The Netherlands Shipping Inspectorate have adopted the requirements as per SOLAS and MSC Circ. 1320 without exemptions. In addition NSI has decided that the following additional guidelines are accepted for vessels flying Netherlands' Flag.
- Only the required scuppers need to be protected, provided that these are distributed as per MSC. Circ. 1320;
- Any equivalent level of safety or exemption offered in relation to this regulation needs to be submitted by the Classification Society and approved by the Flagstate;
- Postponement with regard of compliance to these new requirements is to be endorsed by the Classification Society. The Classification Society shall send a proposal for such a temporary exemption to the Flagstate for their approval suggesting temporary measures with equivalent result;
We have examined the information that has been submitted by RO’s and other parties. As a result please find following remarks for your general benefit cq use in order to obtain approval by the Classification Society for specific vessels/ solutions;
- drain openings with additional vertical grating that does not fully cover the opening in the bulk head is not accepted since waste may gather / be dumped behind the vertical grating thus blocking the primary / original grating;
- the location of scuppers, freeing ports etc. must be evenly distributed in accordance with MSC Circ 1320 (some proposals did not comply);
- removable gratings ("hats"/ "boxes") which are temporarily placed over the scupper for the duration of the voyage, after the vehicles are loaded and removed before unloading, are allowed under the condition that proper (ISM) procedures are in place to guarantee that such gratings are placed whenever required and provided that these gratings are positively fixed in their place, (so not by gravity alone);
- freeing openings at ships sides are to be protected also, unless form / dimensions of such opening are as such that this is considered not necessary to the satisfaction of the attending surveyor;
Please note that the Netherlands Shipping Inspectorate have tried to keep any additional instructions to a minimum so owners and Classification Societies have maximum margin to use at their discretion. However, in order to avoid future unwanted situations we kindly advise shipowners to verify the choosen solution(s) against the requirements by other relevant Administrations, such as Ropax Host States (Ropax/EU Directive 1999/35) and in case of intended change of Flag.