1 Introduction
In accordance with Ships Decree 2004 Article 40 , a ship for which a Passenger Ship Safety Certificate (PSSC) or a Cargo Ship Safety Certificate (CSSC) is required shall satisfy, amongst others, the requirements of SOLAS Convention chapter III, as applicable.
This instruction aims to clarify the requirements for SOLAS regulation III/20.8.2 (Rotational deployments of Marine Evacuation Systems (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 the Netherlands Shipping Inspectorate (NSI) with respect to the provision of SOLAS regulation III/20.8.1.1 to extend the MES service interval.
Through these guidelines, the 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 MES as an appliance for the rapid transfer of persons from the embarkation deck of a ship to a floating survival craft.
Whilst they are maintained in readiness by annual servicing, the only opportunity to assess the system's ability to deploy in an emergency is the 6 yearly rotational deployment. The 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 an extension of service interval in excess of the 12 month window, under the provision of SOLAS regulation III/20.8.1.1, is limited to occasions when servicing is impracticable. Extension, when impracticable, shall not be confused with inconvenience.
3.2 Applications for extension shall be issued by the Recognised Organisation (RO) to the NSI, well in advance of the 12 month service date. The application shall be in accordance with ItoRO no. 15 - Reporting and procedure for non-compliance . This application shall clearly state the reason of impracticability and proposed time and place of service. The service history of the MES shall be presented in the application. Any extension of service shall not alter the initial anniversary date.
4 Deployment Preparation of MES
4.1 Rotational deployment, of each MES, required by SOLAS regulation III/20.8.2 cannot be extended beyond the six years period. It is recommended that deployment is arranged accordingly with adequate notification to all involved parties.
4.2 The RO shall be physically 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 shall 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.
4.4 If necessary in order to comply with SOLAS regulation III/20.8.2, companies will have to incorporate a spare MES into their deployment program such that, as far as practicable, all MES are subject to equal periods between deployments. 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 at least one crew member 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, otherwise it may constitute failed deployment.
4.7 Rotational deployment is a test of installed Life Saving Appliances (LSA) equipment and therefore such deployment shall normally be conducted by competent ship’s staff in accordance with officially documented procedures. In case this test is carried out by a combination of crew and service personnel, clear roles shall be established and agreed beforehand.
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 Original Equipment Manufacterer’s (OEM) manuals and training guides. The outcome of the deployment, including any failures, shall be recorded on the form at Annex 1.
5.2 Failure of the deployment will be determined by the following factors:
- During pre-deployment checks, actions were required without which deployment would not have occurred;
- Deviations away from the Original Equipment Manufacturer (OEM) launching instructions were required in order to facilitate a launch;
- Full MES capacity (assigned persons) would not have been able to embark the rafts from the ship in the permitted timeframe (taking into account the need for health and safety slow time and safe exercise requirements);
- Any other reason as specified in OEM’s instruction
5.3 All of the above failure (assessment) criteria shall 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 as a failed one, the RO shall be presented with a full report of the deployment from the OEM 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 shall be copied to the vessel and the NSI’s approved service station. In the event that the R.O. considers the root cause of the failure of the deployment of the MES to be a design error, the R.O. is encouraged to inform the relevant Notified Body, as well as the Netherlands Shipping Inspectorate of this.
5.6 Once the RO is content with manufacturer’s actions in addition to any actions or modifications required by the OEM and, if relevant, 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 Marine Equipment Directive (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 accepted by the Notified Body, they must be fully documented by the OEM in the technical file.
6.2 Any unauthorized modification to the MES will be considered as a change to the equipment, resulting in invalidating the type 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 The 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 OEM.
6.4 The Notified Body acting on behalf of the Administration, does not need to 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.
7.2 Use for training purposes should be agreed with all parties involved and sequencing of events and objectives should be 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), OEM's 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 system(s).
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 OEMs should make sure that this information is available to the attending surveyor.