – 2/20-1 (requirement for vehicle carriers carrying motor vehicles with compressed hydrogen or natural gas in their tanks for their own propulsion as cargo) since the current SOLAS requirements consider gasoline and diesel as fuel only.
- SAMPLE EXTRACTION SMOKE DETECTION SYSTEM IN FSS CODE. A draft Unified interpretation on the requirement for sample extraction in chapter 10 of the FSS code was agreed for submission to MSC 94. It stipulates that if the CO2 system discharge pipes are used for the smoke sample, the control panel can be located in the CO2 room but only if there is an indicating unit (repeater panel) on the navigation bridge.
- USE OF FLEXIBLE BELLOWS. Noting that flexible bellows (not made of steel or equivalent material) protect the ventilation duct most effectively, especially in that they absorb machinery vibration, it was agreed that a short length, not exceeding 600 mm, of flexible bellows constructed of combustible material may be used for connecting fans to the ducting in the air conditioning room; this recommendation will be forwarded to MSC 93 for consideration.
- FIRE PROTECTION CG. A correspondence group was established to further consider smoke control, ventilation systems in ro-ro cargo spaces and also to revise / update MSC Circular 729. It will report to SSE 2.
- DEVELOPMENT OF LIFE SAFETY PERFORMANCE CRITERIA FOR ALTERNATIVE DESIGN AND ARRANGEMENTS FOR FIRE SAFETY. Following general discussion of this subject in Plenary, it was decided to establish a Correspondence Group under the coordination of the UNITED STATES. It will seek to review available research, methodologies and standards vis-à-vis human exposure to fire effluent and consider whether safety margins in shore-side building design are adequate for use in ships. An appropriate framework for assessment of minimum life-safety performance criteria and safety margins to address survivability when exposed to heat, smoke, toxicity, reducing visibility, etc in relation to evacuation time will also be explored, following which a report will be submitted to SSE 2.
- DRAFT GOAL-BASED GUIDELINES ON THE FRAMEWORK OF REQUIREMENTS FOR SHIPS’ LIFE-SAVING APPLIANCES. Having addressed these goal-based guidelines the WG identified:
.1 a need to restructure / rearrange SOLAS Chapter III for it to be more user-friendly; and
.2 the importance of evaluating feasibility, adequacy and effectiveness of future proposals on new requirements.
- 2009 MODU CODE. Draft amendments to the MODU Code were agreed for submission to MSC 94. These related to Practice musters and drills and in addition, a set of associated draft Guidelines on alternative methods for lifeboat drills on MODUs was developed; they might also be used in conjunction with the provision of on-board training and instruction.
- GISIS DATABASE REGARDING THE EVALUATION OF HOOKS UNDER THE REQUIREMENTS OF MSC.1 / CIRC.1392. The intent behind this MSC Circular is that existing on load release hooks are only re-approved when the function of the hook itself is safe without the use of additional operating mechanisms or devices similar to ‘fall preventer devices’. Such devices should be considered as being in addition to, and not form part of, the original hook’s mechanism. Despite this clear and unambiguous intent, some re-approved hooks effectively constitute fall preventer devices thus denying assurance that the modifications guarantee the safety characteristics of the hooks. In addition, information provided on the GISIS database advises that a particular hook found to be ‘compliant after modification’ affords scant details as to how this has been achieved. A substantial industry coalition represented strong views to the Sub-Committee following which the Chairman invited member governments to submit papers to MSC 93 and noted the USA’s assertion that a new Output of interpretation for MSC Circular 1392 should be considered.
- DEVELOPMENT OF REQUIREMENTS FOR ON-BOARD LIFTING APPLIANCES AND WINCHES. In light of the number of accidents, the Sub-Committee noted WG 3s views on the need for further consideration of available data involving on-board lifting appliances and winches in order to determine the scope and application of measures necessary for potential future regulations. Incident data analysis methodology was endorsed as also was the view that initial consideration of the scope of potential measures should be broad, and not limited only to cargo-handling lifting appliances. However it will not include personnel / passenger elevators (lifts) and escalators on board ships nor equipment regulated by the LSA Code. Application will be considered for all ships to which SOLAS applies but MOUs certified under the MODU Code will be exempt, as also will fishing vessels. It was observed that the focus of potential measures will ultimately determine whether they should apply to existing ships only, or existing and new ships; if certification is included within potential measures, a transitional period for existing ships should be considered. Based on presently available incident data, the following items were noted:
.1 insufficient safety procedures in place;
.2 lifting hooks not engaging properly;
.3 training in operation and maintenance; and
.4 operational and maintenance conditions that could induce failure of on-board lifting and winches, particularly that of wire rope.
Since WG 3 opinion was divided on the issue of mandatory or non-mandatory status of potential measures for on-board lifting appliances and winches, the matter will be considered at SSE 2 following production of a draft framework and refinement by a correspondence group coordinated by NEW ZEALAND. Meanwhile, Member States and international organisations, including industry organisations such as ICHCA whose members have access to marine claims data, were invited to gather incident reports involving lifting appliances and winches, making them available to the correspondence group as soon as possible after SSE 1.
- IACS UNIFIED INTERPRETATIONS (UIs). This is a continuous item on the biennial agenda, established by MSC 78, so that IACS can submit any newly developed or updated UIs for consideration by the Sub-Committee. Assembly 28 expanded the output to include all the proposed UIs to provisions of IMO safety, security, and environment-related Conventions. The most relevant to InterManager are:
.1 Agreement to a draft UI and associated draft MSC circular (for approval at MSC 94) on the load testing of hooks intended for the primary release of lifeboats.
.2 The expectation that MSC 93 will adopt mandatory requirements for periodic servicing and maintenance of launching appliances and on-load release gear however there is no indication as to limitation regarding service providers.
.3 The establishment of a drafting group to finalise the draft text of proposed amendments to MARPOL regulation I/12 and prepare consequential amendments to relevant UIs for approval at MEPC 67.
.4 Agreement of a draft UI and associated draft MSC Circular on the embarkation station and stowage location of the life-raft together with adequate means of illumination.
.5 The forwarding to MSC 94 of a draft UI relating to the provisions in Chapter 9 of the FSS Code on Fixed Fire Detection and Fire Alarm Systems and likewise for Chapter 5, a draft UI relating to the release operation of the CO2 System.
.6 An invitation to IACS to prepare a draft MSC circular on fixed gas fire-extinguishing systems and fixed fire detection and fire alarm systems. This will seek to clarify the number of setting points to the discharge control for the fire-extinguishing medium and also, the time period of the power supply to the latter system.
- GUIDELINES FOR EVALUATION AND REPLACEMENT OF LIFEBOAT RELEASE AND RETRIEVAL SYSTEMS. ILAMA invited the Sub-Committee to reconsider the requirements for a post-installation towing test after replacement of a lifeboat release and retrieval system which would permit alternative testing with no personnel in the lifeboat and the lifeboat not being disconnected from the falls during the test. The proposal received scant support, rather the opposite, and it was decided not to proceed with the issue further.
- THE POLAR CODE. It was generally agreed that additional performance or test standards may be necessary but that detailed discussion should not be started until after MSC 93 has finalised the Polar Code.
- DATE OF NEXT MEETING. SSE 2, 23 – 27 March 2015.
Captain Paddy McKnight END