The IMO’s Sub-Committee on Ship Design and Construction held its 2nd session (SDC2) from Monday 16 through Friday 20 February 2015 under the Chairmanship of Mrs A Jost (GERMANY) and her Vice-Chair, Captain N Campbell (SOUTH AFRICA). Both subsequently declined re-election for 2016 following which Mr Kevin Hunter (UK) was voted in as Chairman and Mrs Turid Stemre (NORWAY) as Vice-Chair. It will be recalled that SDC encompasses former IMO Sub-Committees DE, FP and SLF (Design, Equipment; Fire Protection; Safety, Load-Lines and Fishing Vessels).


In his welcoming speech, the IMO Secretary General voiced his concerns over the unfolding tragedy taking place in the Mediterranean concerning maritime migrants, revealing that more than 300 people had drowned the previous week and in the order of 3,000 people had crossed the sea during the day before. Further startling statistics were that 200,000 people were rescued last year in the Mediterranean, of whom about 3,000 had lost their lives and more than 600 merchant ships had been diverted to assist. The issue of how best to deal with the ‘people smugglers’ responsible for such migration will therefore be the subject of a United Nations Inter-Agency meeting to be held at IMO on 4th / 5th March 2015.


On a different subject, the Secretary General spoke of the accidents concerning NORMAN ATLANTIC and BLUE SKY M, reports of which may be available for discussion at MSC in June. He also stressed the importance to SDC2 of addressing the survivability of large passenger ships after damage, given that safety is the most important aspect of IMO’s work.


Three working groups (WG) and two drafting groups (DG) were formed and chaired as follows:


WG1          Subdivision and damage stability (SDS), Mr J Person (USA)

WG2          Intact Stability (IS), Professor A Francescutto (ITALY)

WG3          Fire Protection (FP), Mr G Szemler (SWEDEN)

DG1          Amendments to SOLAS regulation II-1/11 and Guidelines to ensure adequacy of testing arrangements for watertight compartments, Mr K Koiso (JAPAN)

DG2          Classification of offshore-industry vessels and review of the need for a non-mandatory code for offshore construction support vessels and Guidelines addressing the carriage of more than 12 industrial personnel on board vessels engaged on international voyages, Mr P Wilkins (UK)


Following is a selection of salient points from the meeting on items of most interest to InterManager members:

  • SUBDIVISION AND DAMAGE STABILITY.  The Sub-Committee agreed amendments proposed by WG1 to SOLAS chapter II-1, with a view to approval by MSC95, which meets in early June 2015, and subsequent adoption. In addition, it:
  1. Agreed to forward finalised text of Chapter 2 of the draft OSV Chemical Code on ship survival capability and location of cargo tanks to the PPR Sub-Committee;
  2. Endorsed continued consideration of Explanatory Notes to SOLAS chapter II-1 by a correspondence group with a view to finalisation at SDC3;
  3. Endorsed WG1’s proposal that matters related to the survivability of passenger ships be considered at SDC3; and instructed the FSA (Formal Safety Assessment) Experts Group to meet 10 – 12 November 2015, primarily to review the report of a directly relevant EMSA3 study currently in progress;
  4. Instructed the SDS correspondence group to consider the draft Revised Guidelines on ‘operational information for masters of passenger ships for safe return to port by own power or under tow’ (MSC.1/Circ.1400) for finalisation at SDC3; and
  5. Endorsed WG1’s recommendation that the formula for the required subdivision index R should be based on the total number of persons on board without regard to LSA arrangements. The SSE Sub-Committee will be advised accordingly so that possible consequences to SOLAS regulation III/21 can be examined.


  • INTACT STABILITY (IS). The Sub-Committee approved WG2’s report in general, and in particular, it:


  1. Agreed in principle to draft amendments to the 2008 IS Code regarding vulnerability criteria and the standards related to parametric roll, pure loss of stability and surf-riding / broaching;
  2. Agreed in principle, to Part B chapter 6 amendments of the 2008 IS Code with regard to ice accretion in timber deck cargo, for approval / adoption by MSC 95;
  3. Approved a revised plan of action for matters related to intact stability including a new structure for integrating amendments to the 2008 IS Code;
  4. Noted the need to develop explanatory notes regarding application of the criteria in order to ensure uniform implementation of the information provided;
  5. Agreed a draft amendment to part B of the 2008 IS Code regarding vessels engaged in anchor handling operations, for MSC95’s approval; and
  6. Agreed to re-establish the CG on Intact Stability, reporting to SDC 3.


  • TESTING ARRANGEMENTS FOR WATERTIGHT COMPARTMENTS. The Sub-Committee considered the report of the CG established by SDC1 on Amendments to SOLAS regulation II-1/11 and Development of Associated Guidelines to Ensure the Adequacy of Testing Arrangements for Watertight Compartments and, in addition, documents submitted by JAPAN, GREECE and INTERTANKO. Views were widely expressed, and even more widely divided, such as:


  1. Hydrostatic testing is outdated and should be complemented by up-to-date testing methods;
  2. A compelling need to amend SOLAS regulation II-1/11 was demonstrated in the justification of this output;
  3. The CG report is inconclusive;
  4. Amending SOLAS would lower safety standards;
  5. Ships built in very good shipyards can still have structural problems (i.e. quality management systems do not guarantee quality of construction, nor can they replace full scale testing); and
  6. Alternative arrangement systems can be considered on a case-by-case basis by Administrations,` therefore guidelines for procedures of testing tanks and tight boundaries should be developed.


However, the most telling intervention in the debate was made by INTERTANKO in pointing out that SOLAS regulation II-1/11 is the only one that mandates a full scale test to ensure the water-tightness of tanks intended to carry liquids on ships and should therefore remain. Noting that a clear majority was not in favour of such amendments, the Sub-Committee agreed not to amend SOLAS and instead will recommend to MSC95 that the output should be considered closed.


  • REDUCED GROSS TONNAGE FOR CREW ACCOMMODATION SPACES. A submission by GERMANY proposing a draft resolution to encourage improved living conditions on board ships by means of a reduced gross tonnage parameter for assessing fees was considered. Following an in-depth discussion including concerns that a simplified reduced gross tonnage parameter might lower the safety requirements of ships that are just over 500 tons, and that a recommendatory instrument would not provide an incentive for shipowners to improve seafarers’ living conditions or to increase training accommodation, the Sub-Committee did not agree the proposed draft Assembly resolution and instead invited MSC to note that work on this output has been completed.


  • FIRE PROTECTION. The Sub-Committee welcomed WG3’s wide-ranging report, approving it in general, and in particular, it:


  1. Agreed draft ‘Interim Guidelines for use of Fibre Reinforced Plastic (FRP) elements within ship structures: Fire Safety Issues’ and an associated MSC circular, for approval at MSC95;
  2. Agreed a draft Unified Interpretation (UI) of the ‘Guidelines for Safe Access to Tanker Bows’ (resolution MSC.62(87)) and associated draft MSC95 circular;
  3. Agreed draft amendments to the ‘Guidelines for the application of plastic pipes in ships’ for MSC95 approval;
  4. Noted WG3’s discussion regarding application and purpose of evacuation analysis to various types of passenger ships, also special purpose ships and agreed relevant draft amendments to SOLAS II-2/13 for submission to MSC95 plus the establishment of a CG;
  5. Noted that the WG had failed to establish a consensus view on a UI that would not exceed the SOLAS requirement regarding the means of escape from ro-ro spaces but that nevertheless, a draft UI on SOLAS regulation II-2/13.6 had been finalised for consideration at MSC 95 together with its associated draft MSC circular; and
  6. Agreed the justification for an unplanned output on clarification of application to SOLAS regulation II-2/ with regard to fire integrity of windows on various sizes of passenger ships, as specified.


  • OPENING OF WATERTIGHT DOORS DURING NAVIGATION. This item was on the agenda of SDC1 but was not raised owing to constrained time. The Sub-Committee noted that any revisions to SOLAS regulation II-1/22 and the related ‘Guidance for watertight doors on passenger ships which may be opened during navigation (MSC.1/Circ.1380) are intended to ensure that requirements governing when such watertight doors may be opened, do not inadvertently provide a weak link in the required damage stability survivability of passenger ships. Of note, proposed revisions to SOLAS regulations II-1/22 approved by the Sub-Committee for approval by MSC will apply to new passenger ships whereas MSC.1/Circ.1380 applies to new and existing ships. Revising the latter would have unintended consequences to existing ships thus it was decided not to amend it, enabling continued application to existing ships.


  • REVIEW OF GENERAL CARGO SHIP SAFETY. No documents were submitted to DE57, SDC1 or SDC2 on this subject so in accordance with IMO’s Guidelines on the organisation and method of work, the output was deemed ‘completed’.


  • AMENDMENTS TO THE 2011 ESP CODE. Draft amendment to the 2011 ESP Code proposed by IACS were debated, modified where necessary, then adopted by the Sub-Committee for submission to MSC 95 for approval.




  1. Noted the group’s decision to make minor changes to the footnotes and editorial corrections to the text of the definition of industrial personnel as developed by the correspondence group;
  2. Noted the discussions and deliberations of the group regarding general interpretation in the draft MSC circular. This includes a brief background introduction and a definition of industrial personnel (short-term solution) to assist Member governments with the evolving offshore energy sector;
  3. Agreed to a draft MSC Circular on Definition of industrial personnel for MSC95’s approval;
  4. Agreed terms of reference for a CG to finalise the draft ‘Guidelines for offshore service craft (OSC) used in windfarm service’ and further develop it with a view of finalising the draft ‘Guidelines for offshore construction vessels (OCV) used in windfarm service; and
  5. Will offer a written report to SDC3.



  • GUIDELINES FOR USE OF FIBRE-REINFORCED PLASTIC (FRP) WITHIIN SHIP STRUCTURES. Having considered the report of the correspondence group set up at SDC1 and approved it in general, it was noted that the group had reached the consensus view that regulation II-2/17 can be used for approval of FRP composite structures on SOLAS ships. However, many different opinions were expressed as to the extent of applicability of this regulation and following a comprehensive discussion, the Sub-Committee decided that, at this stage, the working group should finalise the draft interim guidelines only, until experience is gained in its application.




  1. Application of SOLAS regulation II-1/3-6, as amended, and the revised Technical Provisions on means of access for inspections;
  2. Continuous hatchways (regulation 36(6)) of the Protocol of 1988 relating to the International Convention on Load Lines, 1966;
  3. Clarifications to the Code on Noise Levels on Board Ships;
  4. Means of escape from machinery control rooms and main workshops;
  5. Means of escape from machinery spaces on passenger ships;
  6. Means of escape from machinery spaces on cargo ships;
  7. Means of escape from accommodation spaces, service spaces and control stations on cargo ships;
  8. Interpretation of SOLAS regulation II-2/ on ventilation ducts in ‘B’ class divisions; and
  9. Fire integrity of the boundaries of ro-ro / vehicle spaces on passenger and cargo ships.


  • DATE OF NEXT MEETING: 18 – 22 January 2016



Captain Paddy McKnight                                                                                                     END


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