SOLAS
Chapter V - Safety of navigation
1 Definition of bridge wing (11-10)
SOLAS
Chapter V
Definition of bridge wing (11-10)
In accordance
with SOLAS Chapter V, regulation 19.2.1.8 ,
when the ship’s bridge is totally enclosed and unless the Administration determines
otherwise, a sound reception system, or other means, to enable the officer in charge
of the navigational watch to hear sound signals and determine their direction shall
be provided for all ships irrespective of size.
The position of NSI on this issue is as follows:
Overreliance on sophisticated navigational systems must be countered by
the appropriate management of bridge resources, a thorough assessment of the risks
of the passage, contingency plans for when the system fails and good navigational
watch keeping practices at all times.
Regarding the watch keeping practices every vessel should at all times maintain a
proper look-out by sight and hearing, including maintaining a listening watch, as
well as by all available means appropriate in the prevailing circumstances and
conditions so as to make a full appraisal of the situation and of the risk of
collision.
This interpretation aims to provide clarification as to the application of SOLAS
V/19.2.1.8 and in this respect define the expression “totally enclosed ship’s
bridge” in a concrete and practical manner as well as elaborate on the expressions
“unless the Administration determines otherwise” and “or other means” in subject
regulation. Vessels flying the Dutch Flag, built on or after the publication of this
document, shall comply with the interpretations provided below.
References:
- SOLAS V/15
- MSC/Circ.982
- IACS UR 95
- ISO 14612
- STCW Convention and Code, as amended
- Colreg.’72
-
Interpretation of “totally enclosed ship’s bridge” and “unless the
Administration determines otherwise.”
IACS UR 95 and
ISO 14612 provide the following definitions:
Bridge: The
area from which the navigation and control of the ship is exercised, including the
wheelhouse and bridge wings.
Bridge wings: Those parts of the bridge on both sides of the ship’s
wheelhouse which, in general, extend to the ship’s side.
Catwalk: extension to a deck outside a
totally enclosed bridge wide enough to allow the safe passage of a person.
Navigation bridge:
Area of a wheelhouse or enclosed bridge allocated navigating functions and control
of the ship, and which includes any additional bridge workstation to be used by
the officer of the watch.
Totally enclosed bridge: A bridge
without open bridge wings, meaning that bridge wings form an integral part of an
enclosed wheelhouse.
Wheelhouse: Enclosed area of the bridge.
A catwalk
is primarily provided to help maintenance of window wipers and manual cleaning of
bridge front windows. Typically the width of a catwalk is limited and it’s
construction at both sides of the wheelhouse usually consists of gratings,
screened off with railings. Catwalks are most commonly entered from an open deck
space behind the totally enclosed bridge via a door or doors at the portside -
and or starboard side rear end of the totally enclosed bridge.
Vessels with a totally enclosed bridge, also when provided with a catwalk, shall
be equipped with a type-approved sound reception system. In this respect it is
emphasized that a catwalk is not considered as an equivalent for a(n) (open)
bridgewing. This follows instantly from the definitions above, as the definition
of a catwalk is linked to a totally enclosed bridge, which has per definition no
open bridge wings. SOLAS V/15 dictates that the bridge team and pilot have
convenient and continuous access to essential information. NSI
considers the reception of sound signals to be essential information. Consequently
open bridge wings shall be accessible by means of doors placed at both sides of
the ship’s bridge.
In the case of an enclosed wheelhouse (either
with or without a catwalk) a door or doors positioned at the portside - and or
starboard side rear end of the wheelhouse do not qualify as convenient and
continuous access.
-
Interpretation of “or other means”
Up until
the date of this document, NSI considered the provision of windows, that can be
opened, at both sides of a totally enclosed bridge as an equivalent for a sound
reception system. Owing to insight gained from field-surveyor’s feedback, this
equivalency can no longer be considered.
2 Performance Monitor extra radar
SOLAS
Chapter V
Performance Monitor extra radar
A question was
raised by one RO whether radars which are installed in addition to the required
equipment in accordance with SOLAS V/19, are
required to be equipped with a performance monitor (PM). The reason for this
question was that a vessel was delivered with two radars but only one PM, however no
argument was given for the absence of the second PM other than the second radar
being additional.
After consulting suppliers of this equipment
about the practical issues regarding the availability and added value of a
performance monitor, the following conclusions came up:
- A PM assesses the proper functioning of the radar’s transmitter and receiver.
The value of the PM is to give confidence in the proper functioning of the radar
in the absence of echo’s, in particular in circumstances of reduced visibility.
- Due to the introduction of new technologies and carriage requirements like AIS,
and the required link of AIS with the radar (in accordance with MSC.192(79)), the added value of a PM has surely
diminished, but not completely vanished.
- The reluctance of shipowners to install a PM for additional radars arises
sometimes from practical grounds (lack of space), but in particular from economic
grounds.
Based on the above conclusions the position of NSI on this issue is as
follows:
Bearing in mind the requirement of SOLAS V/18.7 with regard to additional
equipment, NSI is of the view that in principle an additional radar shall comply
with all provisions of the performance standard MSC.192(79), including the provision
of a performance monitor.
Bearing in mind the clause in SOLAS
V/18.7 stating “whenever practicable”, NSI may in the rare occasion that installing
a PM is demonstrated to be inevitably impracticable, decide on a case-to-case basis
to grant an individual exemption for this purpose.
Vessels flying
the Dutch Flag, built on or after the publication of this document, shall comply
with the interpretations provided above.
3 Redundancy of ship’s whistle
SOLAS
Chapter V
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.
4 BNWAS issues (11-11)
SOLAS
Chapter V
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
follows:
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 19.2.2.4 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/19.2.2.3). 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:
S-VDR:
Par.5.4.9 of MSC 163(78) (performance standards S-VDR) reads as follows:
Other items
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 this.
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.
5 BNWAS (11-14)
SOLAS
Chapter V
Bridge Navigational Watch Alarm System (BNWAS; Tripartite 11-14)
IMO resolution MSC.282(86) has become applicable for
certain types of vessels as regards to the carriage of a bridge navigational watch
alarm system (BNWAS). It concerns the new regulation 19.2.2.3 and 19.2.2.4 of SOLAS
chapter V. Regulation V/19.2.2.4 determines that Administrations may exempt BNWAS’s
from full compliance with the standards adopted by the IMO (i.e. resolution
MSC.128(75)) when they are installed prior to 1 July 2011.
NSI’s Regulation Seagoing Vessels already gives effect to MSC.128(75) for BNWAS’s
installed on or after 1 July 2009.BNWAS’s installed on Dutch flag vessels before
this date are exempted from full compliance with resolution MSC.128(75) provided
they comply with the provisions in force before that date (i.e. Notice to Shipping
nr.234/1988) or, when it concerns vessels transferred to Dutch register from a
register of another Administration, provided the BNWAS was approved by the
Administration of the previous flag.
The Regulation Seagoing
Vessels will be amended to incorporate this exemption. Until this has been effected
NSI should be consulted in case of comments from –or discussions with- PSC
surveyors.
6 BNWAS issues (11-11)
SOLAS
Chapter V
BNWAS issues (11-11)
Further to our Information
to Shipping no.1 and 2 regarding this subject, clarification is given on existing
systems:
Compliance with the relevant national requirements (i.e.
Notice to Shipping No.234/1988 for
Netherlands flag vessels) needs not necessarily be demonstrated through a type
approval certificate, but may also be documented otherwise or through a functional
check.
Alternatively, when it concerns vessels transferred to
Netherlands flag from a register of another Administration, demonstration of
compliance with the applicable requirements of that Administration in force before 1
July 2009 may be effected in a similar way.
7 Carriage of digital nautical publications
SOLAS
Chapter V
Carriage of digital nautical publications
Official digital publications are permitted in order to meet the carriage
requirements for nautical charts and publications (Ref. SOLAS V/2.2, V/19.2.1.4,
V/19.2.1.5, V/27). They shall be issued by or on the authority of a Government,
authorized Hydrographic Office or other relevant government institution and be
adequate and up to date.
Due to the fact that SOLAS V/2.2,
V/19.2.1.4 and V/19.2.1.5 refer to digital publications they are permitted by virtue
of the mentioned SOLAS regulations. In this respect a separate Flag State approval
is not relevant.
Please note that in accordance with SOLAS V/19.2.1.5 back-up arrangements are
required in the event that nautical charts and/or nautical publications are provided
partly or fully in digital format.
As far as digital nautical charts are concerned the Dutch Maritime Administration
has issued an equivalent arrangement, SLS.14/Circ.191.
Regarding back up arrangements for digital nautical publications the Dutch
Administration has at present not issued an equivalent arrangement or specific
instructions.
So far as is known IMO has not issued any
instrument providing guidance in this matter.
However, when it concerns Dutch flag vessels reference is made to similar
provisions for ECDIS back-up, which are captured in par.3.1.8 of appendix 6 to MSC.232(82):
Those provisions are the following:
- Facilities enabling a safe take-over of the functions in order to
ensure that a failure does not develop into a critical situation;
- Means to provide for safe navigation for the remaining part of the voyage in
case of failure;
- Inclusion of a timely transfer to the back-up system during critical navigation
situations;
- The information to be used in the back-up system should be the latest edition,
as corrected by official updates, of that issued by or on the authority of a
Government, authorized Hydrographic Office or other relevant government
institution. The information displayed should be up-to-date for the entire
voyage;
- It should not be possible to alter the contents of the electronic
information;
- Edition and issuing date of the electronic publication should be indicated;
- The back-up arrangements should provide reliable operation under prevailing
environmental and normal operating conditions;
- If an electronic device is used, it should provide a suitable alarm or
indication of system malfunction;
- If an electronic device is used, the back-up power supply should be separate
from the power supply of the main system, and conform to the requirements of the
ECDIS performance standards.
In conclusion:
The application of digital nautical
publications is permitted by SOLAS. In this case a back up is required in accordance
with SOLAS V/19.2.1.5; SOLAS does not provide any specific requirements regarding
back up provisions for digital nautical publications. In this respect NSI refers to
the above-mentioned guidelines which provide a clear and concrete reference
framework. As such sufficient back up is provided in the event of failure of the
“primary system”.
8 BNWAS issues (CI 2012-14)
SOLAS regulation V/19.2.2.3 requires that BNWAS shall be in operation whenever the ship is underway at sea. The performance standards, required by V/18 however require BNWAS to incorporate an automatic mode which shall be brought into operation whenever the ships heading or track control system is activated and inhibited whenever this system is not activated.
Since both requirements cannot be fulfilled at the same time, the IMO issued interim guidance under MSC.1/Circ.1474.
It is expected that the performance standards will be brought in line with SOLAS V/19, (MSC94 November 2014 decision). As long as no final decision has been taken on this issue, NSI considers the interim guidance Circ.1474 policy rule.
This means that, pending the revision of the performance standards, on Dutch flagged SOLAS ships, the automatic mode on BNWAS, if it is available, shall not be used.
9 Voyage Data Recorder reminder request by the EU Commission (15 -15)
SOLAS Chapter V, Regulation 20 of the Safety of Life at Sea Convention (SOLAS) requires a VDR to be fitted to all passenger vessels and all cargo vessels of 3000 gross tons or more. SOLAS Chapter V, Regulation 18.8 of SOLAS requires VDRs to be subjected to an annual performance test by an approved testing or servicing facility to, inter alia, "…verify the accuracy, duration and recoverability of the recorded data…"
In May 2015, EU member States received a request from the EU Commission to inform shipowners regarding the worrying results of a survey done related to Voyage Data Recorders. In summary, the survey identified that between 2012 and 2014, data could not be recovered from more than one third of the VDRs interrogated by marine accident investigators. The reasons for this were mainly either system malfunctions or incorrect procedures when ships’ crews attempted to save VDR data following the accident. European and therefore also Dutch ship owners are kindly reminded of their responsibilities under SOLAS to ensure VDR’s are installed, maintained and operated on their vessels in a manner which will allow important data to be saved, stored and available to marine accident investigators following a marine casualty.
10 Nautical Publications in electronic format on board Dutch flagged ships
Nautical publications provided in electronic format shall, as stipulated in SOLAS Chapter V, Regulation 19.2.1.4 & .5, also have back-up arrangements in place. The back-up arrangement for nautical publications shall consist of a data storage facility including means of presenting and printing. This arrangement shall be separate from the main facility and preferably be located close to, or on the navigation bridge.
The main computer shall, as a minimum meet the IEC 60945 standard as amended where the backup may meet the EMS requirements from this standard only. Both computers shall meet the requirement of SOLAS Chapter V, Regulation 17 regarding electromagnetic compatibility. At all times, the computers shall meet any requirements as stated by the supplier of the electronic publications. Furthermore, the following is required:
- Since nautical publication may be consulted during night time hours, displays, screens and peripherals shall be visible, dimmable and clearly readable at all times;
- Software used on both the main as well as the backup computer may differ in format as long as it is compatible with the software used for the nautical publication;
- Both the main as well as the backup facility shall be capable of printing;
- Both the main as well as the backup facility shall have up to date antivirus software installed;
- Both the main as well as the backup facility shall be kept up to date with weekly NtM’s;
- If the software is installed on a network, via a LAN application, this network shall be redundant.
11 LRIT ‘Not Reporting Procedure Netherlands’ (15-26)
The Netherlands flag State actively monitors LRIT reporting of ships flying her flag. Ship owners of ships which do not report as required, receive a standard notification by e-mail. This e-mail, usually send to the Company Security Officer, requests the ship’s crew to perform an LRIT equipment log-out / log in.
A conformation by e-mail, that the log out/ log in took place, is send back to the flag State LRIT department, which on its turn restarts the LRIT unit. If it turns out that the first attempt to reset the unit did not succeed a second standard e-mail is send to the CSO and the procedure is repeated.
The procedure used by the flag State is derived from EMSA (LRIT database manager) technical note 8 latest edition. Furthermore it is important for ship owners to realize that changing (parts of) Inmarsat and/or LRIT equipment, including change-out of antenna’s, subsequently lead to the necessity to perform a new conformance test (CTR) for LRIT. This test shall be done by an ASP (application service provider) as indicated on the website mentioned below. A copy of this CTR must be send to info@agentschaptelecom.nl with a request to integrate the ships LRIT unit into the EU (EMSA) LRIT database.
Ship owners are responsible to report any changes in existing or new onboard LRIT systems to the correct department of Agentschap Telecom (AT). Please note that the LRIT counter at Agentschap Telecom is a different counter than the MMSI/Inmarsat counter. More information regarding LRIT on Dutch flagged ships can be found on the ILT website.
12 ECDIS
ECDIS manufacturers, type approval organizations, Classification Societies, ship owners, operators and masters are hereby informed that, as from 31 August 2017, IHO standards S-52 Edition 6.0 / Chart Content and Display Aspects, Presentation Library Edition 3.4 and Standard S-64 Edition 2.0 / Test Data Sets, are no longer valid for existing ECDIS systems type approved with an edition of IEC61174 previous to the 4th edition.
It is the view of the Netherlands Shipping Inspectorate that from01 September 2017 ECDIS systems which do not fulfill the aforementioned hard- and software requirements, and subsequently cannot present ENC’s according to the latest IHO standards, cannot be considered as meeting the chart carriage requirements of SOLAS Chapter V, regulation 19.2.1.4, nor as meeting the qualification of ‘up to date’ nautical charts referred to in SOLAS Chapter V, regulation 27. This is also clearly explained in MSC.1/Circ.1503/rev.1 .
It is the responsibility of the company and the master to ensure compliance with SOLAS Chapter V, regulation 27 and also to ensure that the applicable ECDIS software, and hardware if necessary, was updated before 31 August 2017.
Each ECDIS on board, including those, which are not in use for primary navigation, shall comply with the latest IHO standards.
More details regarding this subject can be found on the website.
13 Carriage of publications
Ship-owners are hereby informed that Guidelines for the carriage of publications on board ships flying the flag of the Netherlands, have been developed by the Association of the Netherlands Ship-owners (KVNR) in cooperation with the Netherlands Shipping Inspectorate.
The main purpose of these Guidelines is to provide guidance in a concise form to ship-owners, operators, Port State Control Officers (PSCO’s) companies and auditor(s) according to the ISM Code and organizations performing the ISM Code certification of the requirements and recommendations of the Netherlands Shipping Inspectorate on the carriage of publications on board of ships flying the flag of the Netherlands which are:
- Explicitly required by the IMO, the ILO and the Netherlands Shipping Inspectorate to be carried on board; or
- Recommended by the Netherlands Shipping Inspectorate to be carried on board.
These guidelines can be found in NeRF .
Ships which, given their size, working area, type of voyages, means of propulsion (or lack of means of propulsion), etcetera, are exempted from complying with certain conventions, regulations, codes or national requirements will show an absence of certificates associated with such conventions, regulations, codes or national requirements. Examples could be manned pontoons and alike. Furthermore such vessels may have none or a limited number of publications on board. In such cases it is up to the master/ship owner’s discretion to place any publications on board. Any publications placed on board under the discretion of the master or ship owner shall be adequate and up to date.
If a National Safety Certificate is issued to a vessel, publications are mentioned on the equipment list attached to the National Safety Certificate and, inherent to this, are part of the relevant surveys. Any publications placed on board as per the equipment list attached to the National Safety Certificate shall be adequate and up to date.
14 Testing and requirements pilot ladder (11-04)
A question was raised by one RO whether the 15 degrees adverse list criterion of SOLAS V/23 (reg.23.3.3.1.4) 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 transfer. This means that in accordance with V/23.3.3.1.4, 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 ship. When this distance exceeds 9 meters, an accommodation ladder in conjunction with a pilot ladder has to be provided (i.a.w. V/23.3.3.2) 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/23.3.3.1.4 (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.