Discussion: Nine out of 13 support this proposal; with 3 opposed and CLIA doubtful of the effects (however, as it would only affect cargo ships, it may not concern them)

Of those against, only China has a comment; of those in favour Spain requires some clarification, Denmark would like to know why cargo ships were originally omitted and the US would prefer some further consideration.

Norway realises that the issue needs further consideration and their proposed change to the regulation is therefore only an interim measure. Another point is that Norway is proposing to introduce new regulatory text which is rather more explicit than that already agreed to in the current EN, and will give it mandatory status. EN 9 currently reads:-

Cargo ships

9. If the Administration considers that the stability in intermediate stages of flooding in a cargo ship may be insufficient, it may require further investigation thereof.

Although a significant majority support Norway’s proposal, we should also bear in mind the responses to Q34 where a majority of 8 to 5 preferred to keep EN 9 as it is rather than change it into a regulation.

We should also note that there is a considerable difference between “found” and “[anticipated]”

in Norway’s proposal; the former implies a full calculation with extra work for the designer whereas the latter implies a judgement based on previous experience and possible discussions with the Administration.

Italy’s comments in answer to Q30 should surely also be taken into account as well, since applying intermediate stage flooding, as proposed by Norway, to the original sample of cargo ships could imply that “R” would need to be revised.

A further point is that the “complete” text of Reg 7-2.2 given in the co-ordinator’s note in Round 1 omits the limits for GZmax and range as well as the sentence relating to cross-flooding. The full regulation as proposed by Norway should therefore read something like:-

“2 For passenger ships the factor sintermediate,i is taken as the least of the s-factors obtained from all flooding stages including the stage before equalization, if any, and is to be calculated as follows:

where GZmax is not to be taken as more than 0.05 m and Range as not more than 7°.

sintermediate,i = 0, if the intermediate heel angle exceeds 15º.

For cargo ships the factor sintermediate,i is taken as unity, except in those cases where it is found [anticipated] that the ship would capsize and sink during the intermediate stages, in which case sintermediate,I is taken as 0.

[For passenger and cargo ships], where cross-flooding fittings are required, the time for equalization shall not exceed 10 min.”

Presumably, if Norway’s proposal were to be adopted, EN 9 could be deleted?

Finally, if we use “found” rather than “anticipated” in adopting Norway’s interim proposal, the implication is that a full stage-flooding calculation would also be needed for cargo ships. If we then equate “capsize and sink” with either GZmax or range = 0 or intermediate heel exceeding 15 degrees, then we may as well simply require passenger and cargo ships to be fully checked for sintermediate, i, changing the opening wording of the existing regulation to:-

2 The factor sintermediate,i is applicable only to passenger [and cargo] ships (for cargo ships sintermediate,i should be taken as unity) and shall be taken as the least of the s-factors obtained from all flooding stages including etc ………

and deleting EN9.

Summary. Given that 3 members are either opposed to any changes to Reg 7-2.2 and EN 9 for cargo ships or would like any reference to intermediate stage flooding for cargo ships removed altogether, it seems there are now 4 options open to us:

Option 1: Apply intermediate stage flooding only to passenger ships. Remove (for cargo ships

……. as unity) in Reg 7-2.2 and delete EN9.

Option 2: Leave Reg 7-2.2 and EN 9 as it stands – the Administration decides if further investigation is needed.

Option 3: Accept Norway’s proposal with the wording of the Regulation 7-2.2 as outlined above using the “anticipated” option in square brackets (slight word changes such as improving

“capsize and sink” may also be needed) and delete EN9.

Option 4: Apply intermediate stage flooding to both cargo and passenger ships. Modify the opening sentence of Reg 7-2.2 as shown above and delete EN9.

. Q32A. Bearing in mind also your previous response to Q34, please indicate which of the above 4 options you prefer – or give alternatives.

Option 1 China

Option 2 MI, France (with comments), Sweden

Option 3 Germany, Italy, Japan (with comment), Norway (with comment), UK, Denmark

Option 4 US

Comments / Alternatives?:- Japan: Japan prefers “anticipated”.

France: This question has been discussed several times and a compromise has been found as written in explanatory notes.

Formulation « in those cases where it is found [anticipated]” suppose that calculations have been done. (Is it possible to anticipate such problems without doing calculations?).

If such calculations are done, it would be logical to take them into account even if they don’t influence the attained index.

Norway: To Denmark’s query on exclusion of intermediate stages for cargo ships: The HARDER project proposed including intermediate stages for cargo ships but this was turned down by a small majority of members of the SDS correspondence group to SLF 47 with the argument that it was not required under the old chapter (i.e. not within the terms of reference).

See SLF 47/3/2 paragraph 13.

CLIA: Not directly relevant - cargo ship issue.

Round 2 Discussion:- Many thanks to Norway for providing the historical background to Denmark’s query in round 1. Opinion favours option 3 but it is by no means unanimous so the matter will have to go to the SLF 53 WG for further discussion to see if agreement can be reached. Option 2 (3 supporters) favours keeping the regulation and EN as they are. Option 3 (6 supporters) favours changing the text as follows and deleting EN 9.

2 For passenger ships the factor sintermediate,i is taken as the least of the s-factors obtained from all flooding stages including the stage before equalization, if any, and is to be calculated as follows:

where GZmax is not to be taken as more than 0.05 m and Range as not more than 7°.

sintermediate,i = 0, if the intermediate heel angle exceeds 15º.

For cargo ships the factor sintermediate,i is taken as unity, except in those cases where it is [found] [anticipated] that the ship would capsize and sink during the intermediate stages, in which case sintermediate,I is taken as 0.

[For passenger and cargo ships], where cross-flooding fittings are required, the time for equalization shall not exceed 10 min.”

France questions whether it is possible to anticipate whether a ship will capsize and sink during intermediate stage flooding without undertaking full stage-flooding calculations.

Q32B (for SLF 53 WG). Can you accept the majority view in favour of Norway’s interim proposal shown in the round 2 discussion above? If so, would you prefer use of the word “found” or “anticipated” as shown in square brackets?

Do you accept Norway’s proposal?

Denmark, Finland, Italy : yes (comments added in Round 4 response)

If yes, do you prefer

“found” or

“anticipated”?

Denmark, Italy : prefer “anticipated”

Finland : “found”. Refer also comment from France in Q32A

(comments added in Round 4 response) Further Comments / Alternatives?:-

Post SLF 53 Comment:- This item was discussed in some depth and, as reported in the report of the WG to plenary, option 2 from the Round 1 discussion notes was preferred (i.e. leave the regulation and EN unchanged, thereby allowing the Administration to decide if further investigation is needed for cargo ships). However, the WG chairman said that because of the variety of views expressed this issue could be re-opened in the 2011 CG.

Q32C (for Round 4 questionnaire):- This question relates to Norway’s interim proposal to calculate intermediate stages of flooding for cargo ships. For the full background and earlier discussions see the working document. As stated, the WG at SLF 53 preferred to make no changes but the chairman left the issue open for discussion in the 2011 CG. Do you therefore support Norway on this issue or do you prefer to leave the regulation as it stands? Q34 covers the EN.

Support Norway?

Yes: US, Norway, Finland No: Vanuatu

Other: Spain (In general terms yes, but we think that the sentence “would capsize and sink” should be clarified (based on s value calculations?, using passenger vessel criteria?). Obviously, it is not possible in cargo vessels to assume the same formula to evaluate the stability during intermediate stages of flooding, because, for example, in a cargo vessel a maximum final equilibrium angle of 30º is permitted (in the formula, only 15º is permitted for intermediate stages of flooding).

As a conclusion:

1) The best solution is to generate a new specific formula or criteria for cargo vessels intermediate stages of flooding.

2) If this solution is not possible, maybe a compromise solution is to add a sentence similar to the included in MARPOL Annex I: “The Administration shall be satisfied that the stability is sufficient during intermediate stages of flooding”.)

No change? Japan, China, Denmark, Germany, Italy, MI (leave as is) Further Comments?:-

Vanuatu: We align ourselves with Spain’s comment as reported from WG. Capsizing and sinking are two separate conditions; the second doesn’t necessarily follow the first, and not immediately.

Norway: With “anticipated” instead of “found”.

Japan: As expressed in the WG, Japan supports option 2.

RINA: With regards to Norway’s proposal which modifies the text with options for [found]

[anticipated] it is difficult to understand how ship designers are going to know when a ship will capsize and sink without carrying out calculations. This is also the line previously taken by France.

It is recognized that there are many cargo ships greater than 80 m in length, where designs vary from the traditional general cargo ship i.e. dedicated car carriers; research ships; supply ships, etc . Therefore it is considered that intermediate stage flooding should apply to both cargo and passenger ships and modify Para 7.2.2 as previously proposed:

“The factor sintermediate,i is applicable only to passenger and cargo ships (for cargo ships sintermediate,i should be taken as unity) and shall be taken as the least of the s-factors obtained from all flooding stages including etc”

Denmark: Leave it up to the Administration to decide.

UK: Considering the ease of running such calculations now, both passenger and cargo vessels must be treated the same way. Therefore the opening sentence may be modified to reflect this.

France: France prefers to leave the text as it is, until we are convinced that intermediate stages of flooding are absolutely necessary also for cargo ships.

Round 6 Discussion: Two members fully support Norway’s proposal requiring