1 Use of butterfly valves instead of screw-down valves
SOLAS
Chapter II-1
Use of butterfly valves instead of screw-down valves
The Maritime Safety Committee, at its ninety-eight session (7 to 16 June 2017), adopted amendments to SOLAS Chapter II-1, regulation 12.6.1, by Resolution MSC.421(98), as amended by MSC 98/23/Add.1/Corr.2, with entry-into-force 01 January 2020, allowing for cargo ships the fitting of a butterfly valve at the collision bulkhead.
SOLAS Chapter II-1, regulation 12.6.1 – Interpretation of “readily accessible.” The interpretation of “readily accessible” is that this does not necessarily mean “remote controlled”. This interpretation is valid till 01-01-2024, as Resolution MSC.421(98) was amended during IMO SDC 6/SDS meetings (still to be approved by MSC, entry into force 01-01-2024).
2 Procedures for open watertight doors passenger ships
SOLAS
Chapter II-1
Procedures for open watertight doors passenger ships (12-19)
SOLAS CH II-1 reg. 22.3 requires watertight doors on board of passenger ships to remain closed during navigation. According to SOLAS CH II-1 reg. 22.4 only in special circumstances and under specific conditions navigation with open watertight doors may be allowed by the administration. MSC.1/Circ.1380 sets criteria for watertight doors that should be open at sea under normal circumstances in order to allow for a safe passage of passengers or for a safe operation of the ship. The Netherlands Shipping Inspectorate deems these requirements appropriate and will address MSC.1/Circ.1380 as ‘policy rule’ for all passenger ships.
Not later than at the first annual survey after 01 January 2013, all passenger ships flying the Netherlands flag shall have assessed and documented the procedures for open watertight doors in compliance with MSC.1/Circ.1380.
3 Interpretation on partial reduction in propulsion capability
SOLAS
Chapter II-1
Interpretation on partial reduction in propulsion capability (13-03)
With regards to SOLAS Chapter II-I, Regulation 26.3, the
Netherlands Shipping Inspectorate states the following interpretation:
NSI may accept that, under specific conditions as set out in
individual class rules, a partial reduction in propulsion capability from “normal
operation” in lieu of the carriage of spare pumps on vessels with multiple engines
driving a single propeller shaft or multiple engines driving multiple propeller
shafts provided the reduced propulsion power capability is at least forty percent of
the total rated propulsion power of the vessel.
Meanwhile, the IACS
technical Committee has been asked by the NSI to look into this subject, which was
confirmed by the IACS organisation.
4 Damage stability unmanned towed barges (11-18)
SOLAS
Chapter II-1
Damage stability unmanned towed barges (11-18)
Unmanned towed split hopper barges need only to comply with damage
stability criteria of the DR-68 when a reduced freeboard based on DR-68 is assigned.
When the hopper barge is only allowed to sail at the international load line
draught, no damage stability criteria apply.
5 Sailing with open top conditions (13-22)
It is recognised that MSC.1/Circ.608 cannot easily be applied to general cargo and heavy cargo ships. In particular the required survival condition with a completely flooded hold is problematic as the permeability of the cargo is unknown. From ship operators with ‘open top’ ships, we learned that the current practice –calculating with 0.5 metres of water on the tank top and tween deck- reflects the actual situations encountered during voyages.
The records of shipowners demonstrate that open top ships do not take over significant amounts of water over the coamings. In the first and second meeting good progress was made, resulting in good confidence for a formalisation of the existing practice. However, after exchange of some e-mails and accompanying experiences, the scientific motivation appears problematic. This may eventually hinder the motivation of the proposed equivalent arrangement. To solve this matter external expertise is sought in order to determine which solution may be the best.
6 Class suspension and 'Stip-notation' (10-47)
1. Class suspension:
'Class suspension' is a situation that the ship temporary does not meet the class requirements. The Classification Society (RO) shall inform the Netherlands Shipping Inspectorate (NSI), when the class of a ship under Netherlands flag is suspended, according the standing agreement between the RO's and NSI.
According the IACS procedures:
Class may be suspended following a decision made by the Society when one or more of the following occurs:
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when a ship is not operated in compliance with the Rule requirements
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when a ship proceeds to sea with less freeboard than that assigned
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when the owner fails to request a survey after having detected defects or damages affecting the class
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when repairs, alterations or conventions affecting the class are carried out without requesting the attendance of a surveyor
In addition, class is automatically suspended:
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when the class renewal/special survey has not been completed by its due date or within the time granted in special circumstances for the completion of the survey, unless the ship is under attendance by the Society's surveyor(s) with a view to completion prior to resuming trading.
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when the annual or intermediate surveys have not been completed by the end of the corresponding survey time windows.
Suspension of class with respect to the above cases will remain in effect until such time as the due surveys and any other survey deemed appropriate by the Society have been completed.
In addition to the circumstances for which automatic suspension may apply, the class of a ship will be subject to suspension procedures following a decision of the Society:
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when a recommendation/condition of class is not dealt with within the time limit specified, unless it is postponed before the due date by agreement with the Society
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when one or more other surveys are not held by their due dates - or the dates stipulated by the Society also taking into account any extensions granted
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when, due to the nature of reported defects, the Society considers that a ship is not entitled to retain its class even on a temporary basis (pending necessary repairs or renewals, etc.)
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in other circumstances where the owner fails to submit the ship to a survey in accordance with a special requirement.
In all cases suspension will remain in effect until such time as matters are rectified and the class is reinstated or class is withdrawn.
Depending on the Society’s procedures, the suspensions of class which are not automatic may take effect either when they are decided by the Society or from the date when the conditions for suspension occurred. However once the conditions for class suspension/withdrawal are met and before any decision by the Society can be taken, either because the Society is not aware of the circumstances (surveys dates, etc. are recorded but not systematically monitored) or because the decision is not yet taken, maintenance of class cannot generally be confirmed by the Society during this period.
Notification of suspension or withdrawal when class is suspended or withdrawn, the Society will at the same time:
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inform the owner, flag Administration and underwriters (the latter at their request)
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publish the information on its website and convey the information to appropriate databases (Equasis, etc.)
Validity of the certificate of classification. A certificate of classification, properly endorsed, is valid until the expiry date unless advised otherwise by the Society or provided there are no grounds for suspension or withdrawal of class.
Formally, the ship is not classed anymore and doesn't meet the Ships Decree 2004, article 37, paragraph 2 requirement. It is our view, in close consult with our legal department (HDJZ), that this article gives NSI the legal ground to suspend the Statutory certificates.
When decided, the suspension of the statutory certificates will be carried out based on the Ships act, article 7, paragraph 3.
Automatic suspension of the Statutory certificates, in case of class suspension is not the issue and will be decided on a case by case situation and in close consult with the shipowner.
In the agreement and the IACS procedures, information to the flag Administration is arranged.
Information should also be provided by the shipowner and is a legal omission when forgotten. In case the NSI has been informed by the RO of the class suspension and not by the shipowner, the shipowner may be contacted by the enforcement department of NSI.
The shipowner should contact the RO to agree upon the corrective actions to be taken.
2. Stip-notation or equivalent class notations
In general the IACS document gives the following information:
CLASSIFICATION NOTATIONS
Classification notations are indicative of the specific Rule requirements which have been met. Additional voluntary notations are offered by individual Societies and may be selected by an owner wishing to demonstrate that the vessel conforms to a particular standard that may be in excess of that required for classification. Depending on the Classification Society, the classification notations are assigned to the ship according to ship type, service, navigation and/or other criteria which have been provided by the owner and/or builder, when requesting classification.
Classification notations assigned to a ship are indicated on the certificate of classification as well as in the Register of Ships published by the Society. These notations can be generalized by the following types which may be used in combination:
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main class symbol
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construction marks
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service notations with additional service features, as applicable
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navigation notations
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geographic notations
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additional class notations
According the Ships Decree 2004, article 37, paragraph 2, the ship is built and maintained according the Rules of a Classification Society, where such rules do not conflict with the requirements of this Ships Decree 2004. (See the legislation for the formal wording).
As long there are no conflicting requirements, NSI will accept the class notation.
An other important subject is that these notations are in line with the procedures within IACS.
7 Automatic switch off for electric heating of tanks (15-05)
Due to the accident on a ship with an explosion in an empty fuel tank caused by the electric heater which did not switch off automatically, NSI decided to change the status of IMO circular MSC.1/Circ.1321 into policy rule.
8 Periodical testing of the UMS provisions (15-07)
For some ship with former UMS notation of NSI the evidence of the checking/testing of alarms and indicators is missing. This may cause problems by PSC or other authorities.
NSI urges shipowners to instruct crew of concerned vessels and arrange in the Planned Maintenance System of the vessel or otherwise that periodical testing (at least every 4 months) of the Unmanned Machinery Space (UMS) provisions is arranged and sufficiently documented.
ROs should verify during each safety construction survey for concerned vessels that above requirement is sufficiently addressed.
9 Sliding watertight doors
According to Ship’s Decree 2004, Article 41.2, concerning the application of SOLAS Chapter II-1 and Chapter II-2, a cargo ship of less than 500 GT and with a length equal or greater than 24 m, is treated equally as a cargo ship of 500 GT. Reference is made to SOLAS Chapter II-1, regulation 13-1.2, which requires “doors provided to ensure the watertight integrity of internal openings which are used while at sea to be sliding watertight doors capable of being remotely closed from the bridge and are also to be operable locally from each side of the bulkhead.”
The fitting of sliding watertight doors onboard cargo ships of less than 500 GT is not always practicable. MSC.1/Circ.1464/Rev.1, as corrected (applicable for ships which are built before 09-06-2017) and MSC.1/Circ.1572 (applicable for ships which are built on or after 09-06-2017) provides a UI to SOLAS Chapter II-1 relating to doors in watertight bulkheads of passenger ships and cargo ships. In a footnote it is stated that small cargo ships not subject to statutory subdivision and damage stability requirements are allowed to be fitted with a hinged quick–acting door.
MSC.1/Circ.1464/Rev.1, as corrected and MSC.1/Circ.1572 may be used when applying SOLAS Chapter II-1, regulation 13-1.2 for cargo ships of less than 500 GT and with a length equal or greater than 24 m for the fitting of a hinged quick–acting door instead of a sliding watertight door provided the hinged quick-acting door complies with the requirements of SOLAS and MSC.1/Circ.1464/Rev.1, as corrected and MSC.1/Circ.1572 as applicable.
10 Structural tank testing
SOLAS Chapter II-1, regulations 11.2 and 11.3 requires all tanks of new ships to be tested under water pressure. IACS in UR S 14 is providing alternative provisions to the requirements of SOLAS Chapter II-1, regulations 11.2 and 11.3 which have been submitted to IMO SDC-1 (SDC 1/INF.13) for consideration. In an effort to work towards amending SOLAS Chapter II-1, regulation 11 (Initial testing of watertight bulkheads, etc.) no consensus could be found leading to the conclusion that there is no need to amend SOLAS Chapter II-1, regulation 11.
Recalling that IMO SDC-2 noted that alternative arrangement systems can be considered on a case-by-case basis by Administrations the Netherlands has done an analysis so as to provide the acceptance criteria for an equivalent arrangement.
Based on the analysis performed by the Netherlands and careful review of IACS UR S 14, the conclusion is that IACS UR S 14 is providing an adequate safety level and may be considered as an equivalent to SOLAS Chapter II-1, regulation 11.2 and 11.3 under the following conditions:
- The tank testing plan shall be reviewed and confirmation of the structural similarity of tanks as stated in IACS URS 14, as amended shall be provided by the RO’s plan approval department;
- The shipyard where the ship is being built shall have in place a certified quality management systemaccording to a recognized standard, e.g. ISO 9001 or an equivalent standard acceptable to the RO which ensures the shipbuilding quality standard covering the production process; and
- The RO shall have experience with the shipyard and its records so that the provisions of IACS UR S 14 are considered adequate for the purpose of ensuring the required tightness and structural strength of watertight boundaries.
The equivalent arrangement containing the conditions under which IACS UR S 14 may be accepted (see item 1 to 3 above) is notified to IMO with GISIS reference number XQ41024.
It is not necessary to issue an exemption however the GISIS reference shall be used as appropriate on the ships file for traceability (e.g. in the approval letter).
11 Redundancy of ship's whistle
SOLAS II-1 regulation 43.2.4.4 requires that with regard to the emergency source of electrical power, the intermittent operation of the ship’s whistle is guaranteed for a period of 18 hours, on the assumption that this equipment is considered an “essential safety service” (reg.43.2).
COLREGs however, where the requirement for a ship’s whistle is established (article 35), and where the technical specifications for this equipment are laid down (Annex III), does not have provisions for redundancy of the ship’s whistle. Nor does it specify the required means of activation of the ship’s whistle.
This brings about a lacuna in the legislation as soon as a means of activation other than electricity is chosen for the ship’s whistle, for instance air.
A question was raised by one RO whether a redundancy is required in such cases.
The position of NSI on this issue is as follows:
Bearing in mind that the ship’s whistle is regarded, through SOLAS II-1 regulations 43.2 and 43.2.4.4, as an essential safety service, the operative requirements (i.e. 18 hours operation after power breakdown) should be guaranteed at all times, irrespective of the means of activation (i.e. electric or non-electric).
How this is guaranteed in the case of non-electric activation (e.g. air) is left to the discretion of the shipowner, as far as the provisions fall within the technical requirements of COLREG Annex III.
Examples of possibilities to provide the required redundancy are (e.g. in the case of air driven whistle) entire duplication, extra compressors, a compressor with larger capacity or an extra electric driven whistle.
Vessels flying the Dutch Flag, built on or after the publication of this document, shall comply with the interpretations provided above.
12 Manual closing devices under the waterline (13-02)
For machinery spaces intended for unattended operations, the location of the controls of any valve serving a sea inlet, a discharge below the waterline and an emergency bilge system is to be such as to allow adequate time for operation in case of influx of water to the space.
The adequate time should allow enough time after the bilge level alarm in the engineer's quarters is sounded for the crew to close the valves mentioned. If for example, the valves are operable from the tank top floor and subsequent to sounding of the bilge level alarm the water level would not raise above the tank top floor in the time allowing closure of the necessary valves, such time would be considered as the “adequate time.”
A time of 10 minutes is to be used as a minimum benchmark for the 'adequate time'; if a designer selects a lesser time, the basis shall be submitted and the owner is to be made aware of the same.
In enclosed documents the applicable requirements are mentioned:
- MSC.1/Circ.1424, Unified interpretation of SOLAS Regulation II-1/48.3.
- IACS recommendation nr.100: IACS recommended practice on the time requirement for thoroughly closing sea inlets and discharges below the waterline in case of influx of water.
- Resolution A.1021(26) CODE ON ALERTS AND INDICATORS, 2009.
- IACS Unified Interpretation (UI) SC 251 on controls of emergency bilge suction valve in periodically unattended machinery spaces (SOLAS regulation II-1/48.3) as guidance.