Chapter III - Life-saving appliances and arrangements
1 Format of the musterlist (10-40)
Format of the musterlist (10-40)
indicated that several flag states have specific instructions for approval of the
format of musterlist, as required by SOLAS Chapter
III Regulation 37.8. It was questioned whether NSI has similar instructions,
or whether NSI intended to provide such instructions.
The position of NSI on this subject is as follows:
First of all SOLAS III/37.8 is only applicable to passenger ships. This
means that only the format of the musterlist on this specific category of ships must
be approved. And the RO is authorised, through the Class Agreement, to perform this
approval on behalf of NSI as part of the statutory surveys.
Subsequently it must be established against which provisions the format of the
musterlist has to be approved. As IMO does not specify those provisions, the only
relevant provisions are those mentioned in Regulation 37 itself. In other words:
does the musterlist specify which crewmember is responsible for what, and are all
aspects of Regulation 37 addressed in this respect?
NSI is of the view that no separate flag state instruction is needed for this
purpose. The RO may use its own checklist or one of another flag state, as long as
all aspects of Regulation 37 are addressed.
NSI has observed that the examples of checklists from other flag states contain
items that go beyond the provisions for the format of the musterlist, e.g. the
execution of drills, etc. These subjects however are captured elsewhere in SOLAS
Chapter III, and should be assessed during the regular (annual) surveys.
2 Testing and requirements pilot ladder (11-04)
Testing and requirements pilot ladder (11-04)
question was raised by one RO whether the 15 degrees adverse list criterion of SOLAS V/23 (reg.184.108.40.206.4) should also be
considered when determining the transferability requirement of regulation V/23.3.2.
The reason for this question was the delivery of a vessel to
which V/23.3.2 applied, but which could only transfer the equipment (i.e.
accommodation ladder in conjunction with a pilot ladder) up to a list of 5 degrees
due to the limitation of the deck cranes.
In determining our
position on this matter NSI consulted the Dutch Pilot Association (DPA) for their
view on this subject, being the major stakeholder (at least from a safety point of
view) with regard to pilot transfer arrangements.
The position of NSI on this issue is as follows:
The most significant viewpoint of DPA is that a ship rolling with lists
of up to 15 degrees is considered to be a realistic operating condition during pilot
This means that in accordance with V/220.127.116.11.4, an
adverse list of 15 degrees always has to be taken into account for determining the
distance from the water surface to the point of access to, or egress from, the
When this distance exceeds 9 meters, an accommodation
ladder in conjunction with a pilot ladder has to be provided (i.a.w. V/18.104.22.168) on
each side of the vessel, unless the equipment is capable of being transferred for
use on either side (i.a.w. V/23.3.2).
Transferring for use on
either side of the vessel has to be possible under the conditions mentioned in
V/22.214.171.124.4 (i.e. also with adverse list of up to 15 degrees).
For the requirements and testing of the accommodation ladders reference is made to
MSC.1/Circ.1331, which should be applied as
the Netherlands gave this circular the status of Policy Rule.
3 Launching rescue boat (11-21)
Launching rescue boat (11-21)
With regards to the
launching test of the rescue boat at a speed of up to 5 knots in calm water
(according to SOLAS III/17.3) it was decided
that this test should be executed. For series of exactly the same (sister) vessels
this test is only required for first vessel in series.
4 Extensions on lifejackets
Extensions on lifejackets (Tripartite 10-53)
new SOLAS regulation III/7.2.5, in force as of 1 July 2010, reads as follows: "If
the adult lifejackets provided are not designed to fit persons weighing up to 140 kg
and with a chest girth of up to 1750 mm, a sufficient number of suitable accessories
shall be available on board to allow them to be secured to such persons." This
requirement does not specify a certain number or percentage of suitable accessories
for corpulent persons to be provided. It is the ship owner’s responsibility to
ensure that a sufficient number of suitable accessories for corpulent persons is
provided, where necessary.
5 Embarkation arrangement for remote liferaft
Embarkation arrangement for remote liferaft
adheres to IACS UI SC 213 for this purpose, which implies that the provision with
regard to knotted ropes applies to ships contracted for construction on or after 1
6 Davits without mechanical stored power for the rescue boat (CI 2013-13)
SOLAS chapter III and the LSA Code stipulate that the launching appliance of a rescue boat shall not depend on any means other than gravity or stored mechanical power which is independent of the ship's power supplies.
The Netherlands issued an equivalent arrangement (SLS.14 Circular 153) for slewing out light rescue boats. Rescue boats (including outboard engine), under 550 kg, are allowed to be slewed outboard using manpower. Cranking up a rescue boat from a stowing cradle, if applicable, the Netherlands consider part of this manual slewing procedure and therefore part of this equivalent arrangement. For rescue boats to which this equivalent arrangement does not apply, the stored power / gravity rule applies.
Furthermore, SOLAS Chapter III, Regulation 14.1 states that: Rescue boats shall be stowed in a state of continuous readiness for launching in not more than 5 min. The arrangement of any rescue boat, disregarding its weight, shall be in compliance with this requirement. Meaning including any necessary manual hoisting from a stowing cradle if applicable.
7 Soaking insulation rescue- and lifeboats (15-12)
Recent accident investigations revealed an increase of weight of a rescue boat and a lifeboat as a result of polystyrene soaked with water.
Ship owners, Classification Societies and service companies are advised to pay special attention to surface damages of the polyester outer skin of lifeboats and rescue boats during maintenance and surveys. Especially if damages allow contact of water with the inner polystyrene (open cell) floating compartments. If any doubts arise the actual weight of the boat shall be determined and compared with the original manufacturers weight specification. Overweight boats, exceeding the SWL of the launching appliances, falls, etc. and taking into account that the life- or rescue boat is fully loaded, shall be replaced.
8 Descent devices used for emergency disembarkation (15-12)
SOLAS Chapter III, Regulation 11 and the LSA code under chapter VI regulate embarkation from a ship in case of an emergency. Regulation 11.7 stipulates that administrations may permit that embarkation ladders can be replaced by approved devices to afford access to the survival craft when water born, provided that there shall be at least one embarkation ladder on each side of the ship. For remote life rafts required by SOLAS Chapter III, Regulation 126.96.36.199 ‘other means of embarkation’ enabling descent to the water, as long as controlled lowering is guaranteed, may be permitted.
The Netherlands Shipping Inspectorate supports this passage under the condition that documentation as well as information regarding the practical use of an alternative descent system, is available. This may be explained via a video instruction. An example of non compliance would be a system, meant for the last man leaving the ship, having a complicated harness attached to a lowering device which is difficult to use wearing a survival suit in combination with 3 fingered-gloves. These systems shall, at all times, take the worst possible weather conditions into account.
9 Illumination of stowage and launching area of a remote life raft
SOLAS Chapter III, Regulation 11. 4 & 16.7 state that muster and embarkation stations shall be adequately illuminated by lighting supplied from the emergency source of electrical power required by Regulation II-1/42 or II-1/43, as appropriate. For a period of 3h, emergency lighting at every muster and embarkation station including overboard deployment area’s are required by Regulations III/11.4 and III/16.7. The IACS unified interpretation SC213 confirms the need of proper illumination of muster and embarkation stations supplied from the emergency source of electrical power.
NSI does not consider a rechargeable handheld torch, which does not provide adequate illumination, placed on a non directional ‘bracket’, as meeting the requirements of these regulations. According to NSI handheld narrow beam torches will not provide adequate illumination to launch and board a survival craft in dark hours. Especially in bad weather conditions and with a rolling ship.
10 Rotation resistant and corrosion resistant steel wire rope
MSC Resolution 218(82) entered into force on 1 July 2008, amending, among others, LSA Code 188.8.131.52. This regulation concerns life- and rescue boat falls and their composition, being rotation resistant and corrosion resistant steel wire rope. This regulation is applicable for systems installed on ships with a keel lay date from 01 July 2008.
Since this regulation was amended, practical experience shows that for some launching systems these wires are not always compatible with existing systems. Sheaves and/or wire drums may have a diameter which do not allow falls to run properly within their normal scope of operation. In case of the above, NSI is of the opinion that the manufacturers manual specifications and recommendations for fall wires should be used.
In any of these cases NSI shall be informed including a well documented proposal why the LSA Code cannot be adhered to. NSI shall grant permission on a case by case basis.