BNWAS issues (11-11)
Further to our Information
to Shipping no.1 the Regulation Safety Seagoing Vessels has been amended to include
the provisions of MSC.282(86). Article 24.3 of this regulation now reads as
If a cargo ship with a length of 24 metres or more or a passenger ship has
been equipped with a bridge navigational watch alarm system on or after 1 July
2009 but before 1 July 2011, it shall meet the requirements of resolution MSC.128(75) of the Maritime Safety Committee
of the IMO, involving Performance standards for a bridge navigational watch
alarm system (BNWAS).”
Furthermore, in accordance with the new Regulation 220.127.116.11 of SOLAS Chapter V, the
Regulation Safety Seagoing Vessels has been amended to include an exemption
provision for the BNWAS in Article 41a, which reads as follows:
“Bridge navigational watch alarm systems, placed before 1 July 2009, have
been exempted from the requirements of Resolution MSC.128(75) of the Maritime
Safety Committee of the IMO, involving Performance standards for a bridge
navigational watch alarm system (BNWAS) or equivalent performance standards.”
Although a text for the Record of Safety
Equipment was already agreed, with the amendment of the Regulation Safety Seagoing
Vessels NSI proposes to slightly alter this text to read as follows:
Existing BNWAS, installed before 1 July 2009, which
complies with National requirements at time of installation and is consequently,
in accordance with Article 41a of the Regulation Seagoing vessels, exempted from
full compliance with resolution MSC.128(75)
Furthermore questions have been raised by ROs whether or not an interface between
BNWAS and the (S)VDR is required.
The position of NSI on this issue is as follows:
Even though the BNWAS was not an IMO mandatory requirement until 1 July
2011, it has always been a national requirement for Dutch flag vessels.
Parallel to the requirement of the engine room personnel alarm being
connected to the (S-)VDR, NSI has in the past always required that the BNWAS be
connected to the (S)VDR as well. And even though sometimes challenges were
experienced, and extra provisions had to be made (e.g. additional cables etc.), the
connection between BNWAS and (S)VDR always proved to be feasible.
Moreover, with the SOLAS mandatory carriage requirement for BNWAS as per 1 July
2011, BNWAS has become an IMO mandatory alarm, also for existing vessels (pending on
the category in accordance with new regulation V/18.104.22.168). As a consequence, also
the connection with (S-)VDR has become mandatory.
NSI’s position wrt BNWAS contained in our Information to Shipping No.1 only deals
with the exemption for the BNWAS performance standards, not those for the connection
to the (S-)VDR.
Considering the above, NSI’s position remains that, in principle, the connection of
BNWAS (including existing installations) shall be connected to the (S-)VDR.
An elaboration on this issue provides the following:
Par.5.4.9 of MSC 163(78) (performance standards S-VDR) reads as follows:
5.4.9 Any additional data items
listed by IMO with the requirements set out in resolution A.861(20) should be
recorded when the data is available in accordance with the international digital
interface standards using approved sentence formatters.
Furthermore this paragraph contains a footnote reference, the footnote reads as
follows: Refer to publication IEC 61162.
The text above provides leeway to apply flexibility as far as the connection of the
BNWAS to the S-VDR is concerned in the event that the BNWAS does not provide the
required data for input in the S-VDR.
However, it shall be
established, for instance by means of a declaration from the manufacturer of the
BNWAS, that the required data is not available and that the BNWAS cannot be adapted
For the sake of good order, we draw your attention to the fact that this
flexibility can only be applied in the event of an S-VDR.