The Netherlands Shipping Inspectorate (NSI) has adopted the requirements as per SOLAS regulation II-2/20, paragraph 6.1.4 and 6.1.5 and MSC/Circ.1320 without exemptions. In addition, the 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 need to be submitted by the Classification Society (Recognised Organisation) and approved by the flag state;
- 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 flag state for their approval suggesting temporary measures with equivalent result.
In the past, the NSI examined the information that has been submitted by Classification Societies and other parties. As a result, please find following remarks for your general benefit or 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 are 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;
- 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 (International Safety Management-) 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 NSI 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 undesirable situations in the future we kindly advise ship-owners to verify the chosen solution(s) against the requirements by other relevant Administrations, such as port states and in case of intended change of flag.