The IMO Sub-Committee on Ship Systems and Equipment held its 6th Session (SSE 6) from Monday 4 through Friday 8 March 2019. Dr S Ota (JAPAN) chaired the meeting (his final one before stepping down at the end of this year), together with his Vice Chair, Mr V Senturk (Turkey). In the ensuing elections, Mr Senturk was elevated to Chair and Mr Sergey Tolmachev of the Russian Federation, promoted to Vice Chair. Three Working Groups (WG) and one Drafting Group (DG) were formed and chaired as follows:
WG1 Life Saving Appliances (LSA), Mr U Senturk (TURKEY)
WG2 Fire Protection, Mr L Fisher (USA)
WG3 On board Lifting Appliances and Anchor Handling Winches, Mr H Eguro (JAPAN)
DG1 Guidelines on Safe Operation of On-shore Power Supply (OPS), Ms L Ma (CHINA)
The meeting was attended by representatives from 69 Member States, 1 Associate Member of IMO, 1 Inter-Governmental Organisation and 26 Non-Governmental Organisations.
ADDRESS BY THE SECRETARY GENERAL. Mr Lim, S-G IMO reminded the Sub-Committee that this year’s theme for World Maritime Day is “Empowering women in the maritime community” and the occasion will be celebrated at IMO Headquarters on 26 September with the annual parallel event to be organised by the Government of Colombia.
Turning to items on the SSE 6 agenda, he mentioned the importance of the development of draft functional requirements for SOLAS chapter III for the development of the goal-based standards safety-level approach in approval of alternative designs and arrangements for regulations on life-saving appliances and encouraged finalisation of work on the accompanying Guidelines for SOLAS chapters II-I and III.
He felt that improvements in ventilation conditions of survival craft will be achieved by finalising draft amendments to the LSA Code on ventilation requirements for survival craft and draft amendments to the ‘Revised recommendation on testing of life-saving appliances’. On a related item, although the Polar Code entered into force on 1 January 2017, some remaining work needs to be carried out in finalising the draft Interim guidelines on life-saving appliances and arrangements for ships operating in polar waters.
In order to minimise the incidence and consequences of fires in ro-ro spaces, also, in special category spaces of new and existing ro-ro passenger ships, he expressed confidence that this would be achieved by progressing work on the revision of SOLAS chapter II-2 and associated codes. A further expected outcome of work in relation to fire safety will be that obtained by progressing the development of amendments to the relevant Guidelines for the approval of systems which increase the efficiency of fixed dry powder systems used on LPG ships.
Finally, the SG stressed the importance of finalising the draft SOLAS regulations and the draft guidelines for on board lifting appliances and anchor handling winches, an item which has been on SSE’s agenda since 2011. This would be aimed at preventing accidents related to such equipment, which has caused harm to operators and damage to ships, cargo, shore-based structures and subsea structures, as well as the marine environment.
SAFETY OBJECTIVES AND FUNCTIONAL REQUIREMENTS OF THE GUIDELINES ON ALTERNATIVE DESIGN AND ARRANGEMENTS FOR SOLAS CHAPTERS II-1 AND III. It was noted by the Sub-Committee that in order to ensure the consistent application of SOLAS regulations III/4.3 and III/38, MSC.1/Circ.1212, and the format of the presentation of functional requirements and expected performance, SSE 5 agreed that a gap analysis would be necessary, and therefore re-established the Correspondence Group on Life-Saving Appliances to submit a report to this session. The Sub-Committee approved the CG’s report in general during which RINA questioned whether enough progress has been made in order to commence the revision of SOLAS chapter III, also IACS highlighted its concerns over the structure of the functional requirements and the need for a quantitative approach for the expected performances. Following debate in Plenary, it was agreed that a hazard identification study approach would not be appropriate and duly instructed the Working Group on Life-Saving Appliances (WG1) to finalise the list of functional requirements and the draft amendments to the Guidelines on alternative design. In consideration of WG1s findings, the Sub-Committee agreed to the draft amendments to the Guidelines on alternative design and arrangements for SOLAS chapters II-1 and III (MSC.1/Circ.1212) and the associated MSC circular for approval by MSC 101. In addition, it was agreed that the task to develop functional requirements for SOLAS Chapter III has been completed.
DEVELOPMENT OF NEW REQUIREMENTS FOR VENTILATION OF SURVIVAL CRAFT. It was recalled that SSE 5 had re-established the LSA Correspondence Group in order to progress work intersessionally, instructing it to submit a report to this session. Having approved it in general, it was noted that the Group had: submitted two additional references regarding data on microclimates; considered criteria for new ventilation requirements; made progress regarding draft amendments to chapter IV of the LSA Code and also draft amendments to resolution MSC.81(70) on testing of LSAs. In addition, China proposed amendments to the ventilation rate criteria whilst CLIA presented its concern on a proposal by Canada to include CO2 monitors for all types of lifeboats. During consideration of the CG report and other submitted documents in Plenary, it was most noticeably agreed that the aim of the work should be to provide a habitable environment rather than enhancing comfort within the survival craft, that CO2 monitoring systems require maintenance and their failure could lead to serious consequences, and that increasing the ventilation rate from 5m3/h to 6.45m3/h should not be considered. Given this, the Sub-Committee decided to prioritise the finalisation of the draft amendments on the ventilation requirement for totally enclosed lifeboats. In the event, WG1 recommended retention of the draft amendments to the LSA Code as contained in Annex 1 to document SSE 5/WP.3 (ie,no change) and this view was duly endorsed by the Sub-Committee. Note was also taken of the progress made by the WG on the draft amendments to resolution MSC.81(70) and that, due to time constraints, the Group was not able to consider the draft amendments to the LSA Code on the ventilation requirement for survival craft other than totally enclosed lifeboats.
CONSEQUENTIAL WORK RELATED TO THE NEW CODE FOR SHIPS OPERATING IN POLAR WATERS. The Sub-Committee considered document SSE 6/5 by Norway containing the Correspondence Group report relevant to this agenda item reporting that good progress had been made on the finalisation of the draft interim guidelines on LSAs and arrangements for ships operating in polar waters. Following consideration of the CG report, WG 1 was instructed to finalise: the draft interim guidelines; examine options on how to determine the ”maximum expected time of rescue”; and, how best to address testing and evaluation of LSAs. Subsequently, the Sub-Committee agreed to the draft interim guidelines on life-saving appliances drawn up by the WG for submission to MSC 101, invited proposals regarding options to develop guidelines on how to determine the “maximum expected time of rescue”, and agreed proposed terms of reference in re-establishing the correspondence group on life-saving appliances.
REVIEW SOLAS CHAPTER II-2 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. In considering the report of the Correspondence Group on Fire Protection set up at SSE 5, the Sub-Committee noted the progress made on the draft interim guidelines for minimising the incidence of fires and on draft amendments to SOLAS regulation II-2/14.3. Following discussion in Plenary which included topics such as recent accident reports, the Firesafe II study and amendments to MSC.1/Circ 1432 concerning testing of the fixed water-based fire-extinguishing systems, the FP Working Group (WG2) was established and following its work, submitted a report which was approved in general by the Sub-Committee, and in particular:
- Agreed to the interim guidelines for minimising the incidence and consequences of fires on ro-ro spaces and special category spaces of new and existing ro-ro passenger ships, and the associated draft MSC circular;
- Invited SSE 7 to consider sections 3.2 and 3.3 in the guidelines related to training and drills for seafarers, and advise MSC as appropriate;
- Noted that consideration by the Group with regard to draft amendments to the SOLAS convention was cut short due to lack of time and that further work emanating from the FIRESAFE II study would be needed at SSE 7, particularly in light of the proposed analysis of the report by the FSA experts group;
- Noted that, whilst agreeing in principle with the purpose of the proposed amendments to test fixed water based fire extinguishing systems required for ro-ro passenger ships, reached a conclusion that these amendments should be more universally applied and thus required a new output to address this matter;
- Noted the discussion by the Group with regard to dry chemical powder and progress made with regard to the draft amendments to the Guidelines for the approval of fixed dry chemical powder fire-extinguishing systems for the protection of ships carrying liquefied gases in bulk;
- Agreed to the draft unified interpretation to SOLAS regulation II-2/9.7.5 and regulation II-2/10.10.4 and the associated draft MSC circular; and,
- Agreed the recommendation to re-establish the Correspondence Group on Fire Protection.
REQUIREMENTS FOR ONBOARD LIFTING APPLIANCES AND ANCHOR HANDLING WINCHES. The Sub-Committee recalled that SSE 5 had considered the goal- and function-based SOLAS regulations concerning onboard lifting appliances and anchor handling winches (OLAW), with a particular emphasis on types of equipment, safe working load (SWL), the scope of application, inspection and testing, training and qualification of the ship’s crew and shore-based personnel, loose gear brought from the shore-side, and the draft guidelines supporting the goals and functional requirements. In regard to the outcome of MSC 100, the Committee had agreed that a “list of inclusions with some exclusions” approach should be taken when drafting the SOLAS amendments relevant to OLAW and that onboard lifting appliances installed on offshore construction ships should be excluded from the new requirements. In view of fears that a Goal Based Standard (GBS) approach could prolong completion, the Sub-Committee agreed to a prescriptive one as a basis for the work.
Before considering the report of the OLAW Correspondence Group, and approving it in general, two documents were introduced by co-sponsors Japan and ICS relating to placement of the new SOLAS regulations which, inter alia, led to the sub-Committee agreeing that it should be SOLAS chapter II-1.
Following interesting Plenary discussions on a number of points raised in the OLAW Correspondence Group Report, terms of reference were drawn up for WG 3, which subsequently reported back to the Sub-Committee. The Sub-Committee then approved the report submitted by WG 3 in general, and in particular:
- Noted the Groups discussion on the draft new SOLAS regulation II-1/3-13, notably the inclusion of a threshold value of 1,000kg as part of the exclusions provisions; the Groups agreement to refrain from setting a SWL threshold value for anchor handling winches; no direct reference being made to the MODU Code in the draft SOLAS regulation; exclusion of offshore construction ships from the application of the draft regulation; the issue of thorough examination and testing requirements mandated by ILO C152 and under SOLAS chapter I; and, the circumstances and conditions that would render a ship unseaworthy for inoperative OLAW;
- Noted that the Group has finalised draft SOLAS regulation II-1/3-13;
- Agreed, in principle, to the draft SOLAS regulation II-1/3-13, with a view to submission to the Committee in conjunction with the associated Guidelines, once finalised;
- Noted that, owing to time constraints, the Group was unable to further develop the draft guidelines for the safety of onboard lifting appliances and anchor handling winches, but the task will be included in the proposed terms of reference of the Correspondence Group;
- Again that owing to time constraints, the Group was unable to prepare the check/monitoring sheet and the record format for the draft amendments to 1974 SOLAS Convention, but has included the task in the proposed terms of reference of the Correspondence Group; and;
- Agreed the WG’s recommendation to re-establish the Correspondence Group on Onboard Lifting Appliances and Anchor Handling Winches, with terms of reference instructing it to further develop the draft guidelines for onboard lifting appliances and a separate set of draft guidelines for anchor handling winches, plus preparation of the check/monitoring sheet and the record format.
DEVELOPMENT OF GUIDELINES FOR COLD IRONING OF SHIPS AND OF AMENDMENTS TO SOLAS CHAPTERS II-1 AND II-2. The Sub-Committee considered the report of the Correspondence Group established by SSE 5 and noted that the Group had made good progress on the development of draft guidelines on safe operation of onshore power supply service in port for ships engaged on international voyages, whilst also identifying some issues for further consideration, including the framework of the guidelines and making reference to international standards. Although the development of such guidelines were considered appropriate, caution was urged concerning the lack of global implementation, practicality, interoperability and cost-effectiveness, taking into account that any measures could require substantial investment. Also tasking of a drafting group for further development of the guidelines was considered premature, thus best tackled by a correspondence group and standardisation aspects should not be mixed with operational ones.
Having considered the documents submitted and in view of the discussion thus generated, it was agreed that a correspondence group be established to further develop the draft guidelines. Subsequently, the Drafting Group was formed and instructed to prepare terms of reference for an intersessional group focussing only on operational matters for consideration by the Sub-Committee. On completion of this task, the Intersessional Correspondence Group was instructed by its terms of reference to: “further develop the draft guidelines on safe operation of onshore power supply (OPS) service in port for ships engaged on international voyages, but limited to operational requirements based on the draft set out in the annex to document SSE 6/11, taking into account document 6/11/1; and, submit a report to SSE 7”.
UNIFIED INTERPRETATION OF PROVISIONS OF IMO SAFETY, SECURITY, AND ENVIRONMENT RELATED CONVENTIONS. As requested by the Sub-Committee, the Secretariat prepared, on the basis of the IACS Unified Interpretations (UIs), draft MSC Circulars on the following UIs for submission to MSC 101:
- SOLAS chapter II-2, with a view to providing more specific guidance on Construction – Fire protection, fire detection and fire extinction, regulation 9.2 – Containment of fire, thermal and structural boundaries;
- SOLAS chapter III, with a view to providing more specific guidance on regulation 20.11 – Operational readiness, maintenance and inspections, thorough examination, operational testing, overhaul and repair of lifeboats, rescue boats and fast rescue boats, launching appliances and release gear;
- The IGC Code, with a view to providing more specific guidance on paragraph 11.3.6 – Fire protection and extinction, Water-spray system, and, paragraph 11.4.8 – Fire protection and extinction, Dry chemical powder fire-extinguishing systems; and,
- SOLAS regulations II-1/28, II-1/29 and II-1/30 with a view to ensuring a uniform approach towards the application of SOLAS provisions concerning the arrangements for steering capability and function on ships fitted with propulsion systems other than traditional arrangements for a ship’s directional control.
REVISION OF THE STANDARDISED LIFE-SAVING APPLIANCE EVALUATION AND TEST REPORT FORMS (MSC/CIRC.980 AND ADDENDA). The Sub-Committee considered document SSE 6/14 (USA and ILAMA), proposing amendments to MSC/Circ.980 by incorporating the amendments to the LSA Code and the ‘Revised recommendation on testing of life-saving appliances’ since MSC/Circ.980 and its two addenda (which had been approved at MSC 73), and noted that, due to the significant size of the document, not all the annexes had been translated. In addition, feedback received after the document had been processed, indicated that further amendments might need to be introduced. The co-sponsors view that a more efficient framework could be developed by creating a separate MSC circular for each section of the circular was also noted. This would mean that in future, updates would be more focussed in lieu of having to re-issue the entire text of MSC/Circ.980 when only one section was being revised. In light of the information from the co-sponsors, it was agreed to translate the proposed draft amendments into all working languages in order to complete the work at SSE 7.
ANY OTHER BUSINESS. A plethora of items was discussed under this item, the most
significant of which are as follows:
- Modification of the draft amendment to paragraph 184.108.40.206 of the LSA code. The Sub-Committee considered document SSE 6/17/4 by Japan proposing to modify the draft amendments to the LSA Code approved at MSC 100. In the ensuing discussions, a majority was of the view that the amendment to paragraph 220.127.116.11 of the LSA Code should apply to newly installed rescue boats. In relation to the meaning of the word “means” which had been queried, the sub-Committee decided that it required no further clarification. Noting the merit of the improvements proposed in Japan’s submission, the Sub-Committee invited MSC 101 to consider them together with a further proposed modification when finalising the LSA Code for adoption.
- Model courses under the purview of IMO bodies other than the HTW Sub-Committee. MSC 100 instructed the Sub-Committee to consider whether four model courses published in 2004 could need to be revised, and if so, to do it in consultation with the Secretariat in order to streamline the process. These were: 3.03 on Survey of machinery installations; 3.04 on Survey of electrical installations; 3.05 on Survey of fire appliances and provisions; and, 3.06 on Survey of life-saving appliances and arrangements. In this regard, the courses should be categorised in one of three ways, viz: first,as to whether no update is necessary; or second, a minor update is required in which case it could be forwarded directly to a review/drafting/validating group; or third, substantial change is necessary in which case it would be considered as being a new course for the purpose of its revision. The Committee (MSC) also decided to include SSE as one of the associated organs in output 1.3 on “Validated model training courses”. The Sub-Committee also agreed that it should first be determined whether the above model courses are being used by training institutes, including sales information, to determine whether or not the courses should be maintained and towards this end, the Secretariat declared its intention to submit a document to the next session indicating statistical information on the sales of the model courses in question to assist the Sub-Committee in making a decision on how best to proceed.
- Draft interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel. MSC 100 endorsed the referral of relevant parts of the draft interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel for consideration by SSE 6 in order to advise CCC 6, in particular section 11 in its entirety and draft section 15.9 regarding control and monitoring of fire detection systems in machinery spaces containing Methyl/ethyl alcohol engines. In addition to supplying the requested text to CCC 6, the Sub-Committee also noted the possible implication of availability of foams in connection with the use of PFOS (perfluorooctanesulphonic acid) and other surfactants in fire-fighting foam on board ships which are still under consideration and should be taken into account by CCC 6.
DATE OF NEXT MEETING. The next meeting, SSE 7, has been scheduled to take place from 2-6 March 2020.
Captain Paddy McKnight