1 Introduction
Date entry into force: 01-04-2015
In accordance with article 40 of the Ships decree 2004, a ship for which a passenger ship safety certificate or a cargo ship safety certificate is required shall satisfy a.o. the requirements of chapter III of the SOLAS Convention applicable to that ship.
This instruction aims to clarify the requirements for SOLAS Chapter III/20.8.2 rotational deployments of MES with respect to the roles that different parties should play in the deployment and the fail criteria for the deployment.
This document also aims to explain the position of NSI with respect to the provision of SOLAS Chapter III/20.8.1.1 to extend the MES service interval.
Through these guidelines, the Netherlands Shipping Inspectorate (NSI) wishes to encourage ship specific training for the use of MES by taking advantage of the rotational deployment as a training opportunity.
2 Background
SOLAS defines a Marine Evacuation System (MES) as an appliance for the rapid transfer of persons from the embarkation deck of a ship to a floating survival craft, and they are becoming more widespread on ships. Whilst they are maintained in readiness by annual servicing, the only opportunity to assess the system ability to deploy in an emergency is the 6 yearly rotational deployment. NSI wishes to ensure that the equipment operates to a required standard at these rotational deployments.
3 Extension of 12 Months Service Provisions
3.1 The Administration’s authority to issue extension of service intervals in excess of the 12 month window, under the provision of SOLAS Ch III/20.08.1.1, is limited to occasions when servicing is impracticable. Extension, when impracticable, should not be confused with inconvenience.
3.2 All applications for extension should be made to the RO well in advance of the 12 month service date. They should clearly state the reason of impracticability and proposed time and place of service. The service history of the MES should be presented in the application. Any extension will not alter the anniversary date.
4 Deployment Preparation of MES
4.1 Rotational Deployment required by SOLAS Ch III/20.8.2 cannot be extended beyond the 6 year period. It is recommended that deployment is arranged accordingly with adequate notification to all involved parties.
4.2 The RO shall be present to witness rotational deployment.
4.3 The ship owner shall obtain agreement with the RO on the number and location of units to be deployed and the RO will complete the checklist detailed in Annex 1. Records for the deployment of each MES, including any spare MES, shall be maintained and will include the dates of deployments.
Companies shall incorporate spare MES into their deployment program such that, as far as practicable, all MES are subject to equal periods between deployments.
4.4 Agreement shall be obtained on the number of liferafts, to include link liferafts that will be deployed from that station. It is important that NSI is able to verify on a selective basis, the ability of the system to effectively deploy and achieve effective evacuations within the timescale required by SOLAS.
4.5 The manufacturer, or his agent, together with a crew member(s) shall conduct an assessment to include thorough visual inspection and any pre-deployment checks necessary to evaluate MES readiness for safe deployment. This inspection must be documented by a pre-deployment checklist or other equivalent documentation, and subsequently presented to the RO witnessing the test.
4.6 No modification, alteration, servicing or any other preparations of MES may be carried out unless prior consent is given by the RO. Pre-deployment work may constitute failed deployment.
4.7 Rotational Deployment is a test of installed equipment. However, such deployment shall normally be conducted by competent ship’s staff in accordance with officially documented procedures. If completed by a combination of crew and service personnel, clear roles shall be established and agreed.
5 Deployment of MES and Failure Criteria
5.1 The unit to be deployed shall be prepared in accordance with an agreed action plan and following the procedures outlined in maker’s manuals and training guides. The outcome of the deployment including any failures will be recorded on the form at Annex 1.
5.2 Failure of the Deployment will be determined by the following factors:
5.2.1 During pre-deployment checks, actions were required without which deployment would not have occurred.
5.2.2 Deviations away from the Original Equipment Manufacturer (OEM) launching instructions were required in order to facilitate a launch.
5.2.3 Full MES capacity would not have been able to embark the rafts from the ship in the permitted time frame (taking into account the need for health and safety slow time and safe exercise requirements).
5.2.4 Any other reason as specified in Maker’s instruction
5.3 All of the above failure assessment criteria should be recorded on the form in Annex 1.
5.4 Should a full deployment have been achieved, having been classified as a failed deployment according to the above criteria, then the deployment will be additionally marked as a “Recoverable Failure” in Annex 1.
5.5 In the event the report considers the deployment a failure, the RO should be presented with a full report of the deployment from the manufacturer/agent within 1 month of the deployment. This report will outline the factors for the failure and remedial action to be taken for the installation in question. Also included are generic design defects which could compromise effective operation of the model in general. The report should be copied to the vessel and under IMO Resolution A.761(18) to the Notified Body responsible for the type approval, with particular regard to prospective generic model issues.
5.6 Once the RO is content with manufacturer’s actions in addition to any actions or modifications required by the Maker and accepted by the Notified Body and in conjunction with that organization, a re-deployment of the system may be requested in order to demonstrate that the system is working within acceptable parameters. Any modifications or alterations shall be approved by that Notified Body as applicable within the framework of the MED as amended.
6 Modifications to MES
6.1 Should the remedial actions identified in paragraph 5.2.1 require modification(s) to the MES, the proposed modification(s) cannot be made unless the Notified Body that approved the equipment verifies that the changes are acceptable, and if any additional tests are required for the equipment. Where changes are made that have been agreed by the Notified Body, they must be fully documented by the Maker in the technical file.
6.2 Any unauthorized modification to the MES will be seen as a change to the equipment, resulting in invalidating the approval and requiring the equipment to be re-tested and approved, as deemed applicable by the Notified Body within the framework of the MED as amended.
6.3 NSI will not approve any modification made to MES. This approval must come from the Notified Body who has previously approved the equipment, having been asked to do so by the manufacturer.
6.4 The Notified Body acting on behalf of the Administration, need not inform the RO of each approval for modification that it receives. If a modification is part of the remedial actions suggested as part of the manufacturer’s report of a failed deployment, the RO will be informed when it receives the report as per paragraph 5.3.
7 Use of Deployment as a Training Exercise
7.1 Ship owners, operators, managers and masters are encouraged to use these limited opportunities to familiarize crews with the MES installed onboard, in addition to any shore based training already in place.
7.2 Use for training purposes should be agreed with all parties involved and sequencing of events and objectives clearly identified.
7.3 The crew involved must have received adequate training and instruction prior to the deployment and exercise.
7.4 All crew assigned MES duties shall undertake training as indicated by the Ships Management System (SMS), Manufacturers Instructions and Training guidelines. Training should normally include annual MES descent, either on board, or at a training facility having a similar type of MES. Where the training facility MES differs from that found on board the crew members vessel, additional instruction shall be provided relating to the differences in the systems.
8 Deployment and Service History
Each MES unit will have a full service history including deployments which shall be available on board the vessel for inspection by all relevant authorities.
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Annex I - Record of Marine Evacuation System Deployment
- Attending surveyors should complete this form and return it to their Branch Office.
Operators and Manufacturers should make sure that this information is available to the attending surveyor.