Load line exemptions for dredgers (11-13)
The guidelines for the assignment of reduced freeboard for dredgers, DR-68 (IMO doc. LL.3/Circ.205) prescribes in article 12.3:
If the dredger meets the intact stability requirements of Section 6.1 of these Guidelines without hatch covers, then the ICLL Exemption certificate should also indicate that the dredger is exempted from Regulation 14 (unless this exemption is already noted on the vessel’s ICLL certificate).“
DR-67 and Richtlijn (Guideline) 28 do not specifically prescribe this obligation and in the past NSI has not always mentioned Regulation 14 in the Exemption Certificate.
However, the format of the Exemption Certificate as given in Annex III of the ICLL, clearly states that the articles/regulations for which an exemption is granted must be mentioned.
Consequently from now on with every renewal or extension of the validity of an ICLL Exemption Certificate, based on DR-67 or Richtlijn (Guideline) 28, the exemption from Regulation 14 (if applicable) must be mentioned.
DR-67 and DR-68 rev.1
Based on article 25 of the International Convention on Load Lines, special rules may be drawn up by agreement among all or some of the Contracting Governments, and such rules shall be communicated to the IMO for circulation to all Contracting Governments. In that respect DR-67 and the superseding DR-68 rev.1 have been issued as special rules by a joint working group in which the Netherlands participate. DR-67 and DR-68 rev.1 contain guidelines for the assignment of reduced freeboard for dredgers. To a dredger or a similar ship complying with DR-67 or DR-68 rev.1 and flying the flag of the Netherlands, the following provisions apply:
- Dredgers with reduced freeboard
Application of DR-67, DR-68 rev.1 and SOLAS
DR-67 and DR-68 rev.1 are providing the provisions under which an International Convention on Load Lines exemption certificate can be issued in order to allow for the immersion of the summer load line marks. Therefore DR-67 and DR-68 rev.1 shall apply in full. According SOLAS, a dredger is a cargo ship. This means that for international voyages at summer draught, the SOLAS damage stability regulations are applicable. DR-67 and DR-68 rev.1 are providing an equivalent arrangement accepted for fulfilling the damage stability requirements under SOLAS Chapter II-1, regulation 4.2. This was agreed by the DR-68 Joint Working Group.
- Sailing without hatch covers
Dredgers sailing without hatch covers, regardless of the assigned freeboard, shall hold a Load Line exemption certificate. For that purpose the provisions of DR-67 and DR-68 rev.1 are considered to provide the ground for exemption regarding sailing without hatch covers. DR-68 rev.1 is clearly stating the provisions for sailing without hatch covers and these provisions may be used regardless of the assigned freeboard. DR-67 does not provide similar provisions and the Netherlands flag State Administration has issued relevant instructions on the item: Load line exemptions fo dredgers (11-13).
- Dredgers without assigned reduced freeboard
Dredgers without an assigned reduced freeboard may apply DR-67 or DR-68 rev.1 as applicable based on the understanding that DR-67 and DR-68 rev.1 are equivalent to the damage stability requirements of SOLAS chapter II-1, regulation 4.
- Dredgers with length less than 80 m
Dredgers with a length of less than 80 m are not subject to damage stability requirements of SOLAS chapter II-1, regulation 4. While DR-67 is in line with SOLAS, for ships subject to DR-68 rev.1, damage stability requirements are also applicable to ships with a length of less than 80 m.
- Application of SOLAS chapter II-1, regulation 9 (double bottoms in passenger ships and cargo ships other than tankers)
Notwithstanding the exemption from the damage stability of SOLAS Chapter II-1, regulation 4, for which the mutual understanding is that DR-67 or DR-68 rev.1 is equivalent to SOLAS damage stability, all other regulations of SOLAS are applicable. This means that SOLAS chapter II-1, regulation 9 is applicable to dredgers. In the absence of a common interpretation on how to apply SOLAS chapter II-1, regulation 9 to dredgers, a proposal should be submitted to the Netherlands flag State Administration for consideration.
Open top cargo ships
The Netherlands accepts under certain conditions that general cargo ships may be exempted from the fitting of hatch covers as required by regulation 14 of annex 1 to the International Convention on Load Lines, 1966 protocol, as amended. The guidelines containing the equivalent arrangement and the technical requirements for granting the exemption are notified to the IMO with GISIS No. XQ42482.
An International Load Line Exemption Certificate shall be issued referring to GISIS No. XQ42482.
The form of the International Load Line Exemption Certificate shall be that of the model given in annex III the International Convention on Load Lines, 1966, as amended.
New ships
- The technical requirements as contained in the Equivalent Arrangement for open- top general cargo ships shall apply to new open-top general cargo ships:
- for which the building contract is placed on or after 01 February 2018; or
- in the absence of a building contract, the keels of which are laid or which are at a similar stage of construction on or after 01 July 2018; or
- the delivery of which is on or after 01 July 2024.
- An International Load Line exemption certificate shall be issued to the open-top general cargo ship referring to the equivalent arrangement with GISIS No. XQ42482 .
Existing ships
- Existing open-top general cargo ships for which the keels are laid, or which are at a similar stage of construction, before 01 February 2018 shall comply with the technical requirements as contained in the Equivalent Arrangement with GISIS No. XQ42482, not later than the date of the annual or renewal survey as required by article 14 of the International Convention on Load Lines, 1966, as amended, to be carried out after 01 July 2018, whichever comes first and in no case later than 01 February 2019.
- In case the maximum hourly rate of ingress of green water in any one open hold determined from the model testing (measured in mm3/hour and converted in mm/hour) is more than 66 mm/hour, the following shall apply:
- The stability of an existing open-top general cargo ship in intact condition shall be (re)calculated in accordance with section 6 of the Equivalent Arrangement with GISIS No. XQ42482;
- An addendum to the existing approved stability documents shall be approved by the RO and placed on board.
- In case the maximum hourly rate of ingress of green water in any one open hold determined from the model testing (measured in mm3/hour and converted in mm/hour) is 66 mm/hour or less, the stability of an existing open-top general cargo ship in intact condition is not required to be (re)calculated. The existing approved stability documents may suffice.
- Appropriate text shall be included reflecting paragraph 2 or 3 in the International Load Line Exemption Certificate issued to the open-top general cargo ship.
Transport of woodchip in open top cargo vessel
The Netherlands Shipping Inspectorate received a request for the transport of a bulk cargo (woodchips) with a ship that is certified based on the Dutch "open-top principle".
The Netherlands has played a pioneering role in the development of the "open top principle" for many years and committed itself in IMO. Initially this was only allowed for container ships (MSC/Circ.608/Rev.1).
Fromthe information provided by the applicant, it can be concluded that the transport of woodchips and, to our knowledge also other bulk cargoes, is not allowed on international voyages by other Administrations.
For that reason it is not feasible to apply the "open-top principle" to the transport of bulk cargoes.