1 F-gas Regulation EU no. 517/2014 (15-04)
Concerning the issue of the shipping sector (i.e. equipment on ships containing f-gasses) under the F-gas Regulation (EU no. 517/2014). Although this shipping sector is not explicitly mentioned in the Regulation, it falls under the scope of the Regulation being mobile equipment. For this type of mobile equipment especially the articles (Article 3) on "Prevention of emissions" and (art 8, sub 3) on "Recovery" are directly relevant.
Article 4, 5 and 6 are not applicable for ships and for that reason ships don’t need to use a logbook, don’t need to perform leakage checks and don’t need to install leak detection equipment.
2 Training F-gas Regulation (15-25)
Concerning the issue of the shipping sector (i.e. equipment on ships containing f-gasses) under the F-gas Regulation. Although this shipping sector is not explicitly mentioned in the Regulation, it falls under the scope of the Regulation being mobile equipment. For this type of mobile equipment especially the articles (art. 3) on "Prevention of emissions" and (art 8, paragraph 3) on "Recovery" are directly relevant.
The crewmembers carrying out such workings are to be considered the "natural persons’ mentioned in the Regulation. It is up to the ship owner to arrange the training of its crewmembers in such a way that it is in compliance with article 8 paragraph 3. As already stated under the above item (15-04), article 4, 5 and 6 are not applicable for ships. In article 10 paragraph 1 sub a and sub b a reference to article 4 is made. As stated above article 4 is not applicable on sea going vessels therefore article 10 paragraph 1 sub a and sub b are not applicable onboard seagoing vessels.
Furthermore article 10 paragraph 1 sub c is referencing article 8 paragraph 1. The nature of the equipment mentioned in article 8 paragraph 1 is not applicable on equipment onboard seagoing vessels, hence article 10 paragraph 1 sub c is not applicable onboard seagoing vessels.
In conjunction with the above it is highlighted that certificates of competency issued in accordance with Chapter III of the STCW Convention, as amended, covers, in a generic nature, the needed knowledge, understanding and proficiency to carry out the installation, servicing, maintenance, repair, decommissioning or leak checks of the equipment onboard seagoing vessels. The ships specific knowledge, understanding and proficiency is part the Dutch Manning Act via Article 4.
3 Rights of passengers
The Regulation (EU) No. 1177/2010, concerning the rights of passengers when travelling by sea and inland waterways (and amending Regulation (EC) No 2006/2004) does not cover the construction of the vessels relating to disabled persons and persons with reduced mobility, but non-discrimination against disabled persons and persons with reduced mobility. There is also an obligation for the disabled person to report it when booking. Where the design of the passenger ship or port infrastructure and equipment, including port terminals, makes it impossible to carry out the embarkation, disembarkation or carriage of the disabled person in a safe or operationally feasible manner, they may be refused. Furthermore, article 8 of the EU Directive 2009/45/EC, as amended requires to apply relevant guidelines as far as reasonable and practicable.