The IMO Sub-Committee on Ship Systems and Equipment held its 4th Session (SSE 4) from Monday 20 through Friday 24 March 2017. Dr S Ota (JAPAN) chaired the meeting together with his Vice Chair, Mr V Senturk (TURKEY), both of whom were subsequently re-elected for 2018. Three Working Groups (WG) were formed and chaired as follows:
WG1 Life Saving Appliances (LSA), Mr S Assheuer (GERMANY)
WG2 Onboard Lifting Appliances and Winches, Mr A Ishihara (JAPAN)
WG3 Fire Protection, Mr L Fisher (USA)
The meeting was attended by representatives from 11 Member States, 1 Associate Member of IMO, 1 Inter-Governmental Organisation and 27 Non-Governmental Organisations.
- ADDRESS BY THE SECRETARY GENERAL. In his short address to delegates, the Secretary General, Mr Kitack Lim, highlighted the fact that, within its purposes, the IMO has to provide the machinery of cooperation among Governments in the field of international shipping regulations relating to technical matters. In this regard, he encouraged a strengthening of cooperation and joining together in order to promote the availability of shipping services to the whole of world trade, equally. He stressed the relevant role played in the execution of IMO policies by those technical and operational matters related to systems and equipment under SSE’s purview, including machinery and electrical installations in all types of ships and mobile units covered by IMO instruments; testing and approval of systems and equipment; life-saving appliances and arrangements; fire safety provisions; and, analyses of casualty and incident records relating to ship systems and equipment.
The Secretary General went on to speak about some key issues amongst the various agenda items for SSE4, which included:
- development of functional requirements for SOLAS chapter III in order that MSC 98 can make a decision on the future direction of the Safety Level Approach (SLA);
- following recommendations arising from the MOL COMFORT casualty investigation report, the need to develop new requirements for ventilation of survival crafts;
- that in order to support implementation of the Polar Code, action should be taken to embark on consequential work related to the Code, in particular, to prepare a work plan addressing any additional requirements related to LSAs and arrangements on board ships operating in polar waters including performance criteria;
- the finalisation of the requirements for Onboard Lifting Appliances and Winches, making clear decisions on issues such as the impact of such equipment on the ship’s certification, the scope of application of the new provisions and the training and education of ‘competent persons’; and
- the importance of Reviewing SOLAS chapter II-2 and associated codes to minimise the incidences and consequences of fires on ro-ro spaces and special category spaces of new and existing ro-ro passenger ships.
Amongst other important issues for review, he mentioned amendments to the 2009 MODU Code prepared in light of investigations into the 2010 DEEP WATER HORIZON incident, finalisation of reviews into two sets of guidelines as a result of adopting ‘Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (resolution MSC.402(96)) and finally, consideration of the application of Anti-Crushing Protection to watertight doors.
The Secretary General concluded his welcome by reminding delegates that the date for submission of nominations to the 2017 IMO Award for Exceptional Bravery at Sea will remain open until 14 April.
Items of particular interest to InterManager members include the following:
- SAFETY OBJECTIVES AND FUNCTIONAL REQUIREMENTS OF THE GUIDELINES ON ALTERNATIVE DESIGN AND ARRANGEMENTS FOR SOLAS CHAPTERS II-1 AND III. The Sub-Committee endorsed the LSA WG’s view concerning the draft functional requirements and the expected performance to SOLAS chapter III, for submission to MSC 98 for consideration, with a view to proceeding with the development of functional requirements and expected performance for SOLAS chapter III, aiming for a more quantifiable version.
- MAKING THE PROVISIONS OF MSC.1/CIRC.1206/REV.1 MANDATORY (MEASURES TO PREVENT ACCIDENTS WITH LIFEBOATS). With regard to the draft MSC circular on Guidelines on safety during abandon ship drills using lifeboats, the Sub-Committee considered several documents related to the launching of free-fall lifeboats. The first document (SSE 4/4), submitted by LIBERIA, MARSHALL ISLANDS, NEW ZEALAND and PANAMA plus 12 NGOs (including InterManager), proposed a definition of simulated launching, as contained in the draft Guidelines for simulated launching of free-fall lifeboats. The definition is intended to differentiate between simulated launching in the context of drills and testing and applying such a concept throughout the draft Guidelines. The second document, submitted by the International Lifesaving Appliances Manufacturers’ Association (ILAMA), (SSE 4/4/1), provided comments on SSE 4/4 , suggesting a new scope for the definition of simulated launching of free-fall lifeboats and the inclusion of the definitions of the draft amended guidelines developed by the Industry Lifeboat Group (ILG).
In the ensuing Plenary discussion, a number of views were expressed:
- drills and testing are different concepts and therefore, the release mechanism of free-fall lifeboats should not be activated when abandon ship drills are conducted in accordance with SOLAS regulation III/19, in order to reduce risks;
- tests of the free-fall system should not be limited to the release mechanism function, but the whole system should be tested;
- a reduced scope of drills may lead to lack of training;
- measures to reduce the risk of accidents when conducting drills should be limited not only to the application of operational procedures but also to technical provisions established by the manufacturer of the equipment; and
- complete alignment between the draft guidelines, SOLAS regulation III/20 and resolution MSC.402(96), in particular its paragraph 6.2.7 (Operational test of the free-fall lifeboat release function), is necessary.
Following discussion the Sub-Committee instructed the LSA WG to complete the work resulting from the adoption of resolution MSC.402(96) and also to finalise the draft MSC circular on Guidelines on safety during abandon ship drills using lifeboats. During subsequent discussion within the LSA WG, it was concluded that the purpose of the revised guidelines is to ensure safe conduct of drills and that testing of lifeboats is dealt with in other instruments. Thus it was agreed that references to testing should be deleted in the draft guidelines and that a further development of the guidelines for simulated launching for the purpose of testing should be prepared at a future stage. The Sub-Committee next endorsed the draft Guidelines proposed by the LSA WG on safety during abandon ship drills using lifeboats and also those for ‘developing operations and maintenance manuals for lifeboat systems’, together with their associated draft MSC circulars for submission to MSC 98 for approval.
- DEVELOPMENT OF THE NEW REQUIREMENTS FOR VENTILATION OF SURVIVAL CRAFTS. In discussing the methods and criteria for improving the microclimate inside totally enclosed lifeboats (including active and passive variants, the LSA WG concluded that it was not feasible to reach a conclusion at this session. However, the Sub-Committee agreed to establish a correspondence group to further progress the issue intersessionally.
- REVIEW OF THE MODU CODE, LSA CODE AND MSC.1/CIRC.1206/REV1. Despite concerns expressed by the delegation of CHINA regarding the possible impact of the draft amendments on recognised designs of the offshore industry lifeboats, the references to national and industry standards and the location of the definition of the terms ‘vital machinery and equipment’, the Sub-Committee endorsed the draft amendments to the 2009 MODU Code, together with the associated draft MSC resolution for submission to MSC 98 with a view to adoption.
- REQUIREMENTS FOR ONBOARD LIFTING APPLIANCES AND WINCHES (OLAW). Following an extensive discussion in Plenary, the Sub-Committee established the WG on Onboard Lifting Appliances and Winches. In considering the subsequent WG report, the Sub-Committee:
- noted the progress made by the WG on the development of the draft SOLAS regulations for onboard lifting appliances and anchor handling winches;
- endorsed definitions for ‘onboard lifting appliance’, ‘anchor handling winch’ and ‘loose gear’;
- endorsed in principle, the goal of draft SOLAS regulations II-1/3-13, it being: ‘To prevent accidents related to onboard lifting appliances and anchor handling winches causing harm to persons or damage to ships, cargo, shore-based structures, subsea structures as well as the environment’;
- noted WG discussion, in particular, on Safe Working Load, functional requirements applicable to existing installations, exclusions, manuals provider, competent persons and appropriateness of including an operational functional requirement in SOLAS chapter II-1; and
- noted that, owing to time constraints, the WG was unable to further develop the draft Guidelines but has included this matter in the terms of reference for a Correspondence Group on Onboard Lifting Appliances and Winches all of which were duly formalised.
- ESCAPE ROUTE SIGNS AND EQUIPMENT LOCATION MARKINGS. The Sub-Committee agreed that a draft Assembly resolution on Escape route signs and equipment location markings, which was prepared in cooperation with the ISO Central Secretariat, should apply to ships constructed on or after 1 January 2018 or ships which undergo repairs, alterations, modifications and outfitting within the scope of SOLAS Chapters II-2 and/or III, as applicable, on or after 1 January 2018.
- ANTI-CRUSHING PROTECTION (ACP) TO WATERTIGHT DOORS. Following a lengthy and indeterminate discussion the Sub-Committee agreed that this output should be continued but that objective information and results of risk assessments are necessary in order to consider feasible safety solutions and to avoid any adverse effects on the primary safety functions of watertight doors, as well as the ship’s watertight integrity and survivability.
- RECOMMENDATIONS OF THE WG ON FIRE PROTECTION. In considering the report of the Fire Protection WG, the Sub-Committee approved it in general and, in particular:
- agreed that there is no further need to proceed with FSS Code amendments for fire-extinguishing pipes in under-deck passageways at this stage;
- endorsed a two-step approach for the review of SOLAS chapter II-2 and associated codes, namely developments of the Interim Guidelines, also amendments to SOLAS and associated codes to minimise the incidence and consequences of fires on ro-ro spaces and special category spaces of new and existing ro-ro passenger ships;
- endorsed the five main tasks to be addressed under the review of SOLAS chapter II-2 and associated codes which are, Prevention / Ignition, Detection and Decision, Extinguishment, Containment, and Integrity of LSA and Evacuation;
- endorsed the WG’s view that the method of work should generally follow risk-based methodology, such as Formal Safety Assessment (FSA); and
- endorsed the draft scope of the review of SOLAS and associated codes, together with a draft work plan for submission to MSC 98 with a view to approval.
- CONSEQUENTIAL WORK RELATED TO THE (NEW) POLAR CODE. As instructed by the Sub-Committee, the LSA WG prepared a work plan addressing additional testing and performance standards related to life-saving appliances and arrangements on board ships operating in polar waters, taking into account how they should be added to existing instruments, e.g. a new chapter in the LSA Code and a new section in resolution MSC.81(70), including any interim solutions. The WG subsequently recommended establishment of a Correspondence Group and drew up terms of reference which were subsequently endorsed by the Sub-Committee, with a view to SSE 5 considering the outcome of the Correspondence Group and finalising draft solutions. It was envisaged that SSE 6 would complete the final draft of the consolidated performance standards plus development of add-ons to existing performance standards and submit a report to MSC 101.
- UNIFIED INTERPRETATIONS. The International Association of Classification Societies (IACS), submitted a number of unified interpretations (UIs) to provisions of IMO safety, security, and environment related Conventions, so that any newly developed or updated draft UI could be submitted for consideration by the Sub-Committee, with a view to developing an appropriate IMO interpretation. The UIs were farmed out to all three WGs for consideration.
Of special interest to InterManager, a draft UI on single fall and hook system used for launching a lifeboat or rescue boat was sent to the LSA WG but it was decided not to submit it to MSC 98, rather it was deferred for further discussion at SSE 5.
- DATE OF NEXT MEETING. The provisional date of the next meeting, SSE 5, is 12 – 16 March 2018.
Captain Paddy McKnight End